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State , 315 Ga.App. 205, 726 S.E.2d 691 (March 27, 2012) (Physical precedent only; “the substantive facts underlying an open juvenile case would not generally be admissible.”). Ziegler v. State, 270 Ga.App. 787, 608 S.E.2d 230 (October 19, 2004). Not error to allow State to explore its own witnesses’ plea agreements on direct examination. Serrate v. State, 268 Ga.App. 276, 601 S.E.2d 766 (July 1, 2004). “Although an attorney is permitted to thoroughly question a testifying co-defendant regarding the details of any plea agreement, it does not necessarily follow that counsel is ineffective for failing to elicit all details of the agreement. Here, Serrate’s attorney questioned [witness] about both a prior drug conviction and his expectation of favorable treatment in exchange for testifying. And counsel also questioned [second witness] regarding his hope that testifying against Serrate would be ‘taken into consideration’ with regard to his case. Thus, the factfinder – in this case the trial court – was provided with evidence that both [witnesses] were potentially biased.” Urapo-Sanchez v. State, 267 Ga.App. 113, 598 S.E.2d 850 (April 15, 2004). “It is well settled that the state must reveal any agreement, even an informal one, with a witness concerning criminal charges pending against that witness, and that a failure to make such a disclosure violates the defendant’s due process rights. [Cit.] But this rule does not require the prosecutor to tell the jury of the agreement, as long as the agreement is made known to defense counsel and defense counsel has the opportunity to cross-examine the witness about it. [Cit.]” Hewitt v. State, 277 Ga. 327, 588 S.E.2d 722 (November 10, 2003). Trial court properly disallowed cross-examination of co-conspirator about his chances for parole while allowing thorough cross regarding charges against him, possible punishment, and his deal with State. Overruled “[t]o the extent that [it] can be read to state that a witness may never be cross-examined regarding eligibility for parole in order to show bias in favor of the State,” Manley (March 1, 2010), above. Cited with approval, Riley (May 6, 2011), above. State v. Vogleson, 275 Ga. 637, 571 S.E.2d 752 (October 28, 2002). Trial court erred by refusing defendant’s attempt to cross-examine co-defendant about the amount of prison time he saved himself by agreeing to testify against defendant. State objected and court excluded testimony on mandatory sentence co-defendant would otherwise have faced, because defendant still faced that same charge. “It is important to note that this concern comes about only when the jury knows that the witness and the defendant were charged with the same crimes and that they have similar criminal histories, and the jury sees the two accomplices as equally culpable or the defendant on trial as less culpable than the accomplice who negotiated a deal. The potential for harm suggested by the State could be put to rest by a limiting instruction given the jury by the trial court prior to the receipt of the witness’s testimony, much like the limiting instruction currently given prior to the admission of similar transaction evidence.” Accord, Perez v. State , 254 Ga.App. 872, 564 S.E.2d 208 (March 27, 2002); Green v. State , 254 Ga.App. 881, 564 S.E.2d 731 (March 27, 2002). Violation of this rule, however, does not require reversal where exclusion of the evidence was harmless beyond a reasonable doubt. Thompson v. State , 266 Ga.App. 29, 596 S.E.2d 205 (March 3, 2004). Distinguished, Perkins (December 7, 2007), above ; Cline v. State , 300 Ga.App. 615, 685 S.E.2d 501 (October 27, 2009) ( Vogleson not applicable where no evidence of deal between State and witness); Sherman v. State , 302 Ga.App. 312, 690 S.E.2d 915 (February 11, 2010) ( Vogleson doesn’t authorize question, “what is the maximum penalty for perjury?” where no deal with State shown). Hernandez v. State, 244 Ga.App. 874, 537 S.E.2d 149 (July 10, 2000). Convictions for entering an auto and related offenses reversed; trial court erred in denying plea in bar based on double jeopardy. Grant of State’s motion for mistrial over defense objection was not “manifestly necessary” as, contrary to State’s argument, defense cross of State’s witness wasn’t improper. Trial court granted mistrial after defense counsel asked cooperating co-defendant on cross about sentence he avoided by agreeing to testify against defendant for lesser charge, including fact that conviction for armed robbery includes no parole. 1. While OCGA § 17-8-76 requires mistrial if counsel argues to the jury “that a defendant, if convicted, may not be required to suffer the full penalty imposed by the court or jury because pardon, parole, or clemency of any nature may be granted by the Governor, the State Board of Pardons and Paroles, or other proper authority vested with the right to grant clemency,” that rule doesn’t apply to witnesses other than the defendant. 2. The defendant has a constitutional right to explore the witnesses’ bias or motivation in testifying , citing “ Delaware v. Van Arsdall, 475 U.S. 673, 680, 106 S.Ct. 1431, 89 L.Ed.2d 674 (1986) (criminal defendant shows violation of confrontation clause by showing he was prohibited from engaging in otherwise appropriate cross-examination designed to show bias of witness); Davis v. Alaska, 415 U.S. 308, 316, 94 S.Ct. 1105, 39 L.Ed.2d 347 (1974) (partiality of witness subject to exploration at trial because Supreme Court has ‘recognized that the exposure of a
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