☢ test - Í

evidence shows that Gould resided in Floyd County during the course of doing business with Gonzalez and that documents authored by Gould show a Floyd County address and phone number. Gould argues that venue was not established in Floyd County because there was no evidence that he ever received money belonging to Gonzalez in Floyd County or spent any money belonging to Gonzalez in Floyd County. While we agree with Gould’s assertions that the evidence did not show that he ever received or spent any of Gonzalez’ money in Floyd County, we disagree with Gould’s conclusion that venue in Floyd County was improper. Here, … the evidence shows that Gould clearly exercised control over money belonging to Gonzalez while he resided in Floyd County. Gould’s Las Vegas agent testified that Gould directed him to make certain transfers out of the St. Vincent account funded by Gonzalez. During the time that Gould gave him directions for the transfers, the Las Vegas agent believed that Gould resided in Floyd County. In fact, Gould directed the transfer of these funds using letterhead showing a Floyd County address and phone number. [A]n individual can exercise control over funds by directing a wire transfer, [cit.] and, pursuant to OCGA § 16-8-11, venue will lie in the county where the individual exercises control over the funds. The trial court did not err in denying Gould’s motion to dismiss and motion for new trial on this ground.” Compare to Naylor (October 11, 2002), below. Franklin v. State, 279 Ga. 150, 611 S.E.2d 21 (March 28, 2005). “The State satisfied its burden to establish venue beyond a reasonable doubt [cit.] by entering into evidence without objection a survey of [defendant’s] property that identifies it as being located in Cherokee County. We also note that [defendant] herself entered into evidence a license issued by Cherokee County for an auto parts business that she operates on her property.” King v. State, 271 Ga.App. 384, 609 S.E.2d 725 (January 25, 2005). Proof that alley where defendant was caught, which was 200 yards from the store where he snatched victim’s purse, was in Ben Hill County was insufficient to prove venue, without proof or judicial notice that the entire City of Fitzgerald was in Ben Hill County. Rejects theory that “proof of the involvement of the officers of the Ben Hill County Sheriff’s Department in this case was sufficient to establish venue in Ben Hill County.” Relies on Jones v. State , 272 Ga. 900, 537 S.E.2d 80 (2000); casts doubt on Chapman v. State , 275 Ga. 314, 565 S.E.2d 442 (2002), both discussed below. Cited with approval, In re: B.R. (December 14, 2007), above. But see Bell (January 12, 2009), above (proof that victim’s home in Fitzgerald was in Ben Hill County was circumstantial evidence supporting finding that bank where forged check was uttered, in Fitzgerald, was also in Ben Hill County). Tompkins v. State, 278 Ga. 857, 607 S.E.2d 891 (January 10, 2005). Defendant agreed to bench trial on stipulated facts. Venue was not challenged, but State forgot to cover it in its statement of facts. Court of Appeals, at 265 Ga.App. 760, 595 S.E.2d 599 (February 23, 2004), held that that defendant couldn’t contest proof of venue in stipulated bench trial where he failed to make an issue of it below, although defendant “did not waive all challenges to the sufficiency of the evidence.” Supreme Court holds that “the fact that a defendant does not affirmatively challenge an element at trial does not relieve the State of this burden, nor does it justify the conclusion that the defendant stipulates to the existence of that element. [Cit.] Accordingly, the Court of Appeals contrary conclusion was in error.” Mullady v. State, 270 Ga.App. 444, 606 S.E.2d 645 (November 15, 2004). “‘The evidence of [Mullady’s] intoxication, although gathered on Fulton County soil, was sufficient to support the inference that [Mullady] had been intoxicated moments earlier while he was observed driving in DeKalb County. The State carried its burden of proving DeKalb County venue beyond a reasonable doubt.’ (Citations omitted.) Page v. State, 250 Ga.App. 795, 796 (553 S.E.2d 176) (2001). ” Watson v. State, 278 Ga. 763, 604 S.E.2d 804 (November 8, 2004). Malice murder conviction affirmed; venue was properly shown. “OCGA § 17-2-2(c) provides, in part: ‘If a dead body is discovered in this state and it cannot be readily determined in what county the cause of death was inflicted, it shall be considered that the cause of death was inflicted in the county in which the dead body was discovered.’ Inasmuch as [victim’s] body was discovered in Fulton County and the county in which the cause of death was inflicted could not be readily determined, it was proper to allege, and for the jury to find, that venue was appropriate in Fulton County.” Accord, Wallace v. State , 284 Ga. 429, 667 S.E.2d 590 (October 6, 2008); Hargrove v. State , 291 Ga. 879, 734 S.E.2d 34 (November 5, 2012); Jackson v. State , 292 Ga. 685, 740 S.E.2d 609 (March 25, 2013); Walton v. State , 293 Ga. 607, 748 S.E.2d 866 (September 23, 2013); Faulkner v. State , 295 Ga. 321, 758 S.E.2d 817 (May 19, 2014); Perera v. State , 295 Ga. 880, 763 S.E.2d 687 (September 22, 2014) (although evidence showed that victim was attacked at his home in Barrow County, it was unclear where cause of death was inflicted, so venue in Douglas County, where the body was found, was proper). Hollis v. State, 269 Ga.App. 159, 603 S.E.2d 516 (August 16, 2004). Conviction reversed; evidence failed to prove venue. Child molestation allegedly occurred between January, 1997 and August, 1999. Evidence showed that family