Id. at 68, 124 S.Ct. at 1374, 158 L.Ed.2d at 203. The Supreme Court has held the term “testimonial” “applies at a minimum to prior testimony at a preliminary hearing, before a grand jury, or at a formal trial; and to police interrogations,” id., and that it does not apply to business records, a category of evidence routinely admitted as an exception to general hearsay rules, id. at 56, 124 S.Ct. at 1367, 158 L.Ed.2d at 195-96. As to hearsay evidence falling between these two poles, lower courts, including our own, have examined specific types of hearsay documents on a category-by-category basis to determine whether they are testimonial or non-testimonial for Confrontation Clause purposes. See, e.g., Anderson v. Commonwealth, 48 Va.App. 704, 714-16, 634 S.E.2d 372, 376-77 (2006) (<HOLDING>). Decisions regarding the admissibility of
holding that biological parents have a prima facie right to custody over third persons holding provision in code  19218701 authorizing trial court to receive duly attested certificate of analysis performed by certain laboratory facilities as prima facie evidence of chain of custody of material tested does not violate confrontation clause because chainofcustody inference is nontestimonial holding district court did not abuse discretion in ruling moving party failed to make prima facie case to modify custody holding the plaintiff satisfies the burden of a prima facie case by a preponderance of the evidence holding that a prima facie case is subject to independent review