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compound’ anything the jury might have heard. Prince's decision not to get curative instructions was part of a legitimate trial strategy and is within the range of reasonable professional conduct. Fargason v. State, 266 Ga. 463, 464(2), 467 S.E.2d 551 (1996).” Nealy v. State, 239 Ga.App. 651, 522 S.E.2d 34 (August 18, 1999). 1. At defendant’s armed robbery trial, no prejudice to defendant where, “during a recess taken during [victim] Hagins' trial testimony, the trial court barred certain members of the public from returning to the courtroom after receiving evidence that they were intimidating Hagins as he testified. In moving for a mistrial, Nealy contended that, when the jury returned, they would notice that the people were no longer in the courtroom and would improperly infer that Nealy was involved in intimidation of the witness. None of the rulings or actions taken by the trial court on this issue was done in the presence of the jury. We find no basis to conclude that the jury would infer that Nealy was intimidating witnesses or that the trial court's actions did anything to prejudice Nealy's right to a fair trial.” 2. At defendant’s armed robbery trial, trial court properly allowed victim to testify that he had been threatened and bribed. “Earlier in the trial, [victim] Hagins gave testimony that the defendants were not the robbers that was inconsistent with other trial testimony and pretrial statements he made identifying the defendants as the robbers. In subsequent testimony, Hagins said that, earlier in the trial, he had falsely testified that the defendants were not the robbers because an unidentified person threatened him with bodily harm if he testified against the defendants and because [co-defendant] Mahmoud's father had bribed him with money. The trial court properly allowed Hagins to give this testimony to explain why he had testified falsely and to rebut its discrediting effect. Bivins, 200 Ga. at 740-741, 38 S.E.2d 273; Benefield, 140 Ga.App. at 731, 232 S.E.2d 89; compare Fields v. State, 260 Ga. 331, 333, 393 S.E.2d 252 (1990) (error to admit prosecution witness' testimony as to threat where it was not admissible to explain other testimony discrediting the witness, and the State's inability to link the threat to the defendant prevented the testimony from being relevant to any other material issue). Moreover, before Hagins gave his explanation, the trial court gave cautionary instructions to the jury that the testimony was solely for the purpose of explaining Hagins' changed testimony, and that it was not to be considered as evidence against any of the defendants or for any other purpose. Under these circumstances, the trial court properly denied the motion for a mistrial.” CCCC. SUBPOENAS See new OCGA Title 24, Chapter 13 Gregg v. State, 331 Ga.App. 833, 771 S.E.2d 486 (March 30, 2015). Physical precedent only. In prosecution for theft by taking, trial court abused its discretion by quashing defendant’s subpoena duces tecum. Defendant was charged with taking money from the cash register at the pharmacy where she worked; she contended that she was directed to take money from the till to pay contract workers, and sought to subpoena records from the pharmacy to prove that practice. “‘When a motion to quash [a subpoena] is filed, the party serving the subpoena has the initial burden of showing the documents sought are relevant.’ Bazemore v. State, 244 Ga.App. 460(1), 535 S.E.2d 830 (2000). Where the evidence sought in a subpoena duces tecum is demonstrably relevant and material to the defense, it is error for a trial court to quash the subpoena. See Henderson v. State, 255 Ga. 687, 689–690(2), 341 S.E.2d 439 (1986); Buford v. State, 158 Ga.App. 736, 767(1), 282 S.E.2d 134 (1981). See generally Dean v. State, 267 Ga. 306, 307, 477 S.E.2d 573 (1996) (‘The constitutional right to compulsory process includes the right to present all material evidence to establish a defense.’) (citation omitted). Gregg met her burden of showing the relevance of the evidence sought in the subpoena. She demonstrated that she sought the documents not just for use in cross-examining the pharmacy owner, but also to prove the volume of cash that the pharmacy used to pay its cash-based employees. The fact that the pharmacy needed a certain amount of cash to pay its cash-paid employees directly pertains to Gregg's sole defense—her claim that she took cash out of the register at her employer's direction to pay those employees and other expenses. Evidence of the volume of cash used to pay those employees is relevant to that defense. … The trial court therefore erred in denying Gregg's motion to compel a response to her subpoena seeking this relevant evidence.” Acknowledging that “[t]here is no generalized right of discovery in criminal cases. See State v. Lucious, 271 Ga. 361, 364(4), 518 S.E.2d 677 (1999),” majority also notes that reciprocal discovery doesn’t exclude discovery from third parties, citing Walker (July 12, 2013), below. Andrews, writing for Boggs and Branch, dissents, would find no abuse of discretion in quashing subpoenas. Dissent argues that the documents were sought only for cross-examination, and that there is no “power to require the pretrial disclosure of any and all information that might be useful in contradicting unfavorable testimony.” Argues that defendant instead “could subpoena employees of the pharmacy as part of her defense at trial.” Walker v. State, 323 Ga.App. 558, 747 S.E.2d 51 (July 12, 2013). Convictions for possession of cocaine with intent to distribute and obstruction reversed; divided Court of Appeals finds that trial court erred in quashing defense subpoenas for evidence held by police. Defendant subpoenaed police to produce evidence seized from him at a motion hearing