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of counsel. The form then contains the statement, ‘I hereby waive my right to a first appearance hearing.’ The form does not purport to inform the arrestee of the various aspects of the right to a first appearance hearing or the consequences of relinquishing that right. Furthermore, the form does not specify that the waiver is knowing and voluntary. The officers who presented the waiver forms for signature did not testify at the bail hearing regarding the circumstances of the purported waiver. Thus, the record contains no evidence that the [defendants’] waiver of their due process right to a first appearance hearing was knowing and voluntary. Accordingly, the trial court erred in finding that the [defendants] waived their first appearance hearing by executing the waiver forms,” citing cases relating to waiver of right to jury trial, e.g., Smith v. State, 270 Ga.App. 759, 608 S.E.2d 35 (2004). 2. After arrest warrant was issued, defendants weren’t entitled to be released from custody despite provisions of OCGA § 17-4-62. “ OCGA § 17-4-62 provides that any person who is arrested without a warrant and who is not brought before an appropriate judicial officer within 48 hours of arrest ‘shall be released.’ Binding precedent clarifies that this means that the defendant shall be released until a warrant or indictment is obtained. Vaughn v. State, 248 Ga. 127, 130(1)(a) (281 S.E.2d 594) (1981); Peters v. State, 115 Ga.App. 743, 746(2) (156 S.E.2d 195) (1967). [fn] Thus, once a warrant is obtained, OCGA § 17-4-62 does not require that the defendant be released for being deprived of a timely first appearance hearing.” “Even if the warrants were obtained more than 48 hours after the arrest in violation of OCGA § 17-4-62, however, the statutory remedy for the violation was only available during the period of illegal detention, which ended when the State obtained valid arrest warrants from a neutral and detached magistrate. [fn]” Boyd v St. Lawrence, 281 Ga. 300, 637 S.E.2d 687 (November 20, 2006). Defendant’s claim for release from custody for failing to be brought before a judicial officer within 48 hours of his warrantless arrest was mooted by his subsequent indictment, citing Ross v. Lemacks , 264 Ga. 839, 452 S.E.2d 109 (1995). Dicta suggesting that defendant was entitled to commitment hearing within 48 hours of arrest disapproved in Tidwell v. Paxton , 282 Ga. 641, 651 S.E.2d 714 (October 9, 2007). Ellison v. State, 242 Ga.App. 636, 530 S.E.2d 524 (March 8, 2000). Cocaine possession conviction affirmed; no reversal based on failure to provide timely preliminary hearing. “Ellison focuses on the seven-week interval between his arrest on March 1, 1996, and his committal hearing on April 17. Citing OCGA § 17–4–62, he argues that because this preliminary hearing did not take place within 48 hours of his warrantless arrest, his conviction should be overturned. Ellison's argument fails for two reasons. First, on the day after his arrest, police obtained an arrest warrant for Ellison based on an affidavit regarding the undercover cocaine sale. Dean v. State , 250 Ga. 77, 81(2)(b), 295 S.E.2d 306 (1982), held that obtaining an arrest warrant from a neutral magistrate within 48 hours of a warrantless arrest, even without an adversarial hearing, satisfies the statute. See Lambert v. McFarland, 612 F.Supp. 1252, 1261 (N.D.Ga. 1984) (ex parte determination of probable cause satisfies statute). Second, even if police had violated the statute, this would not invalidate Ellison's conviction. See Vaughn v. State, 248 Ga. 127, 130(1)(a), 281 S.E.2d 594 (1981).” FF. FORFEITURES Note, civil forfeitures are currently beyond the scope of this work State v. Singh, 291 Ga. 525, 731 S.E.2d 649 (September 10, 2012). Trial court erred by dismissing State’s petition “seeking equitable relief afforded by OCGA § 16–14–6(a)(1)–(4), including injunctive relief to stop the alienation of Singh's property and the appointment of a receiver over Singh's business and property.” Contrary to trial court’s ruling, Cisco (June 15, 2009) , below , did not decide that “all civil in personam claims under the RICO statute were unconstitutional.” Unlike the in personam forfeiture sought in Cisco , the injunctive relief sought here was civil in nature, and thus not unconstitutional. “Approximately two months after the trial court issued its ruling in this case, this Court decided Patel v. State, 289 Ga. 479 (713 S.E.2d 381) (2011). In Patel, which has nearly identical facts to the case at bar, we concluded that ‘in a RICO action, a trial court may properly exercise its discretion to appoint a receiver and enjoin the parties who would otherwise control property that is the subject of an in rem forfeiture proceeding.’ Id. at 481–482. The fact that these remedies are sought in conjunction with an in rem forfeiture does not convert such a proceeding into the type of in personam forfeiture action under OCGA § 16–14–7(m) which we found to be unconstitutional in Cisco. Patel, 289 Ga. at 482. Since the equitable remedies allowed by OCGA § 16–14–6(a) are available to other aggrieved parties as well as to the State (see § 16–14–6(b)), an action for such remedies is uncharacteristic of a criminal matter. Id.[fn] Indeed, none of the subsections of OCGA § 16–14–6 require proof of criminal conduct on the part of the in personam defendants, but the statute allows the superior court to enjoin any violations of OCGA § 16–14–4, which generally prohibits racketeering activity, until the case is resolved. Accordingly, the trial court's dismissal of the claims against the in personam defendants is reversed.” Cisco v. State, 285 Ga. 656, 680 S.E.2d 831 (June 15, 2009). Declares the in personam forfeiture provision of OCGA § 16-14-7(m) unconstitutional as a criminal penalty without criminal due process protections mandated by the U.S.