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written communication as a court exhibit in the presence of counsel; to afford counsel a full opportunity to suggest an appropriate response; and to make counsel aware of the substance of the trial court’s intended response in order that counsel may seek whatever modifications counsel deems appropriate before the jury is exposed to the instruction.” Durham v. State, 281 Ga. 208, 636 S.E.2d 513 (October 16, 2006). “After [defendant] filed her notice to raise issues regarding her mental status and was evaluated by an independent mental health expert, the trial court granted the State’s motion to have [defendant] examined by its own expert. [Defendant]’s counsel knew of the time, place, scope and nature of the examination by the State’s expert but chose not to attend. [Defendant] thereafter filed a motion to suppress her statements made to the State’s expert, claiming the use of her statements would violate her rights under the Fifth and Sixth Amendments to the U.S. Constitution. The trial court denied the motion and the State thereafter introduced at trial its expert’s testimony solely as rebuttal evidence. We find no merit in [defendant]’s contention challenging the denial of her motion. See Stephens v. State, 270 Ga. 354(4) (509 S.E.2d 605) (1998) (no Fifth Amendment violation to introduce State’s expert to rebut defendant’s claim of mental illness; no Sixth Amendment violation where defense counsel knew about examination and its nature and scope). See also Buchanan v. Kentucky, 483 U.S. 402(III) (107 S.Ct. 2906, 97 L.Ed.2d 336) (1987).” Howard v. State, 279 Ga. 166, 611 S.E.2d 3 (March 28, 2005). Murder and related convictions affirmed; no violation of right to counsel in search of defendants’ jail cell and seizure of documents found there. Detective searched defendants’ jail cells without a search warrant, based on co-defendant’s claim that defendants were threatening him and demanding that he sign an affidavit absolving them of responsibility for the crime. “They confiscated some documents that corroborated [co- defendant’s] claim.” Detective “took the documents to the prosecuting attorney, who did not review them, but advised Wynn to deliver them to the trial court for review. The trial court reviewed the documents and conducted an evidentiary hearing, after which it found that no privileged information had been seized. Although defendants make the unspecified claim that the confiscated documents include attorney-client privileged material, the trial court observed that the materials consisted of three affidavits (one signed before a notary republic, and two in blank) along with some legal research. Finding no harm to the defendants, the trial court denied the motion to quash, and returned the documents to the defendants.” Held, “the State established a legitimate purpose for conducting a search for the affidavits, and after an in- camera inspection, the trial court determined that no confidential communications were implicated. It was also shown that the prosecutor was shielded from access to any information obtained by the search, and there is no allegation that the documents were used to the detriment of the defendants at trial. Under the circumstances, we hold the State had a legitimate justification for searching defendants’ cells and that no interference with the Sixth Amendment right to counsel occurred.” Documents here were not privileged because they “were prepared by the defendants and were disseminated to others.” State v. Pinkerton, 262 Ga.App. 858, 586 S.E.2d 743 (August 22, 2003). Pro se defendant’s statements to prosecutor during plea negotiations were not admissible because trial court failed to adequately advise defendant of his right to counsel. Court advised defendant of right to counsel and to appointed counsel. “[T]he court must do more than simply inform defendant of his right to counsel; the court must give the defendant sufficient information and guidance for him to make a voluntary, knowing and intelligent decision about whether to proceed pro se. The accused should understand, for example, the nature of the charges against him, any statutory lesser-included offenses, the range of possible punishments for the charges, possible defenses, mitigating circumstances, and any other facts necessary for a broad understanding of the matter. Otherwise there is no valid waiver.” Based on Ga. Const., Art. I, Sec. I, Para. 14; makes no reference to U.S. Const., Amend. 6. Comment: although Pinkerton speaks in terms of right to counsel at arraignment, real issue addressed is not entering a plea without counsel, but making incriminating statements to prosecutor. Generally, nothing more than Miranda warnings is required under Sixth Amendment when defendant is questioned by state’s attorney post-indictment – see Patterson v. Illinois , 487 U.S. 285, 108 S.Ct. 2389, 101 L.Ed.2d 261 (June 24, 1988) (Type of “rigorous” waiver warning called for in Pinkerton is only required at trial. “Because the role of counsel at questioning is relatively simple and limited, we see no problem in having a waiver procedure at that stage which is likewise simple and limited. So long as the accused is made aware of the ‘dangers and disadvantages of self-representation’ during post-indictment questioning, by use of the Miranda warnings, his waiver of his Sixth Amendment right to counsel at such questioning is ‘knowing and intelligent.’”) Pless v. State, 255 Ga.App. 95, 564 S.E.2d 508 (April 17, 2002). A represented defendant’s pro se motions (in this case, motions for new trial) are void. Accord, McMillan v. State , 266 Ga.App. 729, 598 S.E.2d 17 (March 11, 2004) (not error to deny pro se general demurrer, filed when defendant was represented by counsel. “There is no right to hybrid