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The juvenile court also considered psychological reports which showed average intelligence and no mental impairments that would prevent W.J.F. from working. In fact, the psychologist opined that W.J.F. would benefit from ‘part-time employment.’ Further, the court made accommodations for W.J.F.'s age by deferring the payment of restitution until he turned sixteen.” Order to pay $100 per month restitution thus was supported by evidence. In re: C.S., 280 Ga.App. 781, 635 S.E.2d 176 (July 11, 2006). Following delinquency adjudication for theft by receiving, juvenile court’s restitution order vacated and remanded for failure to make written findings regarding the appropriateness of restitution and the juvenile’s ability to pay. “‘Before ordering restitution, a trial court must hold a hearing to determine whether restitution is appropriate and, if so, the amount that should be paid. OCGA § 17-14-10 requires that the trial court consider several factors in making this determination, including the offender’s present financial status, the offender’s probable future earning capacity, the goals of the restitution order, and the amount of damages suffered by the victim. Following the restitution hearing, the court must make written findings of fact relating to each of the factors set forth in OCGA § 17-14-10. Failure to make such written findings renders the restitution order deficient. Lummus v. State, 274 Ga.App. 636, 638-639(3) (618 S.E.2d 692) (2005) (citation and punctuation omitted); OCGA § 17-14-10 (2004); see Garrett v. State, 175 Ga.App. 400, 403(1) (333 S.E.2d 432) (1985) (holding that restitution orders must contain written findings of fact related to the factors in OCGA § 17-14-10); see also Revis v. State, 223 Ga.App. 470(1) (477 S.E.2d 880) (1996). After the June 2005 extension order was entered in this case, OCGA § 17-14-10 was amended to modify and add factors. Ga. L.2005, p. 88; see Register v. State, 279 Ga.App. 61, 630 S.E.2d 593 (April 21, 2006).” Accord, Newton v. State , 281 Ga.App. 549, 636 S.E.2d 728 (September 13, 2006). In re: C.S. and Newton both disapproved “to the extent they require written findings when ordering an offender to make restitution,” McCart v. State , 289 Ga.App. 830, 658 S.E.2d 465 (February 29, 2008) . 11. MEDICAL Watts v. State, 321 Ga.App. 289, 739 S.E.2d 129 (March 21, 2013). Following convictions for simple assault and battery, restitution order vacated. “No evidence was introduced during the sentencing hearing to support the amount of [victim’s] medical bills [fn] or to show the amount of any payments made to Watts by the Crime Victims Compensation Board.” Elsasser v. State, 313 Ga.App. 661, 722 S.E.2d 327 (December 8, 2011). No error in ordering restitution for medical bills as part of sentence for simple battery. “Even if, as Elsasser suggests, others at the scene may have also kicked the victim, that does not negate Elsasser's liability for damages caused by his role in the attack since ‘[t]here can be more than one proximate cause of an injury[.]’ (Citation omitted.) Dorsey [ v. State, 206 Ga.App. 709, 715(8) (426 S.E.2d 224) (1992)]. Indeed, ‘[i]t is clear that the victim would be able to recover the amount of all medical treatment related to [Elsasser's simple battery].’ Crozier v. State, 233 Ga.App. 831, 832(2) (506 S.E.2d 139) (1998).” Regent v. State, 306 Ga.App. 616, 703 S.E.2d 81 (October 27, 2010). Convictions based on guilty pleas to aggravated assault and aggravated battery affirmed; surgeon’s testimony as to cost of future surgery was sufficient to support trial court’s restitution order. Overruled on other grounds, Nazario v. State , 293 Ga. 480, 746 S.E.2d 109 (July 11, 2013). 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 v. State , 302 Ga.App. 136, 690 S.E.2d 259 (January 26, 2010). 12. MISCELLANEOUS Jackson v. State, 334 Ga.App. 340, 779 S.E.2d 402 (November 6, 2015). Physical precedent only; following guilty plea to financial identity fraud and residential mortgage fraud, evidence supported some, but not all, of trial court’s award of victim restitution. Defendant used Brown’s financial information without Brown’s knowledge or consent to purchase a home. At restitution hearing, Brown testified to the attorney fees he paid and to the time he spent speaking with attorneys, bank representatives and law enforcement investigators and attending court proceedings for the criminal prosecution. He also testified to his hourly rate as a self-employed equipment mechanic, but “admitted that he had never actually lost any money he would have otherwise earned, because he made up his missed time by working weekends.” “Under Georgia law, where a victim has lost time from work as a result of the tortious conduct of another, the victim may recover lost wages even if a third party has already compensated the victim for that loss. See Amalgamated Transit Union Local 1324