FORMAL RECORD CLARIFICATION AND OVERSIGHT NOTICE From: Thomas Coates 3416 Warren Place, Apartment 201 Virginia Beach, Virginia 23452 Primary Email for Response: Tdcoates@gmail.com April 24, 2026 To: Sergeant A. T. Standard, Professional Standards Office Sergeant J. Phelps, Professional Standards Office Virginia Beach Sheriff’s Office Virginia Beach, Virginia Email: Astandard@vbgov.com Case Reference: Sheriff Professional Standards – Case 26-02-023 CC (Complaint Received February 17, 2026) Re: Coates v. Rose Hall Apartments – Sheriff Complaint, Professional Standards Investigation Assigned to Captain W. Thomas, Scope of Record Reviewed, and Statutory Basis for Closure Copies Intended For: Virginia Attorney General; Appropriate Inspector General or Law‑Enforcement Civilian Oversight Body (as authorized by Va. Code § 9.1‑601); Court File in Coates v. Rose Hall Apartments (by e‑file); Additional Oversight or Reviewing Authorities as Needed. Dear Sergeant Standard and Sergeant Phelps: I. Purpose of This Correspondence This letter is submitted as a formal record clarification and oversight notice concerning the Professional Standards investigation opened under Case 26-02-023 CC in response to my complaint received by the Virginia Beach Sheriff’s Office on February 17, 2026, regarding the execution of the writ at 3416 Warren Place, Apartment 201, and the subsequent condition of the premises and property loss following eviction enforcement. It is intended to be read together with your acknowledgment letter advising that “an investigation has begun regarding your complaint received on February 17, 2026, concerning your court case,” the notice assigning the investigation to Captain W. Thomas, the conclusion correspondence, and related court and agency filings in Coates v. Rose Hall Apartments. My goal is not to seek confidential personnel details, but to ensure that the investigation’s scope and record basis can be clearly understood by the Sheriff’s Office, by the courts, and by any independent oversight body that may subsequently review this matter. This is especially important where the conclusions of an internal investigation may later be relied upon to describe what did or did not occur in connection with eviction enforcement and post‑eviction property handling. II. Background and Procedural Chain The relevant events, as reflected in the record, include the following: (1) The execution of the writ of eviction on or about February 4, 2026, when I was removed from 3416 Warren Place, Apartment 201, by a Deputy of the Virginia Beach Sheriff’s Office in connection with Coates v. Rose Hall Apartments, initiating the enforcement and possession timeline. (2) The court‑authorized retrieval window on February 5, 2026, and my return to the premises during that window, at which time the apartment was allegedly found unlocked, in disarray, and with items missing or unaccounted for, giving rise to serious concerns about unsecured premises, chain of access, and property loss associated with the enforcement sequence. (3) No fewer than five written filings and fax transmissions over approximately a three‑week period, addressed directly to the Sheriff’s Office, providing notice of legal objections, rights, and concerns regarding the impending and then‑executed eviction. These communications were sent in reliance on statutory and procedural requirements for notice and were directed to the Sheriff’s Office as the entity charged with lawful execution of the writ. (4) My formal complaint to the Virginia Beach Sheriff’s Office on or about February 17, 2026, concerning the execution of the writ, the handling of the premises, and the resulting property loss, which triggered the Professional Standards process and resulted in acknowledgment correspondence from your office stating that Case 26-02-023 CC had been opened and that “this investigation has been assigned to Captain W. Thomas.” (5) My separate effort to secure a non‑emergency incident report and reference number from the Virginia Beach Police Department to document post‑eviction property loss and unsecured premises, including initial direction to report in person and later identification of the Crime Reporting Unit phone reporting option. (6) The conclusion notice issued from the Professional Standards Office on or about March 2, 2026, advising that the investigation had been completed and closed and indicating that investigative materials and certain personnel information would not be released, with reference to applicable exemptions under the Virginia Freedom of Information Act, including Va. Code § 2.2‑3705.1 (“Exclusions to application of chapter; exclusions of general application to public bodies”). III. Clarification of Investigative Scope and Record Basis I fully recognize that Va. Code § 2.2‑3705.1 permits public bodies to withhold certain records, including personnel records and investigative materials, from mandatory disclosure, while also allowing discretionary disclosure by the custodian except where prohibited by law. I am not requesting confidential personnel files or privileged internal deliberations. Instead, I respectfully request clarification at the level of what categories of information were actually reviewed in Case 26-02-023 CC, so that any later reliance on the investigation’s conclusion can be properly evaluated. Specifically, I ask the Professional Standards Office to confirm, in general terms and without revealing protected details, whether the following categories of records and information were part of the investigative record actually considered by Captain W. Thomas and by your office: 1. Court filings and writ‑related materials in Coates v. Rose Hall Apartments, including the writ of possession itself, any motions or objections addressing the timing, method, or legality of execution, and any written notices or pleadings raising concerns that were directed to or copied to the Sheriff’s Office. 2. All faxed and written notices sent to the Sheriff’s Office during the three‑week period preceding and surrounding the eviction, including the no fewer than five filings that asserted rights, raised concerns about improper eviction, and requested lawful handling consistent with statutory requirements and due process. 3. Documentation reflecting the Deputy’s actions, timeline, and decision‑making on February 4, 2026, including any logs, reports, time stamps, or other operational records that would show how the writ was executed and whether any objections, accommodations, or warnings communicated to the Sheriff’s Office were reviewed or addressed. 4. Information regarding the condition of the premises and property at the time of the court‑authorized retrieval on February 5, 2026, including reports or statements relating to the unlocked apartment, disarray, and missing or unaccounted‑for items, as well as any related correspondence or documentation provided by me. 5. Any supplemental materials, exhibits, or communications submitted after the initial complaint—including emails, attachments, incident descriptions, and the results of my efforts to document property loss through the Virginia Beach Police Department—that were available to your office before the investigation was closed. Clarifying whether these categories of information were included or excluded is necessary so that the investigative conclusion is not later understood, or relied upon, as if it were based on a full and integrated record if, in fact, the review was more limited in scope. An internal investigation that does not incorporate the core court filings, formal notices, and documented property‑loss evidence connected to the Sheriff’s enforcement role can unintentionally create an incomplete picture of events and raise concerns for later reviewers about whether the process satisfied fundamental fairness and due‑process expectations. IV. Statutory and Oversight Context The Virginia Freedom of Information Act, Va. Code § 2.2‑3700 et seq., is grounded in the policy that “the affairs of government are not intended to be conducted in an atmosphere of secrecy,” subject to defined and limited exemptions such as those recognized in Va. Code § 2.2‑3705.1. At the same time, civilian oversight structures authorized under Va. Code § 9.1‑601 contemplate that independent bodies may review “the accuracy, completeness, and impartiality of such investigations and the sufficiency of any discipline resulting from such investigations.” In that context, a clear statement from the Professional Standards Office as to what categories of records were reviewed—without revealing protected details—serves the interests of the Sheriff’s Office, the courts, and any future oversight review by demonstrating that the investigation’s conclusion rests on a defined and identifiable record base. Conversely, where critical categories such as pre‑eviction notices, writ objections, or post‑eviction property documentation were not examined, it is important for that limitation to be expressly acknowledged so that external decision‑makers are not misled into assuming a level of completeness that did not, in fact, exist. V. Request for Clarification and Non‑Exempt Disclosures Accordingly, I respectfully request that the Professional Standards Office: (a) Confirm, in writing, whether each of the categories of records listed in Section III above was actually reviewed as part of Case 26-02-023 CC, or whether certain categories were not reviewed despite being reasonably available and directly relevant to the Sheriff’s execution of the writ and the subsequent property‑loss concerns. (b) Identify, to the extent permitted by law, whether any non‑exempt portions of the investigative record—such as my own statements, purely procedural notices, or administrative communications that do not reveal confidential personnel information—can be disclosed to me, consistent with the principles in Va. Code § 2.2‑3705.1 and the broader policy of Va. Code § 2.2‑3700 et seq. (c) Indicate whether any discretionary authority to release or summarize non‑personnel investigative information has been considered in light of the serious property interests at stake and the potential need for external oversight or judicial review of the Sheriff’s actions in this eviction sequence. If, upon review, your office concludes that the investigation did not encompass the full enforcement and notice chain—including the multiple faxed filings, court‑level objections, and documented concerns about unsecured premises and missing property—I ask that this limitation be explicitly stated. Such candor allows any future oversight body or court to decide whether a further or independent review is warranted, without unfairly placing the entire weight of factual narrative on an investigation that was, by design or in practice, narrow in scope. VI. Closing and Further Routing This correspondence is being prepared with the expectation that it may be included in the court record and provided to appropriate oversight or reviewing authorities, including, where applicable, the Office of the Attorney General and any law‑enforcement civilian oversight body authorized under Va. Code § 9.1‑601. The intent is not adversarial for its own sake, but to ensure that the Sheriff’s Office and all reviewing bodies can rely on a transparent and accurate understanding of what was and was not evaluated when the Professional Standards investigation was closed. I appreciate your attention to these issues and respectfully request a written response to the email address listed above, with any mailed copy sent to my address at 3416 Warren Place, Apartment 201, Virginia Beach, Virginia 23452. Please consider this letter part of the formal record associated with my complaint and with the Professional Standards investigation that followed under Case 26-02-023 CC. Respectfully, Thomas Coates Complainant / Tenant Coates v. Rose Hall Apartments Email: Tdcoates@gmail.com VB CITY OF VIRGINIA BEACH March 2, 2026 BEACH VIRGINIA VA N.D. "Rocky" Holcomb Sheriff/High Constable VIRGINIA BEACH SHERIFF'S OFFICE 2501 James Madison Boulevard Bldg. 7 Virginia Beach, VA 23456-9073 Thomas Coates Tdcoates@gmail.com RE: Case 26-02-023 CC Dear Mr. Coates, In response to the complaint received on February 17, 2026, concerning the action(s) of a member(s) of the Sheriff's Office, a thorough investigation has been conducted. Consistent with the provisions of Virginia State Law 2.2-3705.1, this Officc does not release the contents of investigative reports or personnel information. If you have any further questions conecrning this matter, please contact Captain W. Thomas at 757-385-4446 Monday through Friday, from 9:00 a.m. to 4:00 p.m. Sincerely, Sergeant .Phelpa 12-014 Sergeant J. Phelps Office of Professional Standards Cc: File VB CITY OF VIRGINIA BEACH VIRGINIABEACH VA S N.D. "Rocky" Holcomb Sheriff/High Constable VIRGINIA BEACH SHERIFF'S OFFICE 2501 James Madison Boulevard Bldg. 7 Virginia Beach, VA 23456-9073 February 17, 2026 Thomas Coates Tdcoates@gmail.com RE: Case 26-02-023 QC Dear Mr. Coates, This letter is to notify you that an investigation has begun regarding your complaint received on February 17, 2026, concerning your court case. This investigation has been assigned to Captain W. Thomas. I assure you that the Sheriff's Office takes all complaints seriously and will try to handle this expeditiously. If you have any further questions concerning this matter, please contact Captain Thomas at 757- 385-4446 Monday through Friday, from 9:00 a.m. to 4:00 p.m. Sincerely, Sergeant A. Standard Officc of Professional Standards Cc: File

Cover Letter Clerk of Court Circuit Court for the City of Virginia Beach 2425 Nimmo Parkway Virginia Beach, Virginia 23456 Re: Coates v. Rose Hall Apartments Case No.: CL26-1639 Dear Clerk: Please accept this correspondence as a formal electronic filing submitted for inclusion in the official record of the above-referenced matter. The enclosed document is titled: Notice of Record Clarification and Oversight Concern Regarding Sheriff Professional Standards Investigation (Case 26-02-023 CC) This filing is submitted pursuant to the Court’s authority to maintain a complete and accurate case record and is intended to preserve relevant procedural and factual information associated with the execution of the writ of possession, subsequent complaint to the Virginia Beach Sheriff’s Office, and the resulting Professional Standards investigation. This submission is not a motion and does not request immediate judicial relief. Rather, it is provided to ensure that the record reflects material facts and related oversight considerations that may bear upon future proceedings in this matter. To the extent applicable, this filing is made in alignment with: ● Va. Code § 17.1-258, governing the duties of the clerk in maintaining court records; ● Va. Code § 8.01-420 et seq., concerning filings and recordation in civil actions; and ● The Court’s inherent authority to consider matters properly placed within the record. This correspondence may also be relevant to matters involving: ● The execution of process by the Sheriff pursuant to Va. Code § 8.01-470 et seq.; ● The preservation and evaluation of notice, due process, and related procedural considerations; and ● The documentation of communications and filings associated with the enforcement sequence at issue. The filing party, Thomas Coates, appears pro se. The document is submitted in good faith for record clarification and preservation purposes and is not duplicative of any pending motion or request for relief. Please file and associate the enclosed document with the case record under Case No. CL26-1639. If any additional formatting, indexing, or procedural requirements are necessary to ensure proper acceptance, please advise and I will promptly comply. Thank you for your attention to this submission and for your continued assistance. Respectfully submitted, Virginia Beach Tina Sinnen By LM 4/27/2026 10:01 AM 4/24/2026 12:17 PM /s/Thomas Coates 3416 Warren Place, Apartment 201 Virginia Beach, Virginia 23452 Email: tdcoates@gmail.com FORMAL RECORD CLARIFICATION AND OVERSIGHT NOTICE From: Thomas Coates 3416 Warren Place, Apartment 201 Virginia Beach, Virginia 23452 Primary Email for Response: Tdcoates@gmail.com April 24, 2026 To: Sergeant A. T. Standard, Professional Standards Office Sergeant J. Phelps, Professional Standards Office Virginia Beach Sheriff’s Office Virginia Beach, Virginia Email: Astandard@vbgov.com Case Reference: Sheriff Professional Standards – Case 26-02-023 CC (Complaint Received February 17, 2026) Re: Coates v. Rose Hall Apartments – Sheriff Complaint, Professional Standards Investigation Assigned to Captain W. Thomas, Scope of Record Reviewed, and Statutory Basis for Closure Copies Intended For: Virginia Attorney General; Appropriate Inspector General or Law‑Enforcement Civilian Oversight Body (as authorized by Va. Code § 9.1‑601); Court File in Coates v. Rose Hall Apartments (by e‑file); Additional Oversight or Reviewing Authorities as Needed. Dear Sergeant Standard and Sergeant Phelps: I. Purpose of This Correspondence This letter is submitted as a formal record clarification and oversight notice concerning the Professional Standards investigation opened under Case 26-02-023 CC in response to my complaint received by the Virginia Beach Sheriff’s Office on February 17, 2026, regarding the execution of the writ at 3416 Warren Place, Apartment 201, and the subsequent condition of the premises and property loss following eviction enforcement. It is intended to be read together with your acknowledgment letter advising that “an investigation has begun regarding your complaint received on February 17, 2026, concerning your court case,” the notice assigning the investigation to Captain W. Thomas, the conclusion correspondence, and related court and agency filings in Coates v. Rose Hall Apartments. My goal is not to seek confidential personnel details, but to ensure that the investigation’s scope and record basis can be clearly understood by the Sheriff’s Office, by the courts, and by any independent oversight body that may subsequently review this matter. This is especially important where the conclusions of an internal investigation may later be relied upon to describe what did or did not occur in connection with eviction enforcement and post‑eviction property handling. II. Background and Procedural Chain The relevant events, as reflected in the record, include the following: (1) The execution of the writ of eviction on or about February 4, 2026, when I was removed from 3416 Warren Place, Apartment 201, by a Deputy of the Virginia Beach Sheriff’s Office in connection with Coates v. Rose Hall Apartments, initiating the enforcement and possession timeline. Virginia Beach Tina Sinnen By LM 4/27/2026 10:01 AM 4/24/2026 12:17 PM (2) The court‑authorized retrieval window on February 5, 2026, and my return to the premises during that window, at which time the apartment was allegedly found unlocked, in disarray, and with items missing or unaccounted for, giving rise to serious concerns about unsecured premises, chain of access, and property loss associated with the enforcement sequence. (3) No fewer than five written filings and fax transmissions over approximately a three‑week period, addressed directly to the Sheriff’s Office, providing notice of legal objections, rights, and concerns regarding the impending and then‑executed eviction. These communications were sent in reliance on statutory and procedural requirements for notice and were directed to the Sheriff’s Office as the entity charged with lawful execution of the writ. (4) My formal complaint to the Virginia Beach Sheriff’s Office on or about February 17, 2026, concerning the execution of the writ, the handling of the premises, and the resulting property loss, which triggered the Professional Standards process and resulted in acknowledgment correspondence from your office stating that Case 26-02-023 CC had been opened and that “this investigation has been assigned to Captain W. Thomas.” (5) My separate effort to secure a non‑emergency incident report and reference number from the Virginia Beach Police Department to document post‑eviction property loss and unsecured premises, including initial direction to report in person and later identification of the Crime Reporting Unit phone reporting option. (6) The conclusion notice issued from the Professional Standards Office on or about March 2, 2026, advising that the investigation had been completed and closed and indicating that investigative materials and certain personnel information would not be released, with reference to applicable exemptions under the Virginia Freedom of Information Act, including Va. Code § 2.2‑3705.1 (“Exclusions to application of chapter; exclusions of general application to public bodies”). III. Clarification of Investigative Scope and Record Basis I fully recognize that Va. Code § 2.2‑3705.1 permits public bodies to withhold certain records, including personnel records and investigative materials, from mandatory disclosure, while also allowing discretionary disclosure by the custodian except where prohibited by law. I am not requesting confidential personnel files or privileged internal deliberations. Instead, I respectfully request clarification at the level of what categories of information were actually reviewed in Case 26-02-023 CC, so that any later reliance on the investigation’s conclusion can be properly evaluated. Specifically, I ask the Professional Standards Office to confirm, in general terms and without revealing protected details, whether the following categories of records and information were part of the investigative record actually considered by Captain W. Thomas and by your office: 1. Court filings and writ‑related materials in Coates v. Rose Hall Apartments, including the writ of possession itself, any motions or objections addressing the timing, method, or legality of execution, and any written notices or pleadings raising concerns that were directed to or copied to the Sheriff’s Office. 2. All faxed and written notices sent to the Sheriff’s Office during the three‑week period preceding and surrounding the eviction, including the no fewer than five filings that asserted rights, raised concerns about improper eviction, and requested lawful handling consistent with statutory requirements and due process. 3. Documentation reflecting the Deputy’s actions, timeline, and decision‑making on February 4, 2026, including any logs, reports, time stamps, or other operational records that would show how the writ was executed and whether any objections, accommodations, or warnings communicated to the Sheriff’s Office were reviewed or addressed. 4. Information regarding the condition of the premises and property at the time of the court‑authorized retrieval on February 5, 2026, including reports or statements relating to the unlocked apartment, disarray, and missing or unaccounted‑for items, as well as any related correspondence or documentation provided by me. 5. Any supplemental materials, exhibits, or communications submitted after the initial complaint—including emails, attachments, incident descriptions, and the results of my efforts to document property loss through the Virginia Beach Police Department—that were available to your office before the investigation was closed. Clarifying whether these categories of information were included or excluded is necessary so that the investigative conclusion is not later understood, or relied upon, as if it were based on a full and integrated record if, in fact, the review was more limited in scope. An internal investigation that does not incorporate the core court filings, formal notices, and documented property‑loss evidence connected to the Sheriff’s enforcement role can unintentionally create an incomplete picture of events and raise concerns for later reviewers about whether the process satisfied fundamental fairness and due‑process expectations. IV. Statutory and Oversight Context The Virginia Freedom of Information Act, Va. Code § 2.2‑3700 et seq., is grounded in the policy that “the affairs of government are not intended to be conducted in an atmosphere of secrecy,” subject to defined and limited exemptions such as those recognized in Va. Code § 2.2‑3705.1. At the same time, civilian oversight structures authorized under Va. Code § 9.1‑601 contemplate that independent bodies may review “the accuracy, completeness, and impartiality of such investigations and the sufficiency of any discipline resulting from such investigations.” In that context, a clear statement from the Professional Standards Office as to what categories of records were reviewed—without revealing protected details—serves the interests of the Sheriff’s Office, the courts, and any future oversight review by demonstrating that the investigation’s conclusion rests on a defined and identifiable record base. Conversely, where critical categories such as pre‑eviction notices, writ objections, or post‑eviction property documentation were not examined, it is important for that limitation to be expressly acknowledged so that external decision‑makers are not misled into assuming a level of completeness that did not, in fact, exist. V. Request for Clarification and Non‑Exempt Disclosures Accordingly, I respectfully request that the Professional Standards Office: (a) Confirm, in writing, whether each of the categories of records listed in Section III above was actually reviewed as part of Case 26-02-023 CC, or whether certain categories were not reviewed despite being reasonably available and directly relevant to the Sheriff’s execution of the writ and the subsequent property‑loss concerns. (b) Identify, to the extent permitted by law, whether any non‑exempt portions of the investigative record—such as my own statements, purely procedural notices, or administrative communications that do not reveal confidential personnel information—can be disclosed to me, consistent with the principles in Va. Code § 2.2‑3705.1 and the broader policy of Va. Code § 2.2‑3700 et seq. (c) Indicate whether any discretionary authority to release or summarize non‑personnel investigative information has been considered in light of the serious property interests at stake and the potential need for external oversight or judicial review of the Sheriff’s actions in this eviction sequence. If, upon review, your office concludes that the investigation did not encompass the full enforcement and notice chain—including the multiple faxed filings, court‑level objections, and documented concerns about unsecured premises and missing property—I ask that this limitation be explicitly stated. Such candor allows any future oversight body or court to decide whether a further or independent review is warranted, without unfairly placing the entire weight of factual narrative on an investigation that was, by design or in practice, narrow in scope. VI. Closing and Further Routing This correspondence is being prepared with the expectation that it may be included in the court record and provided to appropriate oversight or reviewing authorities, including, where applicable, the Office of the Attorney General and any law‑enforcement civilian oversight body authorized under Va. Code § 9.1‑601. The intent is not adversarial for its own sake, but to ensure that the Sheriff’s Office and all reviewing bodies can rely on a transparent and accurate understanding of what was and was not evaluated when the Professional Standards investigation was closed. I appreciate your attention to these issues and respectfully request a written response to the email address listed above, with any mailed copy sent to my address at 3416 Warren Place, Apartment 201, Virginia Beach, Virginia 23452. Please consider this letter part of the formal record associated with my complaint and with the Professional Standards investigation that followed under Case 26-02-023 CC. Respectfully, Thomas Coates Complainant / Tenant Coates v. Rose Hall Apartments Email: Tdcoates@gmail.com VB CITY OF VIRGINIA BEACH March 2, 2026 BEACH VIRGINIA VA N.D. "Rocky" Holcomb Sheriff/High Constable VIRGINIA BEACH SHERIFF'S OFFICE 2501 James Madison Boulevard Bldg. 7 Virginia Beach, VA 23456-9073 Thomas Coates Tdcoates@gmail.com RE: Case 26-02-023 CC Dear Mr. Coates, In response to the complaint received on February 17, 2026, concerning the action(s) of a member(s) of the Sheriff's Office, a thorough investigation has been conducted. Consistent with the provisions of Virginia State Law 2.2-3705.1, this Officc does not release the contents of investigative reports or personnel information. If you have any further questions conecrning this matter, please contact Captain W. Thomas at 757-385-4446 Monday through Friday, from 9:00 a.m. to 4:00 p.m. Sincerely, Sergeant .Phelpa 12-014 Sergeant J. Phelps Office of Professional Standards Cc: File VB CITY OF VIRGINIA BEACH VIRGINIABEACH VA S N.D. "Rocky" Holcomb Sheriff/High Constable VIRGINIA BEACH SHERIFF'S OFFICE 2501 James Madison Boulevard Bldg. 7 Virginia Beach, VA 23456-9073 February 17, 2026 Thomas Coates Tdcoates@gmail.com RE: Case 26-02-023 QC Dear Mr. Coates, This letter is to notify you that an investigation has begun regarding your complaint received on February 17, 2026, concerning your court case. This investigation has been assigned to Captain W. Thomas. I assure you that the Sheriff's Office takes all complaints seriously and will try to handle this expeditiously. If you have any further questions concerning this matter, please contact Captain Thomas at 757- 385-4446 Monday through Friday, from 9:00 a.m. to 4:00 p.m. Sincerely, Sergeant A. Standard Officc of Professional Standards Cc: File

IN THE CIRCUIT COURT FOR THE CITY OF VIRGINIA BEACH COMMONWEALTH OF VIRGINIA THOMAS D. COATES, Petitioner, v. ROSE HALL APARTMENTS LLC (also known as Rose Hall Village Associates), et al., Respondents. Case No. CL-__________ (to be assigned) PETITION FOR DECLARATORY JUDGMENT, INJUNCTIVE RELIEF, SANCTIONS, AND SUPERVISORY RELIEF COMES NOW the Petitioner, Thomas D. Coates (“Petitioner”), pro se, and for his Petition for Declaratory Judgment, Injunctive Relief, Sanctions, and Supervisory Relief against Rose Hall Apartments LLC (also known as Rose Hall Village Associates) and associated officials and entities (collectively, “Respondents”), alleges as follows: A. Parties, Jurisdiction, and Venue 1. Petitioner is an adult resident of the City of Virginia Beach, formerly residing at 3416 Warren Place, Apartment 201, Virginia Beach, Virginia 23452. Petitioner appeared pro se in the underlying unlawful detainer proceedings in the Virginia Beach General District Court, including case GV25037264-00. 2. Respondent Rose Hall Apartments LLC, also known as Rose Hall Village Associates (“Rose Hall”), is a Virginia landlord entity that owns and operates the residential premises where Petitioner resided. Rose Hall initiated multiple unlawful detainer actions against Petitioner in 2025. 3. Other Respondents include, to the extent appropriate, officials and entities responsible for the operation and oversight of the Virginia Beach General District Court and related enforcement mechanisms, including but not limited to clerk’s office personnel and sheriff’s civil process/enforcement functions, insofar as they participated in or are necessary parties to the judgment–writ–eviction sequence described herein. 4. This Court has jurisdiction over this Petition pursuant to Va. Code § 8.01-184 and related provisions governing declaratory judgments, the Court’s equitable powers to issue injunctive relief, its authority to impose sanctions under Va. Code § 8.01-271.1, and its inherent and statutory supervisory authority over inferior courts and the ministerial operation of their dockets, records, and enforcement workflow. 5. Venue is proper in this Court because the underlying unlawful detainer proceedings, the premises, the writ issuance, and the sheriff’s execution all occurred in the City of Virginia Beach, and the parties and records at issue are located within this Circuit. B. Prior Unlawful Detainer Proceedings and October–November 2025 Judgments 6. In 2025, Rose Hall initiated multiple unlawful detainer actions against Petitioner in the Virginia Beach General District Court, including case numbers GV25031521-00, GV25031898-00, and GV25037264-00. 7. On or about October 21, 2025, the General District Court held merits hearings at which Petitioner 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. Virginia Beach Tina Sinnen By LM 3/27/2026 9:37 AM 3/26/2026 1:30 PM 26-1639 8. Following those hearings, the court adjudicated two matters in Petitioner’s favor as to lawful tenancy and entered a judgment on Petitioner’s counterclaim awarding monetary relief and confirming his continued right of occupancy. An Abstract of Judgment in Petitioner’s favor issued on or about November 6, 2025. 9. In the weeks immediately after judgment, Petitioner 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. 10. The General District Court docket reflects that Petitioner’s fee motion was carried and continued without a prompt, dedicated hearing date, even as new and conflicting notices and demands were being served. 11. On or about December 9, 2025, Petitioner 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. 12. 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. C. January 13, 2026 – Writs Issued Without Docketed Judgment Predicate 13. 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. 14. 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. 15. 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. 16. 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. D. January 23, 2026 – Acceleration, Medical Continuance Request, and Denial 17. Before January 23, 2026, the merits hearing in GV25037264-00 was accelerated by the clerk from March 10 to January 26, significantly shortening Petitioner’s effective preparation time. 18. On January 23, 2026, while experiencing serious cardiac-related medical symptoms, Petitioner 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. 19. That motion was accepted for filing and date-stamped, but Petitioner’s request for continuance was later denied by the judge, as reflected in a document bearing the judge’s initials denying continuance of Petitioner’s medical request for good cause; Petitioner retains a copy of that document. 20. As a result, the January 26 accelerated hearing remained in place despite Petitioner’s documented health issues and despite the prior continuance and scheduling latitude afforded to the landlord. E. Motion to Quash and Execution of Writ on February 4, 2026 21. On January 22, 2026, Petitioner 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. 22. The Motion to Quash was filed and docketed, but no ruling, stay, or suspension of the writ was recorded in Odyssey prior to execution. 23. 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 Petitioner was physically removed from 3416 Warren Place, Apartment 201, Virginia Beach, Virginia. 24. Sheriff’s paperwork and the writ posted on Petitioner’s door, which he photographed and retains as evidence, reflect the execution of the eviction; those documents are available as separate exhibits. 25. 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. 26. After the eviction, when Petitioner returned to the property on February 5, 2026 during the court-allowed collection window, he found the door unlocked and his belongings in disarray; he documented this condition by photographs and notes, which he also retains. F. Forensic Audit, Circuit Court Attempts, and Need for Relief 27. On February 12, 2026, Petitioner 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, including a 128-row Forensic State Transition Matrix (Exhibit A-1), a Mandamus Control Map, and a 64-step Odyssey Audit Checklist, along with certified copies of writs, orders, and the Motion to Quash. 28. Between September 24, 2025 and February 17, 2026, Petitioner made repeated good-faith attempts to file Circuit Court petitions and motions seeking declaratory, injunctive, sanctions, and supervisory relief concerning the unlawful detainer proceedings and the enforcement-without-judgment sequence, but multiple e-filing envelopes were rejected for shifting and often inconsistent reasons. 29. Petitioner 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 by eFileVA, and attempted to comply with the clerk’s evolving instructions, yet never obtained a docketed Circuit Court case or judicial review on the merits. 30. Petitioner has incurred more than $400.00 in filing-related costs, including repeated payment of filing fees and associated service or transmission expenses, without meaningful access to the Circuit Court’s adjudicative function. 31. Exhibits A (Declaration and Timeline Regarding Judgment–Writ–Eviction Sequence) and A-1 (State Transition Matrix – GV25037264-00 Selected Events) are incorporated herein by reference in support of the factual allegations and requested relief. Count I – Declaratory Judgment 32. An actual controversy exists regarding the legality and effect of the January 13, 2026 writ-issuance sequence in GV25037264-00 in the absence of a docketed judgment for possession, and regarding the lawfulness of enforcing a writ of eviction before adjudication and expiration of any appeal period. 33. Petitioner seeks a declaration that the writs of possession and eviction issued on January 13, 2026 in GV25037264-00 were void or voidable for want of a properly entered judgment predicate, and that enforcement of those writs constituted enforcement-without-judgment inconsistent with Virginia law and basic due process principles. Count II – Injunctive Relief 34. Petitioner requests prospective injunctive relief directing that no further use or reliance be placed on the defective writs or any derivative enforcement actions in GV25037264-00, and that Respondents take reasonable steps to correct and annotate the record so that future courts, agencies, and credit-reporting entities are not misled by an enforcement-without-judgment sequence. Count III – Sanctions (Va. Code § 8.01-271.1) 35. Petitioner seeks sanctions under Va. Code § 8.01-271.1 as to any attorney or party who advocated or relied upon the defective writs or opposed reasonable corrective measures after being placed on notice, if the Court finds that such conduct was not grounded in fact or law and unreasonably multiplied the proceedings or harms. Count IV – Supervisory Relief 36. Petitioner requests narrowly tailored supervisory relief directing ministerial correction and preservation of the Odyssey docket and associated records in GV25037264-00 (and any directly related case) to ensure that: (a) writ issuance is properly tied to docketed judgments for possession; (b) enforcement events do not precede adjudication; and (c) Petitioner’s filings, motions, and granted/denied continuances are accurately reflected. Prayer for Relief WHEREFORE, Petitioner respectfully prays that this Court: (a) Declare that the writs of possession and eviction issued on January 13, 2026 in GV25037264-00 were void or voidable for lack of a properly entered judgment predicate, and that the February 4, 2026 eviction constituted enforcement-without-judgment; (b) Issue appropriate injunctive relief to prevent further reliance on the defective writs or their consequences and to ensure accurate correction and annotation of the court record; (c) Consider and, if warranted, impose sanctions under Va. Code § 8.01-271.1 as to any attorney or party whose conduct in connection with the writs and subsequent enforcement was not grounded in fact or law; (d) Exercise its supervisory authority to direct ministerial correction and preservation of the Odyssey docket and related records, consistent with the Forensic State Transition Matrix attached as Exhibit A-1; (e) Award Petitioner his costs associated with this Petition, including any fees or expenditures reasonably incurred in pursuing corrective relief; and (f) Grant such other and further relief as the Court deems just and proper. 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. Dated: 3/18/2026 /s/ Thomas D. Coates Thomas D. Coates, Petitioner, pro se Signature Block Respectfully submitted, Dated: 3/18/2026 /s/ Thomas D. Coates Thomas D. Coates, Petitioner, pro se 3416 Warren Place, Apt. 201 Virginia Beach, VA 23452 (757) 374-3539 tdcoates@gmail.com COVER SHEET FOR FILING CIVIL ACTIONS Case No. ............................................................................... COMMONWEALTH OF VIRGINIA (CLERK’S OFFICE USE ONLY) ................................................................................................................................................................................................................................. Circuit Court ................................................................................................................................... v./In re: ......................................................................................................................... PLAINTIFF(S) DEFENDANT(S) ................................................................................................................................... ......................................................................................................................... I, the undersigned [ ] plaintiff [ ] defendant [ ] attorney for [ ] plaintiff [ ] defendant hereby notify the Clerk of Court that I am filing the following civil action. (Please indicate by checking box that most closely identifies the claim being asserted or relief sought.) GENERAL CIVIL Subsequent Actions [ ] Claim Impleading Third Party Defendant [ ] Monetary Damages [ ] No Monetary Damages [ ] Counterclaim [ ] Monetary Damages [ ] No Monetary Damages [ ] Cross Claim [ ] Interpleader [ ] Reinstatement (other than divorce or driving privileges) [ ] Removal of Case to Federal Court Business & Contract [ ] Attachment [ ] Confessed Judgment [ ] Contract Action [ ] Contract Specific Performance [ ] Detinue [ ] Garnishment Property [ ] Annexation [ ] Condemnation [ ] Ejectment [ ] Encumber/Sell Real Estate [ ] Enforce Vendor’s Lien [ ] Escheatment [ ] Establish Boundaries [ ] Landlord/Tenant [ ] Unlawful Detainer [ ] Mechanics Lien [ ] Partition [ ] Quiet Title [ ] Termination of Mineral Rights Tort [ ] Asbestos Litigation [ ] Compromise Settlement [ ] Intentional Tort [ ] Medical Malpractice [ ] Motor Vehicle Tort [ ] Product Liability [ ] Wrongful Death [ ] Other General Tort Liability ADMINISTRATIVE LAW [ ] Appeal/Judicial Review of Decision of (select one) [ ] ABC Board [ ] Board of Zoning [ ] Compensation Board [ ] DMV License Suspension [ ] Employee Grievance Decision [ ] Employment Commission [ ] Local Government [ ] Marine Resources Commission [ ] School Board [ ] Voter Registration [ ] Other Administrative Appeal DOMESTIC/FAMILY [ ] Adoption [ ] Adoption – Foreign [ ] Adult Protection [ ] Annulment [ ] Annulment – Counterclaim/Responsive Pleading [ ] Child Abuse and Neglect – Unfounded Complaint [ ] Civil Contempt [ ] Divorce (select one) [ ] Complaint – Contested* [ ] Complaint – Uncontested* [ ] Counterclaim/Responsive Pleading [ ] Reinstatement – Custody/Visitation/Support/Equitable Distribution [ ] Separate Maintenance [ ] Separate Maintenance Counterclaim WRITS [ ] Certiorari [ ] Habeas Corpus [ ] Mandamus [ ] Prohibition [ ] Quo Warranto PROBATE/WILLS AND TRUSTS [ ] Accounting [ ] Aid and Guidance [ ] Appointment (select one) [ ] Guardian/Conservator [ ] Standby Guardian/Conservator [ ] Custodian/Successor Custodian (UTMA) [ ] Trust (select one) [ ] Impress/Declare [ ] Reformation [ ] Will (select one) [ ] Construe [ ] Contested MISCELLANEOUS [ ] Appointment (select one) [ ] Church Trustee [ ] Conservator of Peace [ ] Marriage Celebrant [ ] Bond Forfeiture Appeal [ ] Declaratory Judgment [ ] Declare Death [ ] Driving Privileges (select one) [ ] Reinstatement pursuant to § 46.2-427 [ ] Restoration – Habitual Offender or 3rd Offense [ ] Expungement [ ] Firearms Rights – Restoration [ ] Forfeiture of U.S. Currency [ ] Freedom of Information [ ] Injunction [ ] Interdiction [ ] Interrogatory [ ] Judgment Lien-Bill to Enforce [ ] Law Enforcement/Public Official Petition [ ] Name Change [ ] Referendum Elections [ ] Sever Order [ ] Taxes (select one) [ ] Correct Erroneous State/Local [ ] Delinquent [ ] Vehicle Confiscation [ ] Voting Rights – Restoration [ ] Other (please specify) ............................................................................... [ ] Damages in the amount of $ ................................................................. are claimed. ....................................................................... _____________________________________________________________________ DATE [ ] PLAINTIFF [ ] DEFENDANT [ ] ATTORNEY FOR [ ] PLAINTIFF [ ] DEFENDANT ................................................................................................................................................ PRINT NAME ................................................................................................................................................ ADDRESS/TELEPHONE NUMBER OF SIGNATOR ................................................................................................................................................ ................................................................................................................................................ EMAIL ADDRESS OF SIGNATOR (OPTIONAL) *“Contested” divorce means any of the following matters are in dispute: grounds of divorce, spousal support and maintenance, child custody and/or visitation, child support, property distribution or debt allocation. An “Uncontested” divorce is filed on no fault grounds and none of the above issues are in dispute. FORM CC-1416 (MASTER) PAGE ONE 10/14 Clear All Data City of Virginia Beach Thomas D. Coates Rose Hall Apartments, et al. 0.00 February 20, 2026Thomas D. Coates 3416 Warren Place Apt 201, Virginia Beach, VA 23452 757 374-3539 tdcoates@gmail.com Virginia Beach Tina Sinnen By LM 3/27/2026 9:37 AM 3/26/2026 1:30 PM CL26-1639 Note: did not submit exhibits with the complaint - LAM / 3.27.26 IN THE CIRCUIT COURT FOR THE CITY OF VIRGINIA BEACH COMMONWEALTH OF VIRGINIA THOMAS D. COATES, Petitioner, v. ROSE HALL APARTMENTS LLC (also known as Rose Hall Village Associates), et al., Respondents. Case No. CL-__________ (to be assigned) PETITION FOR DECLARATORY JUDGMENT, INJUNCTIVE RELIEF, SANCTIONS, AND SUPERVISORY RELIEF COMES NOW the Petitioner, Thomas D. Coates (“Petitioner”), pro se, and for his Petition for Declaratory Judgment, Injunctive Relief, Sanctions, and Supervisory Relief against Rose Hall Apartments LLC (also known as Rose Hall Village Associates) and associated officials and entities (collectively, “Respondents”), alleges as follows: A. Parties, Jurisdiction, and Venue 1. Petitioner is an adult resident of the City of Virginia Beach, formerly residing at 3416 Warren Place, Apartment 201, Virginia Beach, Virginia 23452. Petitioner appeared pro se in the underlying unlawful detainer proceedings in the Virginia Beach General District Court, including case GV25037264-00. 2. Respondent Rose Hall Apartments LLC, also known as Rose Hall Village Associates (“Rose Hall”), is a Virginia landlord entity that owns and operates the residential premises where Petitioner resided. Rose Hall initiated multiple unlawful detainer actions against Petitioner in 2025. 3. Other Respondents include, to the extent appropriate, officials and entities responsible for the operation and oversight of the Virginia Beach General District Court and related enforcement mechanisms, including but not limited to clerk’s office personnel and sheriff’s civil process/enforcement functions, insofar as they participated in or are necessary parties to the judgment–writ–eviction sequence described herein. 4. This Court has jurisdiction over this Petition pursuant to Va. Code § 8.01-184 and related provisions governing declaratory judgments, the Court’s equitable powers to issue injunctive relief, its authority to impose sanctions under Va. Code § 8.01-271.1, and its inherent and statutory supervisory authority over inferior courts and the ministerial operation of their dockets, records, and enforcement workflow. 5. Venue is proper in this Court because the underlying unlawful detainer proceedings, the premises, the writ issuance, and the sheriff’s execution all occurred in the City of Virginia Beach, and the parties and records at issue are located within this Circuit. B. Prior Unlawful Detainer Proceedings and October–November 2025 Judgments 6. In 2025, Rose Hall initiated multiple unlawful detainer actions against Petitioner in the Virginia Beach General District Court, including case numbers GV25031521-00, GV25031898-00, and GV25037264-00. 7. On or about October 21, 2025, the General District Court held merits hearings at which Petitioner 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. Virginia Beach Tina Sinnen By LM 3/27/2026 9:37 AM 3/26/2026 1:30 PM 26-1639 8. Following those hearings, the court adjudicated two matters in Petitioner’s favor as to lawful tenancy and entered a judgment on Petitioner’s counterclaim awarding monetary relief and confirming his continued right of occupancy. An Abstract of Judgment in Petitioner’s favor issued on or about November 6, 2025. 9. In the weeks immediately after judgment, Petitioner 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. 10. The General District Court docket reflects that Petitioner’s fee motion was carried and continued without a prompt, dedicated hearing date, even as new and conflicting notices and demands were being served. 11. On or about December 9, 2025, Petitioner 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. 12. 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. C. January 13, 2026 – Writs Issued Without Docketed Judgment Predicate 13. 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. 14. 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. 15. 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. 16. 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. D. January 23, 2026 – Acceleration, Medical Continuance Request, and Denial 17. Before January 23, 2026, the merits hearing in GV25037264-00 was accelerated by the clerk from March 10 to January 26, significantly shortening Petitioner’s effective preparation time. 18. On January 23, 2026, while experiencing serious cardiac-related medical symptoms, Petitioner 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. 19. That motion was accepted for filing and date-stamped, but Petitioner’s request for continuance was later denied by the judge, as reflected in a document bearing the judge’s initials denying continuance of Petitioner’s medical request for good cause; Petitioner retains a copy of that document. 20. As a result, the January 26 accelerated hearing remained in place despite Petitioner’s documented health issues and despite the prior continuance and scheduling latitude afforded to the landlord. E. Motion to Quash and Execution of Writ on February 4, 2026 21. On January 22, 2026, Petitioner 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. 22. The Motion to Quash was filed and docketed, but no ruling, stay, or suspension of the writ was recorded in Odyssey prior to execution. 23. 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 Petitioner was physically removed from 3416 Warren Place, Apartment 201, Virginia Beach, Virginia. 24. Sheriff’s paperwork and the writ posted on Petitioner’s door, which he photographed and retains as evidence, reflect the execution of the eviction; those documents are available as separate exhibits. 25. 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. 26. After the eviction, when Petitioner returned to the property on February 5, 2026 during the court-allowed collection window, he found the door unlocked and his belongings in disarray; he documented this condition by photographs and notes, which he also retains. F. Forensic Audit, Circuit Court Attempts, and Need for Relief 27. On February 12, 2026, Petitioner 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, including a 128-row Forensic State Transition Matrix (Exhibit A-1), a Mandamus Control Map, and a 64-step Odyssey Audit Checklist, along with certified copies of writs, orders, and the Motion to Quash. 28. Between September 24, 2025 and February 17, 2026, Petitioner made repeated good-faith attempts to file Circuit Court petitions and motions seeking declaratory, injunctive, sanctions, and supervisory relief concerning the unlawful detainer proceedings and the enforcement-without-judgment sequence, but multiple e-filing envelopes were rejected for shifting and often inconsistent reasons. 29. Petitioner 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 by eFileVA, and attempted to comply with the clerk’s evolving instructions, yet never obtained a docketed Circuit Court case or judicial review on the merits. 30. Petitioner has incurred more than $400.00 in filing-related costs, including repeated payment of filing fees and associated service or transmission expenses, without meaningful access to the Circuit Court’s adjudicative function. 31. Exhibits A (Declaration and Timeline Regarding Judgment–Writ–Eviction Sequence) and A-1 (State Transition Matrix – GV25037264-00 Selected Events) are incorporated herein by reference in support of the factual allegations and requested relief. Count I – Declaratory Judgment 32. An actual controversy exists regarding the legality and effect of the January 13, 2026 writ-issuance sequence in GV25037264-00 in the absence of a docketed judgment for possession, and regarding the lawfulness of enforcing a writ of eviction before adjudication and expiration of any appeal period. 33. Petitioner seeks a declaration that the writs of possession and eviction issued on January 13, 2026 in GV25037264-00 were void or voidable for want of a properly entered judgment predicate, and that enforcement of those writs constituted enforcement-without-judgment inconsistent with Virginia law and basic due process principles. Count II – Injunctive Relief 34. Petitioner requests prospective injunctive relief directing that no further use or reliance be placed on the defective writs or any derivative enforcement actions in GV25037264-00, and that Respondents take reasonable steps to correct and annotate the record so that future courts, agencies, and credit-reporting entities are not misled by an enforcement-without-judgment sequence. Count III – Sanctions (Va. Code § 8.01-271.1) 35. Petitioner seeks sanctions under Va. Code § 8.01-271.1 as to any attorney or party who advocated or relied upon the defective writs or opposed reasonable corrective measures after being placed on notice, if the Court finds that such conduct was not grounded in fact or law and unreasonably multiplied the proceedings or harms. Count IV – Supervisory Relief 36. Petitioner requests narrowly tailored supervisory relief directing ministerial correction and preservation of the Odyssey docket and associated records in GV25037264-00 (and any directly related case) to ensure that: (a) writ issuance is properly tied to docketed judgments for possession; (b) enforcement events do not precede adjudication; and (c) Petitioner’s filings, motions, and granted/denied continuances are accurately reflected. Prayer for Relief WHEREFORE, Petitioner respectfully prays that this Court: (a) Declare that the writs of possession and eviction issued on January 13, 2026 in GV25037264-00 were void or voidable for lack of a properly entered judgment predicate, and that the February 4, 2026 eviction constituted enforcement-without-judgment; (b) Issue appropriate injunctive relief to prevent further reliance on the defective writs or their consequences and to ensure accurate correction and annotation of the court record; (c) Consider and, if warranted, impose sanctions under Va. Code § 8.01-271.1 as to any attorney or party whose conduct in connection with the writs and subsequent enforcement was not grounded in fact or law; (d) Exercise its supervisory authority to direct ministerial correction and preservation of the Odyssey docket and related records, consistent with the Forensic State Transition Matrix attached as Exhibit A-1; (e) Award Petitioner his costs associated with this Petition, including any fees or expenditures reasonably incurred in pursuing corrective relief; and (f) Grant such other and further relief as the Court deems just and proper. 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. Dated: 3/26/2026 /s/ Thomas D. Coates Thomas D. Coates, Petitioner, pro se Signature Block Respectfully submitted, Dated: 3/26/2026 /s/ Thomas D. Coates Thomas D. Coates, Petitioner, pro se 3416 Warren Place, Apt. 201 Virginia Beach, VA 23452 (757) 374-3539 tdcoates@gmail.com IN THE CIRCUIT COURT FOR THE CITY OF VIRGINIA BEACH COMMONWEALTH OF VIRGINIA Thomas D. Coates, Petitioner, v. Rose Hall Apartments LLC, et al., Respondents. Case No. CL‑__________ (to be assigned) NOTICE REGARDING CLERK’S MINISTERIAL ROLE AND REQUEST FOR JUDICIAL HANDLING OF ANY DEFECTS COMES NOW Petitioner, Thomas D. Coates, pro se, and respectfully states as follows: Petitioner is submitting, with this Notice, a Petition for Declaratory Judgment, Injunctive Relief, Sanctions, and Supervisory Relief as a new civil action classified as “Declaratory Judgment – No Monetary Damages,” with all required filing fees to be paid in full. Petitioner acknowledges the high volume of filings processed by the Clerk’s Office and the importance of consistent intake practices. Petitioner does not ask the Clerk to make any determination about the legal sufficiency, merits, or jurisdictional posture of the Petition. Petitioner respectfully requests that the Clerk treat the attached Petition and civil cover sheet as technically sufficient for docketing and fee assessment, and that any questions about classification, scope of relief, or interaction with General District Court proceedings be reserved for the assigned judge. To the extent there is any perceived ambiguity about case type, relief requested, or prior filing history, Petitioner expressly requests that: (a) this action be docketed as an original civil matter; and (b) any concern about defects or objections be addressed, if at all, through motions practice before the Court rather than by rejection at the intake stage. Petitioner will promptly file any clarifying amendments or supplemental materials the Court may direct, and is prepared to comply with any scheduling or case‑management orders the Court deems appropriate. WHEREFORE, Petitioner respectfully asks that the Clerk accept and docket the accompanying Petition in the ordinary course as an original civil action, and that any issues beyond basic technical compliance be submitted to the Court for determination. Dated: March 18, 2026 /s/Thomas D. Coates Pro Se Petitioner 3416 Warren Place, Apt. 201 Virginia Beach, VA 23452 Phone: 757‑374‑3539 Email: tdcoates@gmail.com Virginia Beach Tina Sinnen By LM 3/27/2026 9:37 AM 3/26/2026 1:30 PM 26-1639