In re Keith’s Tree Farm, No. 13-71316, 2013 Bankr. LEXIS 5182 (Bankr. W.D. Va. Dec. 11, 2013)

(bankruptcy court determined that lessors’ letter stating that “as a result of your material breach,” we have “voted to terminate” your lease was not a proper termination of a lease for a Christmas tree farm; under VA law, lessors were required to make an actual demand for payment of past due amounts before the lease could be terminated; forfeitures were never favored in law, and to enforce a forfeiture without a prior demand would be “grossly inequitable”).