☢ test - Í

v. State , 292 Ga.App. 673, 665 S.E.2d 374 (July 10, 2008) (after entry of stay away provision of probation order, defendant and victim would have consensual contact, then argue; “[T]he evidence failed to establish that Wright's actions that night placed Harrison in reasonable fear for her safety by establishing a pattern of harassing and intimidating behavior.”). Distinguished, Jackson (November 2, 2015), above (evidence sufficient where defendant went to victim’s house uninvited after being ordered not to do so, regardless of fact that victim then let him in). Shafer v. State, 285 Ga.App. 748, 647 S.E.2d 274 (May 9, 2007). Evidence that defendant made telephone calls to victim in violation of protective order was sufficient to support conviction for aggravated stalking. “See Chatham v. State, 280 Ga.App. 695, 696-697 (634 S.E.2d 856) (2006) (upholding aggravated stalking conviction based in part on harassing and intimidating phone calls); Murden v. State, 258 Ga.App. 585, 586(1) (574 S.E.2d 657) (2002) (contact via telephone can be sufficient prohibited contact to serve as the basis for an aggravated stalking conviction).” Patterson v. State, 284 Ga.App. 780, 645 S.E.2d 38 (March 21, 2007). Trial court could admit defendant’s prior plea of guilty to criminal trespass to show proof of notice not to contact victim without regard to whether defendant validly waived the right to counsel in entering the plea. “Patterson’s prior conviction was not used to enhance his sentence. The conviction was presented to show that he had been ordered not to have contact with the victim. A prior conviction is not required to prove aggravated stalking.” Fields v. State, 281 Ga.App. 733, 637 S.E.2d 136 (October 4, 2006). No fatal variance between indictment alleging violation of a protective order and proof of violation of a pretrial bond condition. “The evidence in this case unquestionably showed that Fields was aware that a court order was in place which prohibited him from following or contacting the victim. Whether the order Fields violated was a ‘protective order’ or a bond order containing a protective provision was immaterial.” State v. Carlisle, 280 Ga. 770, 631 S.E.2d 347 (June 12, 2006). A defendant “may not be found guilty as a party to the crime of aggravated stalking” “absent evidence that the person knew of a court order that had been imposed on the second person.” Agrees with Court of Appeals on this point but reverses decision at 273 Ga.App. 567, 615 S.E.2d 543 (2005) by finding evidence that defendant was in fact aware that her co-defendant was under such an order. “Carlisle did not have to know of the specific type of court order that was in effect on December 20, 1996, when she assisted Gibbs in stalking the victim. Rather, she simply had to be aware that a court order was in effect that prohibited Gibbs from contacting the victim.” Benham dissents on this last point, noting difference between type of order alleged in indictment and that proven at trial. Accord, Patterson v. State , 284 Ga.App. 780, 645 S.E.2d 38 (March 21, 2007) (State did not have to prove that defendant was aware of his prior probation condition, just that he knew he wasn’t supposed to contact victim). Phillips v. State, 278 Ga.App. 198, 628 S.E.2d 631 (March 13, 2006). In definition of aggravated stalking, “‘[t]he phrase “harassing and intimidating” is defined as “a knowing and willful course of conduct directed at a specific person which causes emotional distress by placing such person in fear for such person’s safety or the safety of a member of his or her immediate family, by establishing a pattern of harassing and intimidating behavior, which serves no legitimate purpose.” OCGA § 16-5-90(a)(1).’ [fn] ‘Overt threats of bodily harm are not required.’ Jones v. State, 239 Ga.App. 733, 734(2) (521 S.E.2d 883) (1999).” Accord, Brooks (January 30, 2012), above. Revere v. State, 277 Ga.App. 393, 626 S.E.2d 585 (January 26, 2006). 1. “The victim’s previous consent to contact after the order was issued does not alter the fact that, on this occasion, she did not consent and repeatedly requested that he leave. Revere failed to comply promptly with her request, and he violated the court’s order by coming to her home. The evidence supports his conviction, and the victim’s previous consent to contact does not alter this outcome. Littleton v. State, 225 Ga.App. 900, 902-903(4) (485 S.E.2d 230) (1997) (sufficient evidence supported aggravated stalking conviction even though victim had previously allowed the defendant into her home after entry of protective order). The victim’s previous consent to contact after the order was issued does not alter the fact that, on this occasion, she did not consent and repeatedly requested that he leave. Revere failed to comply promptly with her request, and he violated the court’s order by coming to her home. The evidence supports his conviction, and the victim's previous consent to contact does not alter this outcome. Littleton v. State, 225 Ga.App. 900, 902-903(4) (485 S.E.2d 230) (1997) (sufficient evidence supported aggravated stalking conviction even though victim had previously allowed the defendant into her home after entry of protective order).” Accord, Crane v. State , 297 Ga.App. 880, 678 S.E.2d 542 (May 14, 2009); Gates (June 21, 2013), above. 2. Proof of receipt of a written order by the defendant is not required to establish aggravated stalking; in fact, neither notice nor a writing is required. “ ‘The statute does not require a written order