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Appellant maintains that the trial court erred in
1) allowing amendments to some of the indictments against him; 2) declining to recuse itself
after hearing a proffer of the Commonwealth’s evidence during a pretrial motion hearing; and
3) finding that the evidence was sufficient to support his convictions
https://cases.justia.com/virginia/court-of-appeals-unpublish...

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Note added at 15 mins (2017-11-29 15:39:12 GMT)
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Bryant alleges that the trial court erred in denying his motion to dismiss for want of jurisdiction because the proffer of facts failed to establish that jurisdiction was proper due to the absence in the Commonwealth’s proffer of evidence of where the incidents took place and the ages of the victim and defendant at the time of the alleged crimes.
https://cases.justia.com/virginia/court-of-appeals-unpublish...

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Note added at 49 mins (2017-11-29 16:13:35 GMT)
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In a trial, to proffer (sometimes profer) is to offer evidence in support of an argument, or elements of an affirmative defense or offense. A party with the burden of proof must proffer sufficient evidence to carry that burden. For example, in support of a particular argument, a party may proffer documentary evidence or witnesses.
Where a party is denied the right to introduce evidence because that evidence would be inflammatory, hearsay, or would lack sufficient authentication, that party must make a proffer of what the evidence would have shown in order to preserve the issue for appeal.
https://en.wikipedia.org/wiki/Proffer