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“Further, contrary to McNair's argument, the prosecutor was not required to show the witness his recorded statements during direct examination to refresh his recollection. OCGA § 24–6–613(a).[fn] Nor was it improper for the prosecutor to impeach his own witness. OCGA § 24–6–607.[fn] Moreover, the prosecutor was authorized to present extrinsic evidence of the witness's prior inconsistent statements for impeachment purposes and as substantive evidence, given the facts of this case. OCGA § 24–6–613(b) provides, in relevant part, that ‘[e]xcept as provided in Code Section 24–8–806, extrinsic evidence of a prior inconsistent statement by a witness shall not be admissible unless the witness is first afforded an opportunity to explain or deny the prior inconsistent statement and the opposite party is afforded an opportunity to interrogate the witness on the prior inconsistent statement or the interests of justice otherwise require.’” 3. Rejects defendant’s argument that prosecution can’t call witness for purposes of impeachment with prior statement. “[U]nlike the Federal Rules of Evidence, [FN10. Under Federal Rule of Evidence 801(d)(1)(A), the cousin's statements would have been inadmissible hearsay because they were not made under oath. The federal rule provides, in relevant part, that a prior inconsistent statement of a declarant-witness is not hearsay if it “was given under penalty of perjury at a trial, hearing, or other proceeding or in a deposition.” OCGA § 24–8–801(d)(1)(A) has no such limitation. ] OCGA § 24–6–613(b) allows a testifying witness's prior inconsistent statements to be admitted both for impeachment purposes and as substantive evidence, making the prosecutor's intent under the circumstances irrelevant.” Dean v. State, 327 Ga.App. 9, 755 S.E.2d 245 (February 27, 2014). Theft by receiving and related convictions affirmed; trial court erred, but harmless, in admitting witness’s inconsistent statement after the witness had been released from his subpoena. “A prior inconsistent statement of a witness should not be admitted unless the witness is available at that time for cross-examination. See Brinson v. State, 268 Ga. 227, 227–228(2), 486 S.E.2d 830 (1997).” Harmless because witness was examined extensively about the statement by counsel on both sides. Johnson v. State, 293 Ga. 530, 748 S.E.2d 434 (September 9, 2013). Malice murder and related convictions affirmed; no due process violation where prosecutor was allowed to cross-examine hostile witness on the prior statement which he repudiated as “lies” on the stand. Distinguishing Douglas v. Alabama, 380 U.S. 415 (85 S.Ct. 1074, 13 L.Ed.2d 934) (1965), where prosecutor was allowed to read aloud prior statement of witness who “invoked the Fifth Amendment and refused to testify.” “In stark contrast, [witness] Hill took the stand in this case, admitted that he had previously talked with police, and testified that his previous statements were based on lies and rumors— testimony that actually inured to Johnson's benefit. Thereafter, the State failed to place Hill's prior recorded statement into evidence, and, as a result, Johnson had the ability to argue to the jury that Hill was not credible and that the only evidence was that he was an admitted liar.” Cannon v. State, 288 Ga. 225, 702 S.E.2d 845 (September 20, 2010). Defendant’s convictions for malice murder and related offenses affirmed, although trial court erred by admitting prior inconsistent statement of witness without proper foundation. “[T]he arresting detective testified that Ms. Clark had previously informed him that she told Cannon, just prior to the shooting, ‘Don't do it!’ Cannon claims that the failure to object to this testimony constituted ineffective assistance because Ms. Clark had already completed her testimony and had not been asked about this statement, and, therefore, the detective's testimony concerning Ms. Clark's alleged statement was not evidence of a prior inconsistent statement but actually inadmissible hearsay. Since the State did not ask Ms. Clark about this statement, it failed to lay a proper foundation for the admission of a prior inconsistent statement. See OCGA § 24-9-83 (‘Before contradictory statements may be proved against him, ... the time, place, person, and circumstances attending the former statements shall be called to his mind with as much certainty as possible.’); Miller v. State, 300 Ga.App. 652, 654, fn. 12 (686 S.E.2d 302) (2009). Therefore, the detective's testimony was inadmissible hearsay.” Deficient representation for failure to object, but no prejudice based on overwhelming evidence. Accord, Feagin v. State , 317 Ga.App. 543, 731 S.E.2d 778 (August 30, 2012) (conviction for interfering with 911 call reversed where only supporting evidence was victim’s prior inconsistent statement, admitted without proper foundation). Hart v. State, 305 Ga.App. 259, 699 S.E.2d 445 (July 15, 2010). Defendant’s convictions for armed robbery, aggravated assault, and related offenses, reversed; trial court erroneously admitted hearsay. When witness Gaines denied telling someone else that defendant had robbed a store, State presented that person, who testified to Gaines’s prior statement to that effect. “The state claims that, because Gaines thus gave testimony it had not expected, it was entitled to impeach him pursuant to OCGA § 24-9-83. … Hart counters that OCGA § 24-9-83 was not properly invoked because the proponent of the evidence (the state) failed to show that the witness it sought to impeach (Gaines) had any personal knowledge of the truth of his alleged previous out-of-court statement (that Hart had committed the robbery at the Bay Station store). Indeed, the Supreme Court of Georgia has repeatedly instructed that ‘ a prior inconsistent statement is inadmissible in the