Black’s Law Dictionary 831 (6th ed.1990)). At common law, threats of harm to a dwelling and certain accusations of criminality could satisfy the intimidation element. See generally 3 Wayne R. LaFave, supra § 20.3(d), at 187. The present case presents no occasion for examining the contours of these particular common law doctrines, and thus, we offer no opinion on the subject. 6 . See also Wilson v. Commonwealth, 40 Va.App. 250, 254, 578 S.E.2d 831, 833 (2003) (because a prior conviction can be "proven by any competent evidence,” the defendant’s guilty plea was sufficient); Harris v. Commonwealth, 26 Va.App. 794, 806, 497 S.E.2d 165, 170 (1998) (using out-of-court statements of the probation and parole officer); Brooks v. Commonwealth, 24 Va.App. 523, 533, 484 S.E.2d 127, 131 (1997) (<HOLDING>); Miller v. Commonwealth, 22 Va.App. 497, 501,
holding that trial judge did not err in refusing to transfer to another judge defendants motion for substitution of judge for cause where defendants motion was not made in good faith holding district court did not err in admitting reports that were merely cumulative of evidence already in the record holding that the trial court did not err by granting defendants motion for summary judgment holding that the trial judge did not err by admitting copies of the indictments as part of the defendants record of conviction  holding that trial court did not err