Virginia Code § 8.01-160

Defendant to give notice of claim for improvements
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If the defendant intends to claim allowance for improvements made upon the premises by himself or those under whom he claims, he shall file with his pleading a statement of his claim therefor, in case judgment be rendered for the plaintiff.
Code 1950, § 8-829; 1954, c. 333; 1977, c. 617.

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