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Adorno v. State, 314 Ga.App. 509, 724 S.E.2d 816 (March 1, 2012). Child cruelty convictions affirmed; no abuse of discretion in reopening evidence after closing arguments where trial court determined that it had erroneously excluded evidence proffered by State. “[A]fter all parties completed their closing arguments, but before the jury was charged, the trial court held a bench conference outside the presence of the jury, in which it informed the parties that it had made a mistake in excluding [evidence admissible under the Child Hearsay Act]. Consequently, the trial court determined that it would reopen the evidence to allow the State to call the child advocacy counselor as a witness and to introduce the recordings of the counselor's forensic interviews with N.R. and S.R. into evidence. In addition, the trial court ruled that both defendants could also introduce additional evidence if they chose to do so. Both defendants then objected, but neither moved for a mistrial. And thereafter, the State called the child advocacy counselor to testify and played for the jury the recordings of the counselor's forensic interviews of S.R. and N.R. Ramirez now argues that the trial court erred in reopening the evidence. But the trial court was correct in determining that it had erred by initially excluding the child advocacy counselor's testimony and the recordings of her forensic interviews of N.R. and S. R.[fn] Accordingly, we conclude that it did not abuse its discretion in reopening the evidence to the testimony and recordings.” Riley v. State, 311 Ga.App. 445, 715 S.E.2d 835 (August 17, 2011). Armed robbery and related convictions affirmed; no abuse of discretion where trial court re-opened evidence to allow State to tender a photo of defendant’s tattoo, previously identified and shown to jury. “The record shows that the state had laid the foundation for the photo, authenticated it, and shown it to the jury. Although defense counsel was not shown the photograph tattoo prior to the trial, the trial court ruled that defendant had notice of tattoos upon his own body. Riley's ability to present a defense was not prejudiced by the court's action. Peeples v. State, 234 Ga.App. 454, 458(5) (507 S.E.2d 197) (1998) (court did not abuse its discretion, in prosecution for possession of cocaine, in reopening evidence after motion for directed verdict to allow state to introduce additional testimony from a forensic chemist as to the results of a test regarding the contents of a pipe introduced during trial). Compare Smith v. State, 156 Ga.App. 563, 564(1) (275 S.E.2d 140) (1980) (reopening evidence to allow testimony where witness had previously made an out-of-court statement to trial judge concerning his testimony, contents of which were not revealed to either defendants or attorneys, was reversible error).” Gonzalez v. State, 310 Ga.App. 348, 714 S.E.2d 13 (June 30, 2011). Convictions for rape, child molestation, and related offenses affirmed. No abuse of discretion in reopening evidence to allow in-court identification of defendant by witnesses after defense moved for directed verdict on that basis. Davenport v. State, 308 Ga.App. 140, 706 S.E.2d 757 (March 2, 2011). Defendants’ convictions for methamphetamine possession and related offenses affirmed; “the trial court committed no error by allowing the state to reopen the case to establish venue. See, e.g., Dandy v. State, 238 Ga.App. 435, 435(2), 518 S.E.2d 907 (1999) (‘It is within the trial court's discretionary power to permit the state to reopen its case after the close of evidence and to introduce further evidence.’); Thompson v. State, 175 Ga.App. 645, 646(1)(b), 334 S.E.2d 312 (1985) (‘It is within the trial court's discretionary power to reopen a case and permit the introduction of further evidence even though the testimony is not in rebuttal of evidence offered by defendant.’).” Accord, Muldrow v. State , 322 Ga.App. 190, 744 S.E.2d 413 (June 12, 2013) (no ineffective assistance where defense counsel stipulated to venue, given that trial court had discretion to re-open evidence, anyway). Smith v. State, 306 Ga.App. 693, 703 S.E.2d 329 (November 3, 2010). Felony shoplifting conviction affirmed; no violation of defendant’s right to testify where defendant raised the issue after closing arguments, when State’s witnesses had already been released . “[T]he question before us is ‘whether a defendant, who waived [his] right to testify during the presentation of the evidence, can reassert [his] right if [he] disagrees with [his] counsel's presentation of the closing arguments.’ U.S. v. Cummings, 2009 WL 2058845, 4 (E.D.Wash., 2009). Although the U.S. Supreme Court established in Rock v. Arkansas, [483 U.S. 44, 107 S.Ct. 2704, 97 L.Ed.2d 37 (1987)], that ‘the right to testify on one's own behalf in defense of a criminal charge is a fundamental constitutional right,’ 483 U.S. at 53, n. 10, the Court also stated that a defendant's ‘right to present relevant testimony is not without limitation and must sometimes “bow to accommodate other legitimate interests in the criminal trial process.”’ Id. at 55 (quoting Chambers v. Mississippi, 410 U.S. 284, 295, 93 S.Ct. 1038, 35 L.Ed.2d 297 (1973)). Nevertheless, ‘restrictions of a defendant's right to testify may not be arbitrary or disproportionate to the purposes they are designed to serve.’ Rock at 55-56. Smith's request to address the trial court was couched as a complaint about his attorney and not as a request to testify. To the extent Smith's complaint reflected his intent to invoke his right to testify, however, we find that he asserted this right too late, regardless of his dissatisfaction with his counsel's performance. To permit Smith to reopen the evidence after closing arguments and after the State had released all of its witnesses would have detrimentally affected the fairness and legitimacy of the trial. A requirement that ‘a defendant ... exercise his right to testify prior to the close of evidence is not “arbitrary or