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Davis v. State, 251 Ga.App. 436, 554 S.E.2d 583 (August 31, 2001). Both the prosecutor and the trial court assured the defendant that, despite his guilty plea, he would be able to appeal his motions on the denial of his rights to a speedy trial. Court of Appeals held, citing Hooten v. State , 212 Ga.App. 770, 775, 442 S.E.2d 836 (1994), that it does not recognize conditional guilty pleas and that all the usual rules of appellate practice, including the waiver of errors by guilty pleas, are applied. The court further stated that if trial courts wish to permit defendants to appeal pre-trial rulings, the procedures in OCGA § 5-6-34(b) (regarding certificates of immediate review) are available. 2. FACTUAL BASIS New case! Mims v. State, S16A0542, ___ Ga. ___, ___ S.E.2d ___, 2016 WL 3147569 (June 6, 2016). Twenty-eight years after defendant pled guilty to murder and kidnapping, trial court properly denied his motion for out-of-time appeal. Factual basis was adequately laid upon the record by reference to the indictment. “The transcript of the plea colloquy shows that the plea judge recited the relevant allegations of the indictment,[fn] confirmed with Mims that he understood the charges to which he intended to plead guilty, and confirmed that Mims, in fact, intended to plead guilty. Reference to the factual allegations of an indictment may be sufficient to lay a factual basis for a plea, and in this case, we conclude that an adequate factual basis was established on the record.[fn] Cf. Green v. State , 265 Ga. 263, 265 (2) (454 S.E.2d 466) (1995) (‘[W]e find that the indictment provided ample information from which the trial court could discern that the facts alleged by the state actually satisfied the elements of the charges to which Green was pleading guilty.’). See also Lewis v. State , 293 Ga. 544, 548 (1) (748 S.E.2d 414) (2013); Henderson [ v. State , 293 Ga. 6, 7, n. 2 (1) (743 S.E.2d 19) (2013)].” Williams v. State, 334 Ga.App. 311, 779 S.E.2d 91 (November 2, 2015). State court properly denied motion to withdraw guilty pleas to simple battery and criminal trespass. Defendant challenges record “that he made his plea knowingly and voluntarily.” 1. “No verbatim transcript of factual basis required on plea in state court which didn’t “result[ ] in additional incarceration. See King v. State, 270 Ga. 367, 509 S.E.2d 32 (1998). The required contents of the record of a state court plea hearing are set out in Uniform State Court Rule 33.11: ‘[a] record of the proceedings at which a defendant enters a plea of guilty or nolo contendere shall be made and preserved. The record should include: (A) the inquiry into the voluntariness of the plea (as required in section 33.7); (B) the advice to the defendant (as required in section 33.8); [and] (C) the inquiry into the accuracy of the plea (as required in section 33.9)[.]’ The requirements of Uniform State Court Rule 33.11 may be satisfied by a combination of documentary or extrinsic sources, as long as they ‘provide reviewing courts with a record of the plea proceedings to determine if challenged pleas have been entered voluntarily and with proper understanding.’ King, 270 Ga. at 370(1), 509 S.E.2d 32 (citation omitted).” No indication here of the sentence imposed, but apparently not one that resulted in additional incarceration. Probation? 2. Lack of factual basis on record doesn’t automatically require withdrawal of plea. “ In order to successfully attack a guilty plea after sentencing, Williams must show that the trial court’s acceptance of his guilty plea caused him to suffer a manifest injustice. Ramsey v. State, 267 Ga.App. 452, 600 S.E.2d 399 (2004); State v. Evans 256 Ga. 332, 336(3), 454 S.E.2d 468 (1995). He has not done so. ‘[Williams] has argued only that the record contains an insufficient factual basis to support his plea, and, although he states that a manifest injustice occurred, he makes no contentions whatsoever supporting this statement.’ Ramsey, 267 Ga.App. at 453, 600 S.E.2d 399. The record does not support a finding that Williams suffered a manifest injustice.” Childs v. State, 311 Ga.App. 891, 717 S.E.2d 509 (October 7, 2011). Trial court properly denied motion for out-of-time appeal of guilty pleas to aggravated battery and related offenses; factual basis for pleas was adequately established. “The record shows … that the trial court questioned Childs about the facts underlying his pleas. The prosecutor filled in information that Childs omitted from his recitation. The trial court also indicated that the prosecutor previously had given a factual basis for the crimes, although it apparently was not recorded for transcription, and the court asked Childs if he disagreed with anything the prosecutor had said. Childs indicated that he did not disagree. ‘When the transcript presents evidence that the trial court was aware of the factual basis, USCR 33.9 does not otherwise require the trial court to affirmatively state that it is satisfied there is a factual basis. In such an instance, the acceptance of a plea would be deemed a factual finding that there is an adequate factual basis for the plea.’ (Citations and punctuation omitted.) Adams v. State 285 Ga. at 747(4)(a) [September 28, 2009, below].” Accord, Hower v. State , 331 Ga.App. 567, 769 S.E.2d 402 (March 6, 2015) (trial court could ascertain factual basis for plea from prior pretrial hearing). Staley v. State, 309 Ga.App. 520, 711 S.E.2d 70 (May 6, 2011). Trial court properly denied defendant’s motion to withdraw guilty plea to child molestation; record adequately showed factual basis for offense. “Each count of the indictment was read into the record verbatim, and Staley testified in response to the trial court's questioning that he