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Isaac v. State, 237 Ga.App. 723, 516 S.E.2d 575 (April 22, 1999). Following convictions for DUI, interfering with government property, and related offenses, trial court erred “in requiring [defendant] to pay restitution without holding a hearing or making findings of fact as required by OCGA § 17-14-1 et seq. In Radford v. State, 223 Ga.App. 312, 313(2), 477 S.E.2d 428 (1996), we held that ‘Code sections 17-14-8 through 17-14-10 contemplate a hearing and specific written findings by the court in determining whether it will order restitution and, if so, the amount thereof.’ (Punctuation omitted; emphasis in original.)” Remanded to conduct hearing. Accord, Willard v. State , 244 Ga.App. 469, 535 S.E.2d 820 (June 13, 2000). 9. INDIRECT VICTIMS/INSURORS/THIRD PARTIES Wilson v. State, 317 Ga.App. 171, 730 S.E.2d 500 (July 12, 2012). Conviction for making false statement affirmed; award of restitution was proper. Defendant here is building contractor who made false statements on application for building permit, minimizing amount of work to be done on house remodel project; as a result of the false statements, no county oversight occurred, which would have prevented the damage to the house caused by defendant’s work. Restitution proper. Defendant contends that restitution to the homeowners was improper here, as the false statements provision creates no private cause of action. “[T]his argument ignores the law of restitution in this State, which defines a victim as anyone who suffers damages caused by the defendant's unlawful act. … [T]he trial court could properly order that restitution be made directly to the Aarons even if they technically were not the direct victims of the crime.” Wright v. State, 302 Ga.App. 136, 690 S.E.2d 259 (January 26, 2010). Following defendant’s conviction for rape, burglary, and related offenses, trial court erred in dismissing (as premature) defendant’s motion to modify restitution order. Dicta: Patterson (February 20, 2008), below , does not require set-off of restitution for payments made by defendant’s insurance. ““Moreover, relevant case law suggests that in situations where the victim has been fully compensated by a third-party, the defendant may be ordered to pay restitution to that third-party. See Adams v. State, 291 Ga.App. 681, 684(3) (662 S.E.2d 782) (2008) (‘the purpose of restitution is not only to make the victim whole, but also to prevent the offender from shifting the costs of his conduct to third parties. Accordingly, a court may order an offender to make restitution to any third party who has incurred or will incur expenses as a result of his illegal acts’).” Adams v. State, 291 Ga.App. 681, 662 S.E.2d 782 (May 23, 2008). Not error to award victim restitution to charitable fund which paid for victim’s care. “The mere fact that some of the victim's damages have been or may be paid by a third- party, however, would not absolve Adams of civil liability for his conduct and, consequently, it does not absolve Adams of responsibility for making restitution,” citing “Crozier [ v. State , 233 Ga.App. 831, 832-833(2), 506 S.E.2d 139 (1998)] (trial court authorized to require restitution be paid to those third-parties that provided medical services to the individual victim); Bridges v. State, 208 Ga.App. 555, 556(2) (431 S.E.2d 164) (1993) (restitution may be paid to either the victim or their insurance carrier.).” Accord, Wright (January 26, 2010), above. Disapproved on other grounds, Turner v. State , 312 Ga.App. 799, 720 S.E.2d 264 (November 22, 2011) (whole court opinion). Tindol v. State, 284 Ga.App. 45, 643 S.E.2d 329 (March 7, 2007). Convicted of motor vehicle theft, defendant could be ordered to pay restitution for the lost contents of the truck, even though they were owned by someone other than the truck owner. “The sufficiency of evidence to support an order of restitution in a criminal case is measured by the civil standard of preponderance of the evidence. Lawrenz v. State, 194 Ga.App. 724, 391 S.E.2d 703, 725(1) (1990). … Contrary to Tindol’s argument that the tools and equipment were not part of the crime for which he was charged, theft of a motor vehicle, the act for which Tindol was sentenced, caused the disappearance of the equipment. That he was not charged separately with the theft of the items in the truck is irrelevant to whether the victim was entitled to restitution for their loss .” 10. JUVENILE In re. R.H., 316 Ga.App. 317, 728 S.E.2d 911 (June 20, 2012). Physical precedent only. In delinquency case, restitution order reversed and remanded for lack of evidence to support amount. Trial court couldn’t estimate current value based on owner’s testimony as to purchase price four months earlier. Stolen property here consisted of a Nook e-reader, case, memory card, earphones, and e-books . “OCGA § 17–14–9 does not permit a trial judge to set the amount of restitution by approximation but requires that the amount be based on proper opinion evidence of fair market value. Lovell v. State, 189 Ga.App. 311, 313(3) (375 S.E.2d 658) (1988).” Implores legislature to enact a legislative fix. In re: W.J.F., 302 Ga.App. 361, 691 S.E.2d 271 (February 15, 2010). Following delinquency adjudication for interference with government property, no abuse of discretion where trial court found that juvenile was able to pay restitution: “there was testimony that W.J.F. worked occasionally and earned approximately $20 a yard cutting grass during the summer.