☢ test - Í

High State, 282 Ga. 244, 647 S.E.2d 270 (June 25, 2007). No error in refusing to sever defendant’s charges of burglary and murder, committed on consecutive days, where “High killed the victim with a gun that he stole in a burglary committed the preceding day. This ‘shows a continuing course of criminal conduct.’ Varnadoe v. State, 227 Ga.App. 663, 664(1) (490 S.E.2d 517) (1997).” “Since the burglary and murder were connected crimes, the trial court did not abuse its discretion in denying High’s severance motion.” Woolfolk v. State, 282 Ga. 139, 644 S.E.2d 828 (May 14, 2007). The day after victim’s murder, defendant pointed same gun at officer who tried to arrest him for the murder. Held, trial court properly refused to sever charge of aggravated assault against a police officer from the murder charge. “‘This Court has upheld joinder of two crimes when one crime is a circumstance of the arrest on the other crime.’ (Footnote omitted.) Williams v. State, 277 Ga. 368, 369(3) (589 S.E.2d 563) (2003). Therefore, because Woolfolk’s alleged crime of aggravated assault against a police officer was a circumstance of his arrest for the crimes against Young and directly related to that crime, the trial court did not abuse its discretion by denying Woolfolk’s motion to sever these offenses under the facts of this case. Id.” Distinguishing Benford v. State, 272 Ga. 348, 528 S.E.2d 795 (2000) (evidence of other offenses incident to defendant’s arrest not admissible “where the evidence is wholly unrelated to the charged crime, the arrest is remote in time from the charged crime, and the evidence is not otherwise shown to be relevant.”) (emphasis in original). Hunstein dissents. Accord, Daughtry (March 27, 2015), above. Borders v. State, 285 Ga.App. 337, 646 S.E.2d 319 (May 10, 2007). Charged with aggravated child molestation, defendant tried to arrange for victim’s murder. Held, trial court did not err in refusing to sever the resulting solicitation of murder charge from the original child molestation charges. “Here, the joinder of offenses was based upon evidence showing a connected series of acts that started with Borders’ commission of the multiple sexual offenses against the victim, and culminated in Borders’ solicitation to have the victim murdered to prevent her from testifying against him at trial. Thus, severance of the offenses was not required. See Wilcox v. State, 271 Ga. 544, 545-546(2) (522 S.E.2d 457) (1999); Fluker v. State, 174 Ga.App. 890, 890-891(1) (332 S.E.2d 34) (1985). [fn] The evidence was not complex and there is no indication that the jury was unable to distinguish the evidence and apply the law intelligently as to each offense.” Daugherty v. State, 283 Ga.App. 664, 642 S.E.2d 345 (February 21, 2007). No error in denying severance: “Offenses are properly joined for trial where they represent ‘a series of criminal acts closely connected by geography, time and manner so as to constitute a scheme or plan of criminal conduct.’ (Citations omitted.) Thrasher v. State, 261 Ga.App. 650, 652(3) (583 S.E.2d 504) (2003). Here, the acts were the possession and sale of crack cocaine, occurring in the exact same location within an hour of one another. Under these circumstances, the trial court could properly conclude that the separate offenses represented but parts of a single criminal enterprise.” Harmon v. State, 281 Ga.App. 35, 635 S.E.2d 348 (August 10, 2006). No abuse of discretion in trial court’s refusal to sever public indecency charge from defendant’s four charges of sexual battery. “Here, the evidence was sufficient for the trial court to conclude that the various charges against Harmon ‘constitut[ed] a single scheme or plan to prey upon young female victims and satisfy [his] [prurient] desires.’ Howard v. State, 266 Ga.App. 281, 285(3) (596 S.E.2d 627) (2004). The sexual batteries and the public indecency all took place within a month’s period of time and within a five mile radius. See Thrasher v. State, 261 Ga.App. 650, 652(3) (583 S.E.2d 504) (2003) (‘The offenses “were properly joined because they constituted a series of criminal acts closely connected by geography, time, and manner so as to constitute a scheme or plan of criminal conduct.”’). The three victims were women between the ages of twenty and twenty nine. See Howard, supra. Harmon approached each victim in a public place and, after attempting to engage them in conversation of a sexual nature, behaved in a sexually aggressive manner. See Quenga v. State, 270 Ga.App. 141, 145-146(2) (605 S.E.2d 860) (2004) (although charges differed, fact that defendant engaged in ‘overtly sexual’ conduct with all victims was evidence of common scheme or plan). In one instance of sexual battery and in the public indecency incident, he offered the victims money and fondled himself.” Rollinson v. State, 276 Ga.App. 375, 623 S.E.2d 211 (November 15, 2005). Trial court properly declined to sever armed robbery offenses: “The two charged offenses were closely connected in time and place. Both occurred in Reidsville under cover of darkness within eight days of each other. Both involved filling station/convenience stores. In both, Rollinson was shown to have aided Berry in carrying out the armed robberies. The evidence therefore demonstrated a series of connected acts that were part of a common scheme.” Accord, Bowe v. State , 288 Ga.App. 376, 654 S.E.2d 196 (November 9, 2007) (series of similar armed robberies committed by co-defendants within days of each other).