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(2009) (holding that a co-defendant's prior statements made at his guilty plea hearing were not admissible to corroborate his trial testimony because the witness's ‘guilty plea hearing did not predate any improper motive he may have had to testify against [the defendant]’). See also Moon v. State, 288 Ga. 508, 511–512, 705 S.E.2d 649 (2011) (holding that the defendant's cellmate's statement given to the police in a pre-trial interview did not predate the cellmate's alleged motive to fabricate his testimony to obtain a plea deal on his pending federal drug charges); Duggan [ v. State, 285 Ga. 363, 366, 677 S.E.2d 92 (2009)] (holding that statements given by a witness at the police station on the night of the crime ‘did not predate any alleged influence or motive, such as the fact that [the defendant] was accused of killing one of [the witness's] relatives, that might have influenced [the witness's] testimony’). The only motive to fabricate that Cowart and Adams alleged Izzo to have when he testified at trial—the desire to tell a story that the State would reward with reduced charges and a shorter sentence—arose no later than the time Izzo made his proffer during plea negotiations. Indeed, in its briefs and at oral argument, the State did not identify any motive Izzo had when testifying at trial that he did not also have when making his proffer statement. The fact that the State apparently had not yet offered a specific plea bargain to Izzo when he made his proffer does not distinguish this case from Mister and Moon; if anything, that would make his motivation to please the State when giving the proffer even greater than if he had the plea deal in hand.” Harmless as to Cowart, but not as to Adams, based on other evidence in record or lack thereof, respectively. Ryans v. State, 293 Ga. 238, 744 S.E.2d 759 (June 17, 2013). Malice murder and related convictions affirmed; under pre- 2013 Evidence Code, testifying co-defendant Madison’s prior consistent statement was properly admitted after defendant suggested on cross that Madison’s testimony was recently fabricated. Jackson v. State, 292 Ga. 685, 740 S.E.2d 609 (March 25, 2013). Murder and related convictions affirmed; under pre- 2013 Evidence Code, trial court properly admitted officer’s testimony about prior statement of State’s witness whose veracity was called into question by defense. Defense counsel “implied that [witness] Bennie had an improper motive for his testimony, namely diverting suspicion for the victim's death from his sons.” “Detective Dimasi testified during his direct examination that Bennie Grissom told police during the investigation that appellant confessed to Bennie that he had killed the victim.” Kidd v. State, 292 Ga. 259, 736 S.E.2d 377 (January 7, 2013). Murder and related convictions affirmed; under pre-2013 Evidence Code, trial court properly admitted prior consistent statements of State’s witnesses after defense challenged the veracity of their courtroom testimony. “At trial, Stephanie Fallen, the victim's cousin, testified that appellant approached her in August 1999 looking for the victim and threatening to kill the victim. The record shows that on cross-examination, appellant challenged Fallen's veracity by posing questions that suggested she had been dishonest about how long she had known appellant and about whether appellant knew she was the victim's cousin. Thomas Reynolds was an eyewitness to the shooting of the victim and testified on direct examination that he saw something shiny in appellant's hand when he and the victim began to fight, but did not know what the shiny object was. Reynolds also stated that he heard three gunshots in quick succession and that the gunshots sounded as if they were fired from a small caliber weapon. On cross-examination, defense counsel similarly challenged Reynolds's veracity by posing questions that suggested Reynolds had previously stated that he saw a gun in appellant's hand and that the gunshots he heard were muffled. Defense counsel's questions implied that Reynolds's trial testimony was recently fabricated. In both instances, the State, on re-direct, used the witnesses's prior sworn statements to rehabilitate their trial testimony. Under these circumstances, the trial court did not abuse its discretion in allowing the admission of the prior consistent statements.” Unclear how the first witness’s prior statement predated any “alleged fabrication, improper influence, or improper motive.” Mims v. State, 314 Ga.App. 170, 723 S.E.2d 486 (February 16, 2012). Aggravated battery and related convictions affirmed; victim’s prior consistent statement to officers properly admitted after her veracity was challenged on cross. On cross, “defense counsel was able to elicit testimony from [victim] M.C. in which she admitted to consuming a quart of beer and a half-pint of vodka just prior to the assault, that she never saw Mims carrying a stick, and that she did not see the first blow to the back of her head because it came from behind her.” Later, over objection, prosecutor was allowed to elicit testimony from officer about M.C.’s statements to him at the scene, identifying Mims as her attacker. Held, statement was properly admitted to rebut insinuation of recent fabrication. “Although Mims's trial counsel did not directly accuse M.C. of lying, her veracity was certainly challenged by questions eliciting the fact that she had been drinking heavily just prior to the assault and that she did not actually see the weapon or the first blow. Thus, at the very least, Mims's cross-examination of M.C. strongly implied that her direct testimony constituted a recent fabrication. [fn] Additionally, it is undisputed that M.C.'s statement to the responding officer predated her allegedly fabricated trial testimony. See Brown v. State, 310 Ga.App. 835, 838(1)(b), 714 S.E.2d 395 (2011) (noting that victim's prior consistent