Notice of Intent to File Lawsuit

February 6, 2023

Insert Your Full Name

Insert Your Address

Insert Your State & ZIP Code




To the Chief Executive Officer, 

WoodSpring Suites Quantico

1006 Corporate Dr, 

Stafford, VA 22554


Dear Sir/Madam,


This letter serves as a formal notice that I intend to file a lawsuit against WoodSpring Suites Quantico (hereinafter referred to as “WoodSpring”) for harassment and discrimination. I checked into WoodSpring on 10/12/2020. I intended to stay at WoodSpring as my main residence. I am a person living with a visual disability; hence I have a service dog. I made special requests because of my disability, such as a room next to the exit so I could walk my service dog. I was not given the room I requested. The receptionist asked me to sign a document that I couldn’t read. I asked him what it was and he told me that it was a standard document signed by all guests. 

I requested a roll-in shower chair to help me with my disability. I was told that it would be brought to my room. That was the same answer when I followed up over three weeks. It was never brought. Later, a member of staff admitted that portable chairs were not available. I asked if there was a room for disabled persons on the ground floor, as stipulated in the Americans with Disabilities Act (ADA). I was informed that they were all fully booked, while in truth, there were rooms for disabled persons available. I was denied a room for disabled persons for no reason. 

WoodSpring staff began harassing me over my service dog on 10/13/2020. As I was walking my service dog, a member of staff approached me and asked me to walk my dog at the designated dog area. I complied. However, I realized that it was too far. The following day, I walked my service dog next to the side door. I was approached by a member of staff. I informed her that the designated dog area was far and my disability made it difficult for me to get there. I was threatened with a $250 fine. I went and complained to Ms. April who informed me that I could move in to the room near the exit the following day. The room had been unoccupied all along but I had to reiterate the ADA for me to be allowed to move in. All of this was unnecessary. Since the room was empty, I should have been allowed to move in from the beginning to avoid all this.

The following day after Ms. April allowed me to move in to the room near the exit, I realized that none of the staff had been informed of the room switch and Ms. April was not present. I asked a friend to help me move some things into a cart. We moved as much as we could until he had to return to work. The following day, Ms. April showed up and told me that I had to move immediately. I could not move things by myself because of my visual disability. I tried to tell her that I couldn’t but she insisted that I move immediately. It was clearly impossible for me to move my things because of my disability. I was stripped off my dignity at that person. I have never felt so humiliated in my lfife. The staff helped me move. 

Ms. April accused me of stealing two items from the first room, a lamp and a chair.  Confused, I explained that I moved the desk chair that I brought with me, but she said no.  I showed her my room and said I didn’t know what she was referring to, although my new room had both of these items.  They never were in my first room.  I checked with her the next morning and she said they figured it out.

I was having issues with my room key deactivating.  We’re talking 3-6 times a day. I found it frustrating because, its not the easiest to walk to the front desk that many times.  At first we thought it was cell phone, then my keys etc didn’t make sense to me because I rarely carry those things anyway.  I had multiple conversations with front desk staff to try and resolve the issue.  I followed all suggestions to the point I removed everything from my bathroom counter and only placed my door key there, the situation didn’t improve.  I asked Ms. April if it could be a battery issue or if they could call the lock company to see what they suggested.  She said it wasn’t battery related and I believe she never made the call.  Instead, she tried to fine me. The WoodSpring policy states they can charge guests for lost keys. I pointed out that I didn’t loose any key, they stopped working.  I pointed out the 3 times I have spent time brainstorming with the staff to try and figure out the issue.  Everyone was out of ideas but no one would bother speaking with the company or checking the battery. Fortunately, the night shift realized how ridiculous this was and would issue me multiple cards.  Even still there were a few times, I ended up waiting quite awhile, once over three hours.  My main issue was that my service dog was locked inside my room and twice I was late taking my medication.

One morning I got a knock on my door. WoodSpring staff were trying to enter my room without my awareness and permission, but they didn’t realize I was still inside. Over the following few hours, management admitted to police that they had been sneaking into my room, when they saw me leave, on their security cameras.  I had zero awareness of this.  I had actually walked my service dog early that morning so I was in the room. I answered the door and they basically told me to let them in for inspection.  I explained I had just gotten up so they gave me 15 minutes. When they returned, I explained that this seems very strange, I had been there almost 3 months and never heard of this before.  I declined and stated I wanted to look into my rights. Management said they had been entering my room because I had declined cleaning so they felt the need to inspect.  I said I had no issue with inspection but this was a violation of privacy.  

After I submitted my case for review, it was pointed out that they were not actually entering to inspect.  After stating I wanted time to look into my rights, WoodSpring evicted me with one hour to vacate.  They stated if I was not out they would have me arrested and removed.  I immediately requested and ADA accomodation, which they would have legally been required to grant me since they were fully aware of my ability to pack and leave within that time frame.  They ignored my request.

I later realized they were actually attempting to sneak into my room, again. I called the police and requested their service. They arrived and the first visit went off well.  They explained they could only mediate because it was a civil matter.  I explained I had no issue with them doing inspections I just wanted my rights respected.  24 hour notice and they are free to do what they wish.  We worked out an agreement, I allowed the inspection while the police were there. As they left I was called to the front desk. Mr. Tyree, the general manager was basically, almost yelling, saying its his hotel, he can go into any room, for any reason, at any time.  He was basically trying to force me to agree, which I did not. I was evicted because he could not force me to agree with his statements.  I walked away, returned to my room.  Fearing further retaliation, I called the front office and requested they phone the police. They did and the same officers return.  First the officer asked April, if there was a lawful reason to evict, in which she replied no.  She said I caused no issues and was always paid in advance.  At this point, I tried to explain the eviction ban, trying to point out to police that they can not lawfully enfore the eviction.  They didn’t listen and totally mixed up what I was trying to say. Management went ahead and forged my paperwork. Ms. April admitted that management had been spying on me. 

Over the next 3 days, management continued to lie to me and threaten me.  Everytime I tried to discuss the issue, they would say, they are not dealing with this and reduced the time I had to vacate.  At one point I was down to 15 minutes,  I contacted the police to help.  Again, management lied. They denied the conversation and said I had 48 hours to vacate. I held legal right to my room so I was not tresspassing.

I explained I had no issue leaving, but it was not possible to move my belongings.  I asked them to let me leave them in my room or even store them in a cubby or underneath the stairs.  They said no and Mr. Tyree stated, more then once, if I left my belongings he would trash them.  I mentioned this to the police a few times and even had a discussion with the police and staff, trying to express my concerns.  In the end the police dismissed this stating that the hotel had procedures that had to follow.  I’ll point out here that management made good on their promise.  In the end, practically everything, except what was in my car was destroyed. 

I went to the front office and called the Attorney General who ordered management to stop evicting me. Unable to walk, confined to a chair and mentally incapacitated.  I was rolled out onto the sidewalk, Some of my belonging tossed on the grass, no id, no money, nothing.  What was the worst was None of my medications or necessary medical supplies.  I had a port I could tube feed through when my digestive tract shuts down.  I knew I had to hook up that night, It had been almost three days.  I had planned to because I didn’t expect to be thrown out until it was too late.  If I had stayed in my room and had access to all my supplies, I wouldn’t have suffered physically as much as I did.  I phoned the front desk a few times asking to be let in to get what I needed or for them to bring it out, they refused and hung up on me.  I spent a very difficult night in my car.

During the removal I was promised to be let back in, the next morning to see what stuff I could get out.  I absolutely needed my medical supplies and medication.  That morning I called and requested a key card, they refused. They said they would let me in to my room once I argued that was not what I was told the night before. They didn’t care.  I contacted the police, the police called the hotel and were told they had not said that.  They had stated they would stay with me to make sure I can get in and out.  The police relayed this to me, but I knew it was a lie.  Anyway, still couldn’t walk, so I rolled in with the chair. Management opened my room and told me they were heading back to do their work.  I stated what the police told me, they said they were not going to stand around waiting for me. I was also stuck on the lip of the door frame.  I only have one leg to use and my hands were full.  I tossed my dogs bowl past the door, it actually landed past and slightly behind the door. Mr. Tyree who was standing behind me, blocking me, started going off threatening to charge me with assault for throwing something at the staff member who was slightly infront on the left.  This got him mad so he tried to force my chair back out saying I plan on blocking myself in.  I am disabled and cant even walk. He thought I was fighting, I had actually picked up both of my feet because I didn’t want them rolled over.  Tyree wrestled with my chair until an employee told him to stop because I was stuck. He eventually got me out.

I was given 48 hours to remove my belongings from the hotel.  I had a moving company there within 12 hours.  I got a call stating that everything had been packed up into large black garbage bags and smelled really awful and was leaking putrid liquid.  I asked the to bring it, I’ll deal with it. My clothes were put into a bag and an open bottle of bleach was added.  All clothes either disintegrated or was covered in bleach stains.  In my dry goods the tossed in a open carton of eggs, in another an open jar of cranberry sauce, in another I couldn’t identify the substance. The actions of WoodSpring staff amount to harassment.

I’d like to sue your company. At this time, I’m extending an olive branch: a settlement offer. I would like compensation in the sum of $16 million. I also want the following: 

  • Written commitment to address your company’s dispute resolution process to either assign full responsibility to the franchised hotel, including the complaint contacts, or a full acceptance and accountability for all disputes and resolutions. 
  • A full outside/third party (I’d like to have a say but not necessary) investigation of all policies, procedures, agreements, regulations, contracts, auditor assessment and any other vulnerable to corruption and full compliance to every recommendation. This will take place every two years until a minimum of 5 consecutive investigations return an acceptable evaluation. 
  • A review of company policies and ethics and a commitment to not only uphold these commitments in a tangible manner.
  • A soft commitment to work with me on hotel evaluations as an active method for prevention of future issues.

This offer to settle out of court is valid for 30 days after the date of this letter. If you do not accept my offer within 30 days, I will proceed with legal action against you.

Yours Sincerely,


Insert Your Full Name

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