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613(c) expands use of prior consistent statements. As defendant notes, old code only allowed prior consistent statements where a party alleged “recent fabrication or improper influence or motive.” New OCGA § 24-6-613(c) provides that “A prior consistent statement shall be admissible to rehabilitate a witness if the prior consistent statement logically rebuts an attack made on the witness’s credibility. A general attack on a witness’s credibility with evidence offered under Code Section 24–6–608 or 24–6–609 shall not permit rehabilitation under this subsection. If a prior consistent statement is offered to rebut an express or implied charge against the witness of recent fabrication or improper influence or motive, the prior consistent statement shall have been made before the alleged recent fabrication or improper influence or motive arose. (emphasis supplied). According to its plain terms, this new rule allows the admission of prior consistent statements if they logically rebut any attack on a witness’s credibility, except for attacks upon his character for truthfulness or evidence of his prior convictions. Accordingly, our inquiry is not limited to asking whether Walters impugned [victim] Mike’s credibility by charging her with recent fabrication or improper influence or motive. We must also consider whether Walters attacked Mike’s credibility on other grounds.” This section also differs from the parallel federal rule, but court here notes 2014 amendment to Federal Rule 801(d)(1)(B), which now allows prior consistent statement “if offered ‘(i) to rebut an express or implied charge that the declarant recently fabricated it or acted from a recent improper influence or motive in so testifying; or (ii) to rehabilitate the declarant’s credibility as a witness when attacked on another ground.’ Fed.R.Evid. 801(d)(1)(B) (2014) (emphasis supplied). This language is not identical to that of OCGA § 24–6–613(c), which allows a prior consistent statement if it ‘logically rebuts an attack made on the witness’s credibility.’” Nevertheless, OCGA § 24–6–613(c) and newly amended Fed.R.Evid. 801(d)(2)(B) both broaden the scope of credibility attacks that can trigger admissibility of a prior consistent statement, such that precedent interpreting the latter may be useful in construing the former.” No federal case precedent yet interprets the change, but “the advisory committee notes indicate that while prior consistent statements remain inadmissible under federal law to bolster a witness’s testimony, they may now come in to rebut a broad range of attacks on a testifying witness’s credibility.” And victim’s credibility was challenged here: “while Walters did not call Mike a liar, he nevertheless attacked her credibility by suggesting that she had misidentified Walters’s weapon during her 911 call and that her account of the events was not believable due to her heightened emotional state.” “Although some of these credibility attacks occurred after Mike’s prior consistent statement was introduced through Neff’s testimony, a prior inconsistent statement may be admissible if the testifying witness’s credibility was ‘eventually attacked’ at a later point in the trial. Pate v. State, 315 Ga.App. 205, 207(1)(a) (726 S.E.2d 691) (2012), citing Sterling v. State, 267 Ga. 209, 213(9) (477 S.E.2d 807) (1996).” And the prior statement here “logically rebut[ted]” the attack on her credibility: “Mike’s prior statement that her assailant had wielded a knife logically rebutted Walters’ suggestion that she had misidentified the weapon. And Mike’s prior statement that she did not scream and flee until Walters pulled the knife logically rebutted his claim that she was so upset when he initially approached her that she misconstrued his intentions.” To the extent that parts of the prior statement didn’t “logically rebut” the attack on her credibility, “it is not probable that the admission of the remainder of Mike’s prior consistent statement contributed to the verdict and that any error was therefore harmless.” Silvey v. State, 335 Ga.App. 383, 780 S.E.2d 708 (November 20, 2015). Burglary convictions affirmed. 1. Physical precedent only on this point. Under 2013 Evidence Code, no error in admitting prior consistent statements of co- conspirator, after he was accused of fabrication to earn a deal from the State. “Silvey does not dispute that his attorney questioned [co-conspirator] Webb’s credibility and raised issues of improper motive during its cross-examination of Webb, and the record demonstrates that Silvey’s attorney, in fact, led off his cross-examination of Webb by questioning his motives for testifying and attacked his credibility throughout. Specifically, Silvey’s attorney elicited testimony that Webb had rejected a plea deal with the hope that the State would offer a better one if he cooperated and testified at Silvey’s trial. Silvey, on the other hand, argues that Webb’s statement did not predate his improper motive of wanting to lessen his own culpability, which Silvey asserts arose when Webb’s house was searched and he was arrested for burglary. We disagree. The statements at issue occurred during Webb’s ride-alongs with police, two of which took place within two days of his arrest and a third around two weeks later. Thus, he made these statements to police investigators during the course of their investigations into the burglaries. And at no point in the cross-examination did Silvey’s attorney imply that Webb had a motive to fabricate at the time of the ride-alongs, nor did he make that argument at the time he objected to the investigator’s testimony. Moreover, the record is devoid of evidence indicating that Webb had been engaged in plea negotiations with the State at the time of the ride-alongs. Under these circumstances, we cannot say that the trial court abused its discretion in admitting the evidence of Webb’s prior consistent statement. See Moon v. State, 288 Ga. 508, 511(4) (705 S.E.2d 649) (2011) (questioning witness about receiving a better plea deal by cooperating and testifying is a ‘classic example of an implication of improper motive for testifying’).” 2. Pretermitting whether allowing detective to testify to statements of victim was proper, its admission was harmless because defendant didn’t contest the accuracy of the statement. Rather, defendant simply denied he was the man the victim saw at her house, and victim

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