DEFENDANT'S MOTION FOR RULE 7A:9 SANCTIONS
AGAINST LANDLORD AND COUNSEL FOR BAD FAITH
AND CLERK DOCKET MANIPULATION
TO THE HONORABLE COURT:
1.
LANDLORD AND COUNSEL HAD ACTUAL NOTICE OF CONTINUANCE REQUEST.
• 01/06/2026: 7-day VRLTA demand email (Exhibit 3-005)
• 01/12/2026: 24-hour continuance notice (Exhibit 3-004)
• 01/12/2026: Docketed continuance motion filed
• Despite actual notice, Plaintiff proceeded January 13, 2026 and obtained writs/dismissal
2.
Plaintiff's actions constitute bad faith proceeding subject to Rule 7A:9 sanctions.
Rule 7A:9 provides: "The court may impose sanctions on any party or attorney... for bad faith conduct, abuse of process, or failure to comply with court orders."
3.
POST-FILING CLERK MANIPULATION (Third Documented Incident):
• Defendant filed repair motion after January 13 hearing
• Clerk contacted Plaintiff during Defendant's visit
• Immediately after Defendant departed, unlawful detainer accelerated to Plaintiff's advantage
4.
VRLTA NONCOMPLIANCE: Plaintiff failed repeated demands for required ledgers and lease (§ 55.1-1234).
WHEREFORE, Defendant requests:
1.
Monetary sanctions against counsel ($500 minimum) [Rule 7A:9]
2.
Dismissal of illegal January 13 writs
3.
Docket freeze—no landlord changes without judge order
4.
JIRC referral for clerk pattern
5.
Confirm March 10 setting + sheriff execution stop
Exhibits: 3-001 thru 3-005 (timeline/demands) + Fax confirmation + March 10 court card
cc: Judicial Inquiry & Review Commission, P.O. Box 367, Richmond VA 23218
"Pattern clerk docket changes post-filing"
Thomas D. Coates
[Address]
[Phone]
[Email]
EMERGENCY FAX FILING | Faxed 01/26/26 8:01 AM from [Hospital]
Medical Necessity Due to Flu Appointment Conflict | All Rights Preserved