☢ test - Í

West v. State, supra, 200 Ga. at 569, 37 S.E.2d 799.” Phillips v. State, 289 Ga.App. 281, 656 S.E.2d 905 (January 24, 2008). “ Under the rule of completeness, the trial court did not abuse its discretion in allowing the state to read from the incident report to the jury. As recognized in Dickerson v. State, 280 Ga.App. 29 (633 S.E.2d 367) (2006), this rule is that ‘when an admission, conversation or declaration previously made by a party or a witness is pertinent, the side tendering evidence as to the same is at liberty to prove such portion only thereof as is deemed material, and the other side may then bring out the whole of the admission, conversation or declaration, so far as so doing may be essential in order to arrive at the true drift, intent and meaning of what was said on the previous occasion.’ Id. at 35(3). Here, the court was authorized to find that it was necessary for the state to admit all relevant parts of the incident report in evidence to show that the omissions noted by Phillips were not so material as to have effected the accuracy of the report.” Bowe v. State, 288 Ga.App. 376, 654 S.E.2d 196 (November 9, 2007). Trial court erred in failing to sever co-defendants’ trials, as it prevented co-defendant Baker from tendering portions of his statements to police which were exculpatory as to Baker and incriminating to Bowe. Baker contended that Bowe coerced him into participating in string of armed robberies for which they were jointly tried. Neither defendant testified at trial, but State tendered incriminating portions of Baker’s prior statements. “Although the excluded portions of the statement were self-serving hearsay, ‘[w]here a part of a conversation, which amounts to an incriminatory admission, is admitted in evidence, it is the right of the accused to bring out other portions of the same conversation, even though it is self-serving in its nature, or exculpatory, in that it justifies, excuses, or mitigates the act.’ West v. State, 200 Ga. 566, 569 (37 S.E.2d 799) (1946).” Houston v. State, 270 Ga.App. 456, 606 S.E.2d 883 (November 15, 2004). “[D]uring [witness’s] cross-examination, the defense read portions of the written statement to [witness] in front of the jury and questioned [witness] about the written statement using phrases and lines from the statement. Defense counsel pursued the inconsistencies between [witness’s] trial testimony and her statement to the detective, specifically the statement’s identification of the robber as a man. OCGA § 24-2-4 provides that where either party introduces part of a document or record, the opposite party may read ‘so much of the balance as is relevant.’ The state was entitled to rebut the implication that [witness] told the detective the robber was a male by reading the entire statement to the jury, including the portions referring to the robber as a female. Jackson v. State, 262 Ga.App. 451, 585 S.E.2d 745 (July 18, 2003). “‘The rule of evidence is, that when an admission, conversation or declaration previously made by a party or a witness is pertinent, the side tendering evidence as to the same is at liberty to prove such portion only thereof as is deemed material, and the other side may then bring out the whole of the admission, conversation or declaration, so far as doing so may be essential in order to arrive at the true drift, intent and meaning of what was said on the previous occasion.’” Based on OCGA § 24-3-38. 2. PRIOR CONSISTENT STATEMENTS See also EVIDENCE – STATEMENTS OF DEFENDANT – PRIOR CONSISTENT STATEMENTS, above Seminal cases: Cuzzort v. State, 254 Ga. 745, 334 S.E.2d 661 (1985); Woodard v. State , 269 Ga. 317, 496 S.E.2d 896 (1998). See Hackett (March 15, 2005), below. See OCGA § 24-6-613(c) Mosley v. State, S16A0514, ___ Ga. ___, ___ S.E.2d ___, 2016 WL 1295024 (April 4, 2016). Malice murder and related convictions affirmed; under 2013 Evidence Code, no error in admitted evidence of co-conspirator’s prior consistent statement. “Phillips confessed to his friend only a short time after the shooting, and that confession predated the plea offer that, according to Mosley, had led Phillips to fabricate his testimony. And because Phillips testified and was subject to cross-examination about his prior statement, testimony about what Phillips said to his friend shortly after the shooting would have been admissible as a prior consistent statement made by Phillips.” Franklin v. State, S15A1308, ___ Ga. ___, ___ S.E.2d ___, 2016 WL 1085235 (March 21, 2016). Murder and related convictions affirmed. Under pre-2013 Evidence Code, witness’s prior consistent statement was properly admitted following defense attack on his credibility – “his pending, serious criminal charges—that arose subsequent to the time Green made his statement to Detective Smith.” Walters v. State, 335 Ga.App. 12, 780 S.E.2d 720 (November 20, 2015). Aggravated assault and weapons convictions affirmed; under 2013 Evidence Code, no error in admission of witness’s prior consistent statement. New OCGA § 24-6-