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47. SUBSEQUENT TRANSACTIONS Martin-Argaw v. State, 311 Ga.App. 609, 716 S.E.2d 737 (September 8, 2011). Aggravated assault and related convictions affirmed; trial court properly admitted evidence that defendant tried to hire someone to murder witnesses prior to trial, finding this evidence “admissible to show ‘motive, intent, identity, course of conduct, and bent of mind where the incidents involve attempts to harm or kill the same individuals.’” McGhee v. State, 303 Ga.App. 297, 692 S.E.2d 864 (March 31, 2010). Defendant’s conviction for possession of drug related object, a glass pipe, affirmed; trial court properly admitted evidence of subsequent transaction involving possession of methamphetamine and possession of a glass pipe used to smoke methamphetamine. 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. Kennedy v. State, 298 Ga.App. 372, 680 S.E.2d 478 (June 16, 2009). Trial court properly admitted similar transaction evidence: in the case on trial and in the similar transaction case, the two co-defendants were charged with breaking the glass front door of Chevron stations, four miles apart on I-85 in Coweta County, using a large chunk of concrete, and stealing packs of cigarettes using black plastic bags. The similar transaction occurred two weeks after the case on trial. Hayward El v. State, 284 Ga.App. 125, 643 S.E.2d 242 (February 16, 2007). “Hayward El argues that the similar transaction evidence should not have been admitted because the act that led to this evidence being introduced occurred after the act at issue in this matter. This argument is without merit. There is no requirement that to be admissible the similar act must have occurred prior to the act on which the defendant is being tried. See Lee v. State, 281 Ga.App. 479, 484(3) (636 S.E.2d 547) (2006) (similar transaction evidence of robbery committed after robberies for which defendant was charged admitted); Houston v. State, 270 Ga.App. 456, 458(1) (606 S.E.2d 883) (2004) (similar transaction evidence of robbery committed one day after robbery for which defendant was charged admitted). Evidence supports the trial court’s findings that the act for which Hayward El was arrested in Florida was sufficiently similar to the act for which he was charged here and was appropriate for showing scheme and course of conduct. Accordingly, the trial court did not abuse its discretion in admitting the similar transaction into evidence.” SSSSS. SPEED DETECTION DEVICES See OFFENSES – UNIFORM RULES OF THE ROAD – SPEEDING, below TTTTT. STATEMENT IN PLACE BY ATTORNEY Anthony v. State, S16A0059, ___ Ga. ___, ___ S.E.2d ___, 2016 WL 1290786 (April 4, 2016). Felony murder and related convictions affirmed; trial court properly denied motion for pretrial immunity where defendant relied mostly on counsel’s statement-in-place as to witnesses’ likely testimony. “‘Attorneys are officers of the court and a statement to the court in their place is prima facie true and needs no further verification unless the same is required by the court or the opposite party. ’ Sherman v. City of Atlanta, 293 Ga. 169, 173–174(4), 744 S.E.2d 689 (2013) (citations and punctuation omitted; emphasis in original). The statements-in-place by the appellant’s lawyer were not a proper substitute for evidence at the hearing on the motion for immunity because the State did not accept those proffers but rather insisted that the appellant prove his immunity with traditional evidence. Id. at 173(4), 744 S.E.2d 689. Cf. State v. Cooper, 324 Ga.App. 32, 749 S.E.2d 35 (2013) (affirming the grant of a motion for immunity from prosecution and denying the State’s motion to reopen the evidence, where the State never presented any evidence, made any proffer as to the omitted evidence, or cross-examined any of the defendant’s witnesses at the hearing).”