☢ test - Í

specific acts of violence by a victim against third persons, ’ 261 Ga. at 407, 405 S.E.2d 669 (emphasis added), not evidence of a victim's threats to a defendant or evidence that the victim might have had a weapon but had not used it against a third person.” Hence, trial court properly ruled that counsel didn’t provide ineffective assistance by failing to provide such notice. Render v. State, 288 Ga. 420, 704 S.E.2d 767 (January 10, 2011). Defendant’s felony murder and related convictions affirmed; no ineffective assistance for failure to tender alleged evidence of victim’s prior acts of violence toward third parties. “The defendant has the burden of demonstrating the admissibility of Chandler [ v. State, 261 Ga. 402 (405 S.E.2d 669) (1991)] evidence [regarding prior violent acts of victim], and at a minimum must follow the procedural requirements for introducing the evidence, establish by competent evidence the existence of prior violent acts, and make a prima facie showing of justification. Spencer v. State, 287 Ga. 434, 436(2)(a) (696 S.E.2d 617) (2010).” Spencer v. State, 287 Ga. 434, 696 S.E.2d 617 (June 28, 2010). Defendant’s convictions for murder and related offenses affirmed; trial court was not required to conduct hearing on defendant’s notice to admit evidence of victim’s prior violent acts pre-trial. Based on Chandler v. State, 261 Ga. 402 (405 S.E.2d 669) (1991), and USCR 31.1 and 31.6, which “require detailed pre-trial notice of the defendant's intention to present Chandler evidence (and of the State's intention to offer any rebuttal evidence), in order to prevent trial by ambush. Chandler did not require, however, that the trial court hold a hearing on the issue before trial begins. Rule 31.6(B) requires the trial court to conduct a hearing on Chandler evidence outside the jury's presence, during which the judge ‘may receive evidence on any issue of fact necessary to determine the request.’ But the rule expressly leaves the timing of that hearing to the discretion of the court, stating that ‘[t]he judge shall hold a hearing at such time as may be appropriate ’ (emphasis added). Pre-trial Chandler hearings may be common, see, e.g., Peterson v. State, 274 Ga. 165, 167 (549 S.E.2d 387) (2001); Laster, 268 Ga. at 172, but they are not universal, see Stobbart v. State, 272 Ga. 608, 610 (533 S.E.2d 379) (2000). A pre-trial ruling on proposed Chandler evidence may assist the parties and the court in framing the issues to be tried, if the supporting evidence is defined and its admissibility can be determined at that point. But Spencer has identified nothing in the rules or our cases that requires Chandler hearings to be held before trial in every case. Having reviewed the record in this case, we find no abuse of discretion in the trial court's decision as to when to hear and rule on the proposed Chandler evidence.” Arnold v. State, 286 Ga. 418, 687 S.E.2d 836 (February 1, 2010). At defendant’s murder trial, trial court properly refused to admit evidence of victim’s prior conviction for robbery. Although defendant here claimed justification as a defense, making evidence of victim’s prior violent acts against third persons admissible, defendant failed to show that the prior robbery “involved violence.” Record here includes only “defense counsel's unchallenged recitation of the allegation set forth in the indictment, namely, that the victim took money and various items ‘with intent to commit theft by force, by intimidation, and by placing [the robbery victim] in fear of receiving serious bodily injury.’ Although this language sets forth certain elements of the crime of robbery, see OCGA § 16-8-40(a)(1) and (2), it does not provide a factual basis for determining whether an act of violence was involved in the robbery at issue.” Bennett v. State, 298 Ga.App. 464, 680 S.E.2d 538 (June 18, 2009). Convictions for aggravated battery and related charges reversed; trial court erred in prohibiting defendant from presenting evidence of another violent act by victim against a third party, as defendant made “a prima facie showing that in the incident being tried, the victim was the aggressor, the victim assaulted him, and he was honestly trying to defend himself.” Defendant here testified that victim approached defendant with his hand in his pocket. “Bennett testified that he feared for his life because he knew of [victim] Mr. Johnston's reputation and had previously seen him with a pistol in his jeans.” Based on Johnson v. State , 266 Ga. 380, 381 (467 S.E.2d 542) (1996) (prima facie case made for victim as aggressor where defendant testified that “victim approached him with his fists clenched and raised.”). Doesn’t make a difference that the similar act was subsequent to the incident on trial. Lewis v. State, 292 Ga.App. 257, 663 S.E.2d 721 (May 27, 2008). 1. In defendant’s trial for homicide, trial court erred in refusing to allow defendant to present evidence of victim’s prior acts of violence against third parties; defendant made a prima facie showing of justification with his own testimony that victim attacked him. 2. “The procedural requirements for introducing prior violent acts evidence are set forth in USCR 31.1 and 31.6, which are intended to ensure that the state receives timely and reasonable notice of the defendant’s intent to introduce prior violent acts evidence ‘as well as the nature of [that] evidence.’ Watkins v. State, 264 Ga. 657, 662(4) (449 S.E.2d 834) (1994). Substantial, rather than absolute, compliance with the notice requirements is sufficient to pass muster. Johnson v. State, 229 Ga.App. 586, 590(6)(a) (494 S.E.2d 382) (1997).”