of the Code of Virginia, under which Silver was charged in the indictments. C. Testimony Regarding the Fact That the Alleged Victim Complained to Her Guidance Counselor about Silver’s Allegedly Taking Indecent Liberties with Her Is Admissible Having found that the recent complaint hearsay exception applies to the statute under which Silver was indicted, the Court now must decide whether, under the facts of this case, the alleged victim’s report of sexual abuse to her high school guidance counselor is admissible as a recent complaint of sexual assault that qualifies as an exception to the hearsay rule. In Williams v. Commonwealth, the Virginia Court of Appeals, when analyzing the recent complaint exception to the hearsay rule, upheld the admissibility of -17, 467 S.E.2d 824, 827 (1996) (<HOLDING>). Silver characterizes the delay in reporting
holding that a letter written by a thirteenyearold victim two years after her alleged rape was admissible reasoning that the issue of the twoyear delay was one of credibility not admissibility holding that a delay in reporting an alleged rape goes to the victims credibility which is solely a jury question holding that the trial court did not commit constitutional error by excluding evidence about the pri or rape of the tenyearold victim when she was five years old because the defendant did not proffer evidence that the prior rape was similar to the current incident holding that twoyear delay was not reasonable holding that against her will in the rape statute means without her consent and that the fact that the victim was under the age of consent was sufficient to establish that element