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County, not just the death. “[T]he jury heard testimony that the victim was found lying down and injured in Fulton County; the jury heard testimony that, based on blood stains discovered in a nearby parking lot, the victim staggered 75–100 yards from where he was stabbed to the place he was found when the ambulance arrived; and the jury saw a police-drawn sketch of the area as well as diagrams, [fn] including street names and locations of where the blood stains were found and where the victim was found by emergency services.[fn] Although the City of Atlanta does extend into DeKalb County, there was no evidence presented that any incident related to the crime took place outside of Fulton County.[fn] The evidence here was sufficient for the jury to conclude beyond a reasonable doubt that venue for the stabbing was in Fulton County.” Nahmias concurs specially: “we could resolve the venue issue … simply on the ground that the jury heard testimony that the alleged crimes were committed within 100 yards of a location that other evidence showed was within Fulton County. In the absence of evidence to the contrary (and there was none in this case), jurors can very reasonably infer that a location within 100 yards of a location in a particular county is in the same county, since that fact is true of the overwhelming majority of locations in this State.” Nahmias would overrule Jones v. State, 272 Ga. 900, 537 S.E.2d 80 (2000), holding such an inference inappropriate. Davis v. State, 322 Ga.App. 826, 747 S.E.2d 19 (July 12, 2013). Conviction for theft by deception reversed; evidence didn’t prove venue “[b]ecause there was no evidence that Davis had exercised control over the funds in Morgan County.” Evidence showed that victim received a phone call from an unknown person at her home in Morgan County. Victim was told she had won a contest, and directed her to wire funds to defendant and others to cover fees and taxes on her (non- existent) prize. Defendant received the wired funds in Cobb County. Contrary to State’s argument, venue doesn’t exist in the county where the victim relinquished control of the funds; “in a theft by deception case, ‘the crime shall be considered as having been committed in any county in which the accused exercised control over the property which was the subject of the theft.’ OCGA § 16-8-11 (emphasis supplied).” Erick v. State, 322 Ga.App.71, 744 S.E.2d 69 (May 30, 2013). In theft by taking prosecution, venue was properly proven. “In a theft by taking case, ‘the crime shall be considered as having been committed in any county in which the accused exercised control over the property which was the subject of the theft.’ OCGA § 16–8–11. Consequently, ‘the State bears the burden of proving that the defendant exercised control over the property taken in the county where the case was prosecuted.’ Williams [ v. State, 297 Ga.App. 150, 151(2), 676 S.E.2d 805 (2009)]. Notably, ‘[i]n a prosecution for theft by taking checks in one county and depositing them into a bank account in another county, venue is proper in either county.’ Gautreaux v. State, 314 Ga.App. 103, 106(1), 722 S.E.2d 915 (2012). See Bearden v. State, 316 Ga.App. 721, 724(2), 728 S.E.2d 874 (2012) (noting that ‘in the prosecution of theft by taking, venue is proper in the county where the checks were taken or deposited’).” Check here was deposited in an ATM in Gwinnett County; circumstantial evidence suggested that defendant deposited it. Carter v. State, 320 Ga.App. 454, 740 S.E.2d 195 (March 18, 2013). Child molestation and related convictions reversed for failure to prove venue. 1. Although victim testified that incidents occurred at her mother’s house, “A.W.'s father testified that A.W.'s mother moved frequently and that she had moved approximately three times within a year.” There was no testimony to indicate at which of the residences the incidents occurred, and only one of the residences was described as being in Clayton County. 2. Other incidents were alleged to have occurred at defendant’s residence in Jonesboro, but “the State presented no evidence establishing that the entire city of Jonesboro lies within Clayton County. It is well established that ‘proving that a crime took place within a city without also proving that the city is entirely within a county does not establish venue.’ (Footnote omitted.) Graham v. State, 275 Ga. 290, 293(2), 565 S.E.2d 467 (2002).” Lopez v. State, 319 Ga.App. 486, 735 S.E.2d 812 (December 21, 2012). In prosecution for aggravated child molestation and related offenses, evidence established venue. Young victim testified that the incidents occurred at home, but didn’t know what county she lived in. School counselor “testified that all students who attend the school the victim was attending at the time she made the disclosure were required to live in Gwinnett County. And the DFACS worker testified that she established that the victim lived with Lopez, her mother and her siblings, and that the home was located in Gwinett County. Further, Officer McCullough testified that Lopez was arrested at his home in unincorporated Gwinnett County.” Manhertz v. State, 317 Ga.App. 856, 734 S.E.2d 406 (October 9, 2012). Physical precedent only. Convictions for identity fraud and related offenses affirmed. Where co-defendant Joyner sold other people’s personal information to Manhertz through a mediary in Dekalb County, and Manhertz was found with the information in Henry County, Joyner could be prosecuted in Henry County though she never went there. “[U]nder the financial-identity-fraud statutes, a ‘crime will be considered to have been committed in any county where the person whose means of identification or

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