I, Thomas D. Coates, declare as follows:
1. I am the Petitioner in this action and the former tenant of 3416 Warren Place, Apartment 201, Virginia Beach, Virginia 23452. I make this declaration based on my personal knowledge and on certified court records, docket extracts, and sheriff’s paperwork obtained in connection with General District Court case GV25037264‑00 and related matters.
2. This Exhibit A sets forth, in chronological order, key events in the unlawful detainer proceedings, the issuance of writs of possession and eviction in GV25037264‑00, and the execution of those writs by the sheriff, including where enforcement actions occurred without a properly docketed judgment for possession.
A. Prior Unlawful Detainer Proceedings and October–November 2025 Judgments
3. In 2025, Rose Hall Apartments LLC (also known as Rose Hall Village Associates) initiated multiple unlawful detainer actions against me in the Virginia Beach General District Court, including case numbers GV25031521‑00, GV25031898‑00, and GV25037264‑00.
4. On or about October 21, 2025, the General District Court held merits hearings at which I appeared pro se, asserted defenses under the Virginia Residential Landlord and Tenant Act, and presented a counterclaim regarding Rose Hall’s billing practices, notice defects, and interference with lawful rent payment.
5. Following those hearings, the court adjudicated two matters in my favor as to lawful tenancy and entered a judgment on my counterclaim awarding monetary relief and confirming my continued right of occupancy. An Abstract of Judgment in my favor issued on or about November 6, 2025.
6. In the weeks immediately after judgment, I filed and served a Motion for Attorney’s Fees and Costs and related enforcement and preservation notices, while Rose Hall simultaneously issued new five‑day notices and other post‑judgment communications referencing charges that had already been adjudicated.
7. The General District Court docket reflects that my fee motion was carried and continued without a prompt, dedicated hearing date, even as new and conflicting notices and demands were being served.
8. On or about December 9, 2025, I submitted supplemental motions requesting sanctions, clarification of the effect of the prior judgments on Rose Hall’s subsequent notices, and a scheduled hearing on the still‑pending fee motion.
9. On December 12, 2025, the General District Court entered an order enjoining further unlawful detainer filings in GV25031521‑00 and GV25031898‑00, prohibiting Rose Hall from filing additional unlawful detainer actions involving the same premises while existing actions were still pending.
B. January 13, 2026 – Writs Issued Without Docketed Judgment Predicate
10. On January 13, 2026, at approximately 9:14 a.m., the Odyssey case‑management system recorded issuance of both a writ of possession and a writ of eviction in GV25037264‑00.
11. At the time those writs were generated, the Odyssey docket for GV25037264‑00 contained no judgment event, no disposition code, no judicial authorization object, and no appeal‑period trigger. The case status remained “Pending,” with a merits hearing scheduled for March 10, 2026, fifty‑six days in the future.
12. Certified docket extracts and Odyssey event timelines, later transmitted to oversight bodies as part of a 128‑row Forensic State Transition Matrix, show that enforcement events overtook adjudication: writs were issued and transmitted to the sheriff in the absence of any properly docketed judgment authorizing possession.
13. Despite the December 12, 2025 order enjoining further unlawful detainer filings in related cases, writ‑level enforcement was generated and executed in GV25037264‑00 with no judgment for possession on the docket.
C. January 23, 2026 – Medical Continuance Request and Denial
14. Before January 23, 2026, the merits hearing in GV25037264‑00 was accelerated by the clerk from March 10 to January 26, significantly shortening my effective preparation time.
15. On January 23, 2026, while experiencing serious cardiac‑related medical symptoms, I filed an Emergency Motion for Continuance, Conditional Dismissal, and Verified Discovery, supported by medical information, asking that the January 26 accelerated hearing be continued for good‑cause medical reasons.
16. That motion was accepted for filing and date‑stamped, but my request for continuance was later denied by the judge, as reflected in a document bearing the judge’s initials denying continuance of my medical request for good cause. I retain a copy of that document.
17. As a result, the January 26 accelerated hearing remained in place despite my documented health issues and despite the prior continuance and scheduling latitude afforded to the landlord.
D. Motion to Quash and Execution of Writ on February 4, 2026
18. On January 22, 2026, I filed a Motion to Quash and Vacate Writ of Eviction in GV25037264‑00, expressly raising the absence of a final judgment for possession and the procedural defects in the writ‑issuance sequence.
19. The Motion to Quash was filed and docketed, but no ruling, stay, or suspension of the writ was recorded in Odyssey prior to execution.
20. On or about February 4, 2026, between approximately 8:30 a.m. and 9:10 a.m., a sheriff’s deputy executed the writ of eviction, and I was physically removed from 3416 Warren Place, Apartment 201, Virginia Beach, Virginia.
21. Sheriff’s paperwork and the writ posted on my door, which I photographed and retain as evidence, reflect the execution of the eviction; those documents are available as separate exhibits.
22. The eviction was executed thirty‑four days before the scheduled March 10, 2026 merits hearing, meaning enforcement preceded adjudication by more than a month in GV25037264‑00.
23. After the eviction, when I returned to the property on February 5, 2026 during the court‑allowed collection window, I found the door unlocked and my belongings in disarray; I documented this condition by photographs and notes, which I also retain.
E. Forensic Audit Submissions to Oversight Authorities
24. On February 12, 2026, I submitted a forensic audit packet to the Office of the Attorney General of Virginia, the Judicial Inquiry and Review Commission, the Virginia State Inspector General, and selected media outlets.
25. That packet included: (a) a 128‑row Forensic State Transition Matrix documenting whether enforcement‑relevant state transitions in Odyssey were supported by lawful predicates and adjudicative events; (b) a Mandamus Control Map confining requested relief to ministerial record correction and preservation of evidence; (c) a 64‑step Odyssey Audit Checklist for independent verification; and (d) certified exhibits such as the writs, orders, and my Motion to Quash.
26. As of the date of my PX8.5 filing, I have not received substantive responses from those oversight bodies, but the forensic materials show that the enforcement‑without‑judgment sequence in GV25037264‑00 is not an isolated clerical error; it reflects systemic workflow vulnerabilities in the Odyssey case‑management platform.
F. Serial Circuit Court E‑Filing Attempts and Rejections
27. Between September 24, 2025 and February 17, 2026, I made repeated good‑faith attempts to file Circuit‑Court‑ directed petitions and motions seeking declaratory, injunctive, sanctions, and mandamus‑style relief concerning the unlawful detainer proceedings and the enforcement‑without‑judgment sequence.
28. The e‑filing record reflects multiple envelopes that were rejected for varying and often inconsistent reasons, including that the matter was “not a Circuit Court matter,” that filings “must be filed with General District Court,” that fee‑waiver forms could not be accepted electronically, or that the initiating document was “not in proper Petition or Complaint format.”
29. Despite these rejections, I consistently tendered signed, captioned pleadings with numbered paragraphs and specific prayers for relief, selected “Declaratory Judgment – No Monetary Damages” as the civil case type when required, and attempted to comply with the clerk’s evolving instructions.
30. As a result of these serial rejections, I incurred more than $400.00 in filing‑related costs, including repeated payment of filing fees and associated service or transmission expenses, without ever obtaining a docketed Circuit Court case or judicial review on the merits.
31. None of the rejection messages cited a specific Virginia statute, Supreme Court Rule, or local administrative order that my pleadings violated; instead, they rested on characterizations that the matter “must be in GDC,” that the filings “looked like a letter,” or that appeals must start in GDC, even though my submissions explicitly sought original Circuit Court relief unavailable in General District Court.
Verification
I declare under penalty of perjury under the laws of the Commonwealth of Virginia that the foregoing is true and correct to the best of my knowledge, information, and belief.
______________________________________
/s/Thomas D. Coates
Date: 2/20/2026