Legal Question in Civil Litigation in Virginia

Hi there--I would prepare the amended complaint and a motion for leave to file it, and bring them both with you, together with a propsed order granting the motion and accepting the amended complaint for filing. I would file these pleadings with the court clerk's office before I went into the courtroom. Whether or not I was able to do that, I would try to tell the courtroom clerk this before the judge even takes the bench, and if that failed, let the judge know after the parties introduce themselves but before anyone gets up to address the demurrer. This is to keep the other side's characterizations of the case from assailing the judge's ears. If all that fails, just say what you have to say when you're called on. Good luck.