☢ test - Í

Accord, Williams v. State , 291 Ga.App. 279, 661 S.E.2d 658 (April 24, 2008); Danenberg v. State , 291 Ga. 439, 729 S.E.2d 315 (June 25, 2012) (proper to admit recorded interviews with murder victim’s small sons made soon after her murder, at trial 20 years later when they couldn’t remember details of the event). Hampton v. State, 282 Ga. 490, 651 S.E.2d 698 (October 9, 2007). “[T]he trial court erroneously instructed the jury that it could consider prior consistent statements as substantive evidence only if they were made by someone other than the witness whose testimony they are designed to bolster.” McClendon v. State, 287 Ga.App. 238, 651 S.E.2d 165 (August 13, 2007). Trial court properly admitted police officer’s prior consistent statement; defendant affirmatively placed officer’s veracity in issue by cross-examining the officer about a detail of the incident mentioned on direct, but not mentioned in his report. “On redirect examination … the prosecutor asked questions about the responding officer’s report which showed that McClendon’s instruction to [co- conspirator] Horton was not the only detail the responding officer omitted from his report. The jury could have inferred from defense counsel’s cross-examination that the responding officer’s statement that he heard McClendon direct Horton to get into the truck was a recent fabrication. Because the veracity of the responding officer’s trial testimony had therefore been placed in issue at trial, the trial court did not abuse its discretion in admitting the officer’s prior consistent statement. Brown v. State, 273 Ga.App. 577, 580(2) (615 S.E.2d 628) (2005).” Smith v. State, 282 Ga.App. 339, 638 S.E.2d 791 (November 8, 2006). Victim’s credibility was placed in issue sufficiently to authorize admission of her prior consistent statement to her doctor. “As set forth in Tuff v. State, 278 Ga. 91, 94(4) (597 S.E.2d 328) (2004), ‘[a] witness’s prior consistent statement is admissible only where: (1) the veracity of a witness’s trial testimony has been placed in issue at trial; (2) the witness is present at trial; and (3) the witness is available for cross-examination. A witness’s veracity is placed in issue so as to permit the introduction of a prior consistent statement if affirmative charges of recent fabrication, improper influence, or improper motive are raised during cross- examination.’ (Footnote omitted.) Here, the victim testified at trial and was cross-examined by Smith. During that cross- examination, Smith insinuated that improper motive was the reason she testified that the sex was non-consensual. Specifically, as he had asserted in opening statement, Smith implied during cross-examination that because the victim’s mother would have been upset if she believed her daughter were having consensual sex with the mother’s old boyfriend, the victim had falsely testified that Smith forced her to engage in sex, which testimony was designed to preserve her relationship with her mother and to continue her receipt of food and shelter from her mother. Accordingly, the victim’s prior consistent statement to her physician was thereafter properly admitted. See Shields v. State, 264 Ga.App. 232, 237(2) (590 S.E.2d 217) (2003) (‘ both the cross-examination and the opening statement by the defense implied that the victim’s allegations were improperly motivated’; victim’s prior consistent statement properly admitted).” Accord, Green v. State , 281 Ga. 322, 638 S.E.2d 288 (November 28, 2006); Brown v. State , 287 Ga.App. 857, 652 S.E.2d 807 (September 17, 2007); Warren v. State , 283 Ga. 42, 656 S.E.2d 803 (January 28, 2008); Overton (November 26, 2008) , above ; Ward v. State , 304 Ga.App. 517, 696 S.E.2d 471 (June 21, 2010). Buchanan v. State, 282 Ga.App. 298, 638 S.E.2d 436 (November 7, 2006). Trial court properly refused to let victim’s written statement go out with jury; although it was not read from the stand, “Buchanan’s attorney thoroughly covered the substance of the statement in his examination of both [victim/witness] Milton and the investigator who wrote the statement.” Citing Broadnax-Woodland v. State , 265 Ga.App. 669, 595 S.E.2d 350 (February 18, 2004). Thompson v. State, 281 Ga.App. 627, 636 S.E.2d 779 (September 20, 2006). Victim/witness’s veracity was placed in issue where his friend testified on cross that he would lie for victim; but admission of victim’s prior consistent statement was “arguably” error, as victim’s motive to lie “arose shortly … before [victim] made his initial statement to the investigating officer.” “[When] a witness is alleged to have been motivated or influenced to testify falsely, his or her prior consistent statement may be introduced only if the prior statement was made before the alleged motive or influence came into existence. Woodard v. State, 269 Ga. 317, 320(2) (496 S.E.2d 896) (1998).” If error, however, harmless given overwhelming evidence of guilt. Brown v. State, 273 Ga.App. 577, 615 S.E.2d 628 (June 8, 2005). Witness’s veracity was placed in issue such as to authorize admission of his prior consistent statement: “The transcript here shows that during cross-examination, Brown’s trial attorney posed questions to Holloman which were clearly intended to challenge the truthfulness of his trial testimony by showing that his present recollection of events was suspect since he could recall certain things concerning the crimes but not others. Counsel also elicited testimony from Holloman that part of his plea negotiation included the agreement to testify against Brown. The trial court did not err in admitting the prior statement in this case.” Accord, Brown v. State ,