IN THE CIRCUIT COURT OF THE CITY OF VIRGINIA BEACH

Thomas D. Coates
Plaintiff

v.

Rose Hall Apartments LLC, et al.
Defendants

Case No. CL26-1639

PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF RECORD,
VERIFY JUDGMENT PREDICATE, AND FOR LIMITED CORRECTIVE RELIEF

I. NATURE OF THIS MOTION

This motion presents a narrow, record-based question: whether a writ of eviction and its execution were supported by a valid, docketed judgment for possession at the time of issuance.

Plaintiff does not seek re-weighing of facts, but requests verification of the existence and integrity of the required adjudicative predicate.

II. CORE ISSUE PRESENTED

Plaintiff has submitted filings demonstrating that:

• A writ was issued on or about January 13, 2026
• Eviction was executed on or about February 4, 2026
• The matter remained pending until a scheduled hearing on March 10, 2026

The record, as currently available, does not demonstrate the existence of a properly entered judgment for possession prior to those enforcement actions.

III. REQUEST FOR PRODUCTION (LIMITED AND SPECIFIC)

Plaintiff respectfully requests production of records sufficient to establish:

1. Judgment Predicate
Any docketed judgment for possession, including entry date, judicial authority, and associated record identification.

2. Writ Authorization Record
Data supporting issuance of the writ, including certifications, supporting documentation, and workflow approvals.

3. System Audit Records
Logs reflecting case status, validation steps, and sequence of events relating to judgment, writ issuance, and execution.

4. Clerk Filing Records
Records showing receipt and handling of Plaintiff’s prior filings submitted January 25, March 9, and March 10, 2026.

IV. LIMITED RELIEF REQUESTED

Pending verification, Plaintiff respectfully requests:

• Review of enforcement actions for compliance with required predicate conditions
• No retroactive validation of enforcement actions absent verified judgment support
• Consideration of referral to the original presiding judge from the October 21, 2025 proceeding for continuity and record clarity

V. BASIS FOR RELIEF

This motion is grounded in the requirement that enforcement actions be supported by a valid judgment, and in the Court’s authority to ensure procedural integrity and record accuracy.

VI. CONCLUSION

Plaintiff does not request factual adjudication at this stage.

Plaintiff requests only that the record answer a single question:

Whether a lawful judgment for possession existed prior to writ issuance and execution.

WHEREFORE, Plaintiff respectfully requests that this Court grant the limited relief requested herein.

Respectfully submitted,

Thomas D. Coates
Pro Se