☢ test - Í

Navarrete v. State, 283 Ga. 156, 656 S.E.2d 814 (January 28, 2008). ADA who tried defendant’s case testified at the hearing on defendant’s motion for new trial. Held, “ we reject Navarrete’s claim that the trial court committed reversible error by allowing ADA Jackson, who participated as co-counsel for the State in the new trial hearing, to testify in violation of the rule of sequestration. After a proffer, the court allowed Jackson to testify to impeach the testimony of Sergeant Pruitt. A violation of the rule of sequestration generally does not affect the admissibility of the testimony, but may impact on the credibility of the offending witness. Rakestrau v. State, 278 Ga. 872(4) (608 S.E.2d 216) (2005). We find no abuse of discretion in the trial court’s ruling especially in light of the fact that this was a non-jury matter. Id.” Warner v. State, 281 Ga. 763, 642 S.E.2d 821 (March 26, 2007). “[I]n the circumstance, as in this case, in which the State maintains that it needs the presence of the primary investigator for the orderly presentation of the case, the exception of the investigator from the rule of sequestration is within the discretion of the trial court. Williams v. State, 277 Ga. 853, 856- 857(4) (596 S.E.2d 597) (2004).” Carter (February 10, 2005), below, does not require the State to make any more detailed showing, although one was offered here: “the trial court specifically asked the State for more information about why the detective’s presence was needed, and the prosecutor explained that there were many witnesses and ‘hours and hours’ of taped interviews, and that the detective was the one most familiar with such evidence and with the complexities of this particular case.” Accord, Moorer v. State , 286 Ga.App. 395, 649 S.E.2d 537 (July 6, 2007); Morgan v. State , 287 Ga.App. 569, 651 S.E.2d 833 (September 17, 2007); Stafford v. State , 288 Ga.App. 733, 655 S.E.2d 221 (November 1, 2007) (trial court could take prosecutor’s statement that the investigator ‘has assisted me in the prosecution of the case’ to mean “she currently needed the officer’s assistance during the trial.”); Burns v. State , 288 Ga.App. 507, 654 S.E.2d 405 (November 2, 2007); Lewis v. State , 283 Ga. 191, 657 S.E.2d 854 (February 25, 2008); Gray v. State , 291 Ga.App. 573, 662 S.E.2d 339 (May 19, 2008); Hollis v. State , 295 Ga.App. 529, 672 S.E.2d 487 (January 13, 2009) (no evidentiary showing required to support exemption from rule); Butler v. State , 285 Ga. 518, 678 S.E.2d 92 (June 8, 2009); Thorpe v. State , 285 Ga. 604, 678 S.E.2d 913 (June 29, 2009); Nava v. State , 301 Ga.App. 497, 687 S.E.2d 901 (November 23, 2009); Dockery v. State , 287 Ga. 275, 695 S.E.2d 599 (June 7, 2010); Andrews v. State , 307 Ga.App. 557, 705 S.E.2d 319 (January 19, 2011); Mitchell v. State , 290 Ga. 490, 722 S.E.2d 705 (February 6, 2012) (prosecutor “needed the detective with her to ensure the orderly presentation of the State's 28 exhibits and 21 witnesses, some of whom were expected to (and did) testify differently than in their pre-trial statements.”); Holloman v. State , 291 Ga. 338, 729 S.E.2d 344 (July 2, 2012); Kegler v. State , 317 Ga.App. 427, 731 S.E.2d 111 (August 15, 2012) (large number of exhibits, need for orderly presentation); Hudson v. State , 325 Ga.App. 657, 754 S.E.2d 626 (February 5, 2014). Pollio v. State, 278 Ga.App. 729, 629 S.E.2d 583 (April 11, 2006). “[I]t is not an abuse of a trial court’s discretion to allow ‘the chief investigating officer to remain in the courtroom during the testimony of other witnesses for the prosecution,’ despite the invocation of the rule of sequestration. Scully v. State, 256 Ga. 683, 685(3), 353 S.E.2d 29 (1987).” Johnson v. State, 275 Ga.App. 21, 619 S.E.2d 731 (August 8, 2005). “Johnson maintains that the trial court improperly allowed the home owner to testify without a cautionary instruction to the jury because she had violated the rule of sequestration by being present in court when the arresting officer testified. See Thomas v. State, 262 Ga. 754, 756(2)(b) (425 S.E.2d 872) (1993) (trial court properly instructed jury that witness’s violation of the rule of sequestration should be considered by the jury in determining testimony’s weight and credibility). However, the rule of sequestration is invoked by the parties, and Johnson does not show that he insisted upon the rule until after the arresting officer had begun to testify, at which point it appears the witnesses complied. See OCGA § 24-9-61 (with certain exceptions, a party has the right to have the witnesses of the other party examined out of the hearing of each other). The trial court did not err.” Howse v. State, 273 Ga.App. 252, 614 S.E.2d 869 (May 11, 2005). “Citing Stuart v. State, 123 Ga.App. 311 (180 S.E.2d 581) (1971), Howse contends the trial court erred when it failed to require the investigating officer to testify first. Stuart is factually inapposite. In Stuart, we held the trial court erred when it followed its ‘policy’ of allowing the State to call its witnesses in whatever order it desired, rather than exercising its discretion in determining whether to require the witness excepted from the rule of sequestration to testify first. Id. at 313(1). In the instant case, the trial court expressly recognized that it was vested with discretion. ‘No, I don’t think there is a requirement that he testify first. That’s within the discretion of the Court and I’ll allow him to sit at counsel table and I will not require him to testify first.’ Moreover, the investigating officer’s testimony was primarily directed at the playing of his videotape interview with [child molestation victim]. Howse has neither suggested nor demonstrated any harm arising from the alleged violation of the rule of sequestration. Ryles v. State, 177 Ga.App. 537, 538 (339 S.E.2d 792) (1986). The trial court did not err in excepting the