Id. (quoting Grattan v. Commonwealth, 278 Va. 602, 620, 685 S.E.2d 634 (2009)). After defense counsel referred to Thomas as "developmentally delayed" during opening statements, the Commonwealth moved to exclude such evidence for lack of notice under Code ยง 19.2-271.6.
Id. (quoting Grattan v. Commonwealth, 278 Va. 602, 620 (2009)).