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Secure the Attendance of Witnesses from Without the State (‘Uniform Act’), OCGA § 24-10-92.” 1. Foreign court’s certificate issued “‘in the words of the statute, … is sufficient’” to have prima facie validity as a finding that Wollesen was a material witness in the grand jury proceeding, without further findings of fact by the foreign court. “‘[I]nasmuch as the certificate is issued by a judge of the requesting state who has satisfied himself as to the sufficiency of the evidence or facts to establish the necessary conditions for the making of the certificate, it is not required that he give the basis of his decision in order to have a certificate that is prima facie good.’ Skakel v. State of Fla., 738 So.2d 468, 471 (Fla. App., 1999), also citing numerous cases from other states . Maryland certificate was accompanied by supplemental affidavit from Maryland prosecutor, explaining why Wollesen’s attendance was sought (regarding alleged fraudulent transfer of funds to Wollesen by her son to avoid payment of child support and property division). 2. “‘It is logically the witness' burden to come forward with evidence of undue hardship, not the State's duty to negate the existence of undue hardship,’ Ex Parte Armes, 582 S.W.2d 434 (Tex. Crim. App., 1979).” 3. Maryland prosecutor’s affidavit was properly considered over Wollesen’s hearsay objection. “[T]he admission of evidence in a hearing held to determine whether a witness who resides in Georgia should be compelled to testify before a grand jury in a foreign state is analogous to the admission of evidence at a grand jury proceeding.” 4. Act allows issuance of a subpoena duces tecum. “‘Indeed, the power to compel a witness to appear and the power to compel production of documents both are critical and fundamental to the evidence-gathering process....’ Delit v. State, 583 So.2d 1083, 1085 (Fla., 1991).” U. PRIOR STATEMENTS See new OCGA § 24-6-613, 24-8-801(d) 1. COMPLETENESS See new OCGA §§ 24-1-106, 24-8-822 Westbrook v. State, 291 Ga. 60, 727 S.E.2d 473 (May 7, 2012). Malice murder and related convictions affirmed; where defense introduced part of a prior statement by State’s witness, State was entitled to introduce other relevant portions under the rule of completeness. “OCGA § 24–3–38 provides, ‘When an admission is given in evidence by one party, it shall be the right of the other party to have the whole admission and all the conversation connected therewith admitted into evidence.’ This longstanding rule prevents litigants from misleading the jury by presenting portions of prior statements taken out of context and is often ‘essential in order to arrive at the true drift, intent and meaning of what was said on the previous occasion.’ Smalls v. State, 105 Ga. 669, 671, 31 S.E. 571 (1898). Thus, ‘[i]t is the universal rule, in both civil and criminal cases, that, if part of a conversation is introduced, all that is said in the same conversation which is relevant to the issue should be admitted. ’ West v. State, 200 Ga. 566, 569, 37 S.E.2d 799 (1946). Appellant notes that § 24–3–38 does not make admissible parts of a statement that are irrelevant to the case and to the parts of the statement introduced into evidence by the opposing party. See Boatman v. State, 272 Ga. 139, 141, 527 S.E.2d 560 (2000). But the part of [witness] Moses's prior statement challenged here satisfies this requirement. It helped to rebut the defense's charge that Moses had fabricated his incriminating testimony at trial by showing that he had also made statements incriminating Appellant during his pre-trial interview with defense counsel, and the statement also addressed Appellant's self-defense claim and thus was relevant to the case.” Wilson v. State, 285 Ga. 224, 675 S.E.2d 11 (February 23, 2009). At Wilson and Frazier’s joint murder trial, trial court properly prohibited Wilson’s attorney from playing for the jury parts of Wilson’s custodial statement inculpatory to Frazier, although parts incriminating to Wilson were played to jury by district attorney, unless Wilson took the stand and was subject to cross-examination by Frazier. Wilson’s request was based on the ‘rule of completeness’ found in OCGA § 24-3-38. Based on West v. State , 200 Ga. 566, 569, 37 Ga.App. 799 (1946): “once a defendant's incriminating admissions are admitted into evidence, the statute gives the accused the right to bring out another portion of the conversation in which he made the incriminating admissions, ‘in that [the other portion of the conversation] justifies, excuses, or mitigates the act.’ See Bowe v. State, 288 Ga.App. 376(3), 654 S.E.2d 196 (2007) (error to deny motion to sever where portion of defendant's statement implicating co-defendant also contained evidence of defendant's defense antagonistic to that of the co-defendant (that he had been coerced by co-defendant into committing the crime)).” Rights under this code section “must … yield to the constitutional underpinnings of Bruton: when the State introduces the inculpatory portions of a defendant's statement as the admission of a party-opponent (see Teal v. State, 282 Ga. 319(3), 647 S.E.2d 15 (2007)), the trial court correctly defuses a non-testifying defendant's attempt to use OCGA § 24-3-38 to gain admission into evidence of the remainder of the defendant's statement which includes a portion that directly inculpates his co-defendant in the crime. Where, however, the portion of the defendant's statement that directly inculpates his co-defendant also contains evidence of the defendant's defense, that portion of the defendant's statement must be admitted, and the State's ability to try defendants jointly must yield. See Bowe v. State, supra, 288 Ga.App. at 385, 654 S.E.2d 196. Cf.