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Richardson, supra at 697; see Kimmons v. State, 267 Ga.App. 790, 791-792(1)(a) (600 S.E.2d 783) (2004).” Disapproved on other grounds, Thomas v. State , 292 Ga. 429, 738 S.E.2d 571 (February 18, 2013). Hunnicutt v. State, 276 Ga.App. 547, 623 S.E.2d 714 (November 23, 2005). “Although a defendant is entitled to a thorough and sifting cross-examination, the trial court has a duty to protect a witness from being unfairly dealt with, and does not abuse its discretion in prohibiting cross-examination questioning in a ‘rapid-fire’ method. Harris v. State, 272 Ga.App. 650, 652-653(4) (613 S.E.2d 170) (2005). Here, defense counsel often cut off witnesses’ answers and sometimes prefaced his questions with statements or recitations.” No abuse of trial court’s discretion in so doing. Courrier v. State, 270 Ga.App. 622, 607 S.E.2d 221 (November 23, 2004). “During his cross-examination of the [victim], Courrier sought to use excerpts from the videotaped interview of her by authorities. The trial court prevented this method of cross-examination, holding that the entire videotape would be played later and that Courrier could use it thereafter to cross-examine the [victim] during his portion of the case if he wished to recall her…. ‘[E]very party has a right to a thorough and sifting cross-examination of witnesses called against him. OCGA § 24-9-64 .’ Givens v. State, 264 Ga. 522, 523 (2) (448 S.E.2d 687) (1994) In Carswell v. State , 268 Ga. 531, 534 (5) (491 S.E.2d 343) (1997), the trial court refused to allow defense counsel to play a videotape during the cross-examination of a State witness. The Georgia Supreme Court held: ‘By refusing to allow defense counsel to play the ... videotaped statement, ... the trial court effectively cut off in limine all inquiry on a subject with respect to which the defense was entitled to a reasonable cross- examination. This was an abuse of discretion.’ (Punctuation omitted.) Id. at 535(5) . Similarly, we hold that the trial court abused its discretion here in refusing to allow Courrier to use the videotape in the cross-examination of his daughter. See Givens, supra at 523-524 (2) (it is better practice for a trial court to allow a defendant to cross-examine a witness by use of a videotape showing the actual incident in question involving the witness).” Harmless error, however, “because the subject matter was covered later during the trial when the entirety of the videotape was played and because Courrier had the opportunity to verbally cross-examine the [victim] during the State’s case regarding her former statements to authorities (even though the precise method of using the videotape to confront her was precluded).” Herring v. State, 263 Ga.App. 470, 588 S.E.2d 286 (October 1, 2003). Trial court did not abuse its discretion when it prohibited defense counsel’s cross-examination of special agent about a different case where he allegedly misidentified the defendant. “‘[T]he extent of cross-examination can be curtailed if the inquiry is not relevant or material, and such restriction lies within the discretion of the trial court[,] which will not be disturbed on appeal unless manifestly abused.’” Identification testimony here was corroborated by other evidence. Sallie v. State, 276 Ga. 506, 578 S.E.2d 444 (March 24, 2003). Malice murder and related convictions affirmed. After kidnapping and raping his wife, and while still holding her against her will, defendant made an audiotape with her reminiscing about their marriage and made regretful statements about his violent acts. He also wrote several notes of a similar nature. At trial, defendant sought to cross-examine the wife about the audiotape and notes without admitting them into evidence (and thus losing right to closing argument). Held, court properly sustained state’s objection to the cross- examination without tendering the tape and notes. Court instead allowed counsel to cross-examine the wife about the statements made by the defendant, without referring to the existence of the tape and notes. Phyfer v. State, 259 Ga.App. 356, 577 S.E.2d 56 (January 29, 2003). “Although a defendant is entitled to a thorough and sifting cross-examination as to all relevant issues, the trial court, in determining the scope of relevant cross-examination, has a broad discretion. Generally speaking, the Confrontation Clause guarantees an opportunity for effective cross- examination, not cross-examination that is effective in whatever way and to whatever extent, the defense might wish.” Court did not abuse discretion in preventing counsel from cross-examining 16-year-old witness in “rapid-fire” fashion. “[I]n allowing a thorough and sifting cross-examination, the trial court has a duty ‘to protect a witness from being unfairly dealt with.’” Accord, Walker v. State , 267 Ga.App. 155, 598 S.E.2d 875 (April 21, 2004) (“[T]he state has a legitimate interest in protecting witnesses from harassment and intimidation. Harris v. State , 257 Ga. 666, 362 S.E.2d 211 (1987). Thorough cross-examination is a principal means of ascertaining the truth, but a witness has a right to be examined only as to relevant matters and to be protected from improper questions and from harsh and insulting demeanor. Id. The trial court did not err in placing a limit on the questions Walker could ask related to the victim being a stripper.”); Jones v. State , 305 Ga.App. 586, 699 S.E.2d 810 (July 30, 2010) (trial court could limit defendant’s re-cross of co- defendant; “[w]hile a defendant is entitled to effective cross-examination, [s]he is not entitled to unfettered cross- examination, and the trial court has broad discretion in limiting its scope.”).
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