strictly construed. This section is procedural and compliance with its provisions is not jurisdictional. In 2007, the notice provisions relating to counties, cities, and towns were moved and reworked by the General Assembly from Va. Code § 8.01-222 to Va. Code § 15.2-209; additionally, subsection G was added at this time. 2007 Va. Acts, eh. 368; see Annual Survey of Virginia Law: Civil Practice and Procedure, 42 U. Rich. L. Rev. 229, 263 (2007). Case law prior to the 2007 amendment “espoused a doctrine of substantial compliance and some creative relay-delivery circumstances had been treated as meeting the [notice] requirements.” Kent Sinclair & Leigh B. Middleditch, Jr., Virginia Civil Procedure § 2.30[B], at 183 (6th ed. 2014); see, e.g, Miles v. Richmond, 236 Va. 341, 344-45 (1988) (<HOLDING>); Town of Crewe v. Marler, 228 Va. 109, 112
holding that substantial compliance with notice is sufficient holding that strict compliance is not required holding that a four percent error rate constitutes substantial compliance with a statute holding that defective notice can be excused if there is substantial compliance with the maine tort claims holding that substantial compliance is sufficient to satisfy the notice requirements of sdcl 3212 and 3