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authorize jurors to take notes during the course of a trial and to refer back to them during their subsequent deliberations. See Denson v. State, 149 Ga.App. 453, 455(3) (254 S.E.2d 455) (1979) (holding that ‘[i]t was not error to allow the jurors to take notes during the trial and to refer to these notes during their deliberations’); See also Potts v. State, 259 Ga. 96, 104(21) (376 S.E.2d 851) (1989) (same); Thomas v. State, 90 Ga. 437, 437 (16 SE 94) (1892) (same); White v. State, 137 Ga.App. 9, 10(1) (223 S.E.2d 24) (1975) (same). Juror notes, then, are not subject to a continuing-witness objection, which pertains to documents that ‘contain their makers' assertions of purported truths [and] are ascribed evidentiary value only to the extent that their makers are credible[,]’ such as ‘answers to written interrogatories, written dying declarations, and signed statements of guilt.’ Sims [ v. State, 275 Ga.App. 836, 840(3) (621 S.E.2d 869) (2005)]; see also Bryant v. State, 270 Ga. 266, 270-71(3) (507 S.E.2d 451) (1998) (“The continuing witness rule prohibits writings from going out with the jury when the evidentiary value of such writings depends upon the credibility of the maker.’ (punctuation omitted)). In sum, notes reflecting an attentive juror's recollection or interpretation of the evidence presented during a trial – which are not evidence and have no evidentiary value – do not fall within the contemplated scope of the continuing- witness objection.” Stinski v. State, 286 Ga. 839, 691 S.E.2d 854 (March 1, 2010). “The trial court did not err by denying Stinski's motion to make the jurors' handwritten notes part of the record. McMichen v. State, 265 Ga. 598, 613(35) (458 S.E.2d 833) (1995).” T. JURY COMMISSIONERS Worthy v. State, 307 Ga.App. 297, 704 S.E.2d 808 (November 4, 2010). 1. Indictment for false imprisonment, aggravated assault, and related offenses wasn’t invalid for inaccuracies in oath of jury commissioners or jury clerk. Both oaths varied from those statutorily prescribed, but “even ‘if [the jury commissioners] were not de jure officers, their acts as de facto officers were not invalid ... [T]he official acts of an officer are none the less valid for his omission to take and file the oath, unless in cases when so specifically declared.’ Rosenblatt v. State, 2 Ga.App. 649, 651 (58 S.E. 1107) (1907) (citations and punctuation omitted). Thus, the jury commissioner's official acts were valid despite omissions in the oath as originally taken and subscribed.” No difference in outcome if challenge made before or after trial. 2. Prior reprimand and fine from State Election Board “ for assisting voters with absentee ballots and failing to sign the ballot envelopes indicating that he had provided such assistance” didn’t disqualify jury commissioner from being a “discreet” person eligible to be jury commissioner pursuant to OCGA § 15-12-20(a). 3. “ Because a bailiff is not a county officer within the meaning of OCGA § 15-12-20, Barrett was not disqualified based on that statute. [fn] In any event, even if a jury commissioner were ineligible to hold the office of jury commissioner, if he was appointed and acted therein, he was a jury commissioner de facto, and the acts of the board were valid and cannot be collaterally attacked on the grounds of his incompetence to hold that office. [fn] A de facto jury commissioner's acts are not void as to the public and third parties, and they cannot be invalidated in a proceeding to which he is not a party. [fn]” U. JURY SELECTION, GENERALLY Stinski v. State, 286 Ga. 839, 691 S.E.2d 854 (March 1, 2010). At defendant’s capital murder trial, 1. “[t]he trial court did not err by denying Stinski's motion to compel the prosecutor to disclose all notes or records he might possess regarding the prospective jurors. See King v. State, 273 Ga. 258, 263(12)(c) (539 S.E.2d 783) (2000) (holding that such materials must be disclosed only if they are exculpatory within the meaning of Brady v. Maryland, 373 U.S. 83 (83 S.Ct. 1194, 10 L.Ed.2d 215) (1963)); Tyree v. State, 262 Ga. 395, 397(2) (418 S.E.2d 16) (1992) (noting that prosecutors have a duty to disclose specific, relevant facts known to them that have been misrepresented by prospective jurors).” 2. “The trial court did not err by denying Stinski's motion for a daily transcript of voir dire. See Thomason v. State, 268 Ga. 298, 312(12) (486 S.E.2d 861) (1997); Hightower v. State, 259 Ga. 770, 772(8) (386 S.E.2d 509) (1989) (“A defendant is not entitled to a daily transcript”).” V. JURY TRIAL, RIGHT TO See CONSTITUTIONAL ISSUES – JURY TRIAL, above ; SENTENCING – AGGRAVATED SENTENCE – GENERALLY/ APPRENDI , below W. JURY VIEW 1. OF DEFENDANT Jefferson v. State, 312 Ga.App. 842, 720 S.E.2d 184 (November 3, 2011). Armed robbery and related convictions affirmed. Trial court properly prohibited defense from asking police officer/state’s witness, on cross, “‘come down and examine [defendant’s] arm and tell us what he sees in the way of tattoos.’ After the state objected, the trial court, relying upon Wesley v. State, 228 Ga.App. 342, 491 S.E.2d 824 (1997) and State v. Battaglia, 221 Ga.App. 283, 470 S.E.2d 755 (1996), sustained the objection because ‘that deprives the State of the right to—cross-examine the defendant.’

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