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the statute.” Accord, A.A. Professional Bail v. State , 279 Ga.App. 113, 630 S.E.2d 620 (April 27, 2006); First Choice Bonding Co. (June 10, 2009), above. Reliable Bonding Co. v. State, 262 Ga.App. 280, 585 S.E.2d 192 (July 10, 2003). Where surety received notice to show cause why judgment shouldn’t be entered on bond, trial court had no duty to send copy of judgment absolute to surety. OCGA 15-6-21(c), requiring notice of orders to the parties, is satisfied by the prior notice that judgment will be entered absent cause shown. Classic City Bonding Co. v. State, 256 Ga.App. 577, 568 S.E.2d 834 (July 16, 2002). Notice of bond forfeiture proceeding was sent to bonding company 12 days after defendant’s failure to appear. Bonding company moved for judgment in its favor, based on requirement of OCGA § 17-6-71 that such notice be sent within 10 days of the failure to appear. Held, forfeiture of the bond is affirmed; substantial compliance with the notice requirement is sufficient; strict compliance is not required. Superseded by 2009 amendment requiring that “[s]uch ten-day notice shall be adhered to strictly.” See A.A. Professional Bail (September 14, 2010), above. Delta Bail Bonds v. State, 245 Ga.App. 491, 538 S.E.2d 146 (August 8, 2000). Bond forfeiture judgment affirmed; trial court properly considered “due diligence” on part of the bonding company when it declined to release the company from liability under OCGA § 17-6-31(d)(2). Evidence at hearing showed that the surety learned shortly after issuing the bond that the defendant had used an alias and a false address, but didn’t hire a private investigator to find him until several months later when he failed to appear for arraignment. Raburn Bonding Co. v. State , 244 Ga.App. 386, 535 S.E.2d 763 (June 9, 2000). Trial court erred in refusing order to return bond paid in by bonding company where principal/defendant was found to be on active duty in U.S. Army in Germany. Bond was forfeited after defendant’s failure to appear for trial on unspecified misdemeanor charges. Bondsman paid in amount of bond, then moved for return of bond on grounds that defendant was on active duty. Trial court erroneously concluded “that under OCGA § 17-6-31, when the principal is not surrendered to the court, the bondsman may receive a remission only if application is made before a final judgment on the appearance bond is entered.” The “prior to entry of judgment” limitation is found in subsection 31(d)(1), and only applies when “there is: (A) A deferred sentence; (B) A presentence investigation; (C) A court ordered pretrial intervention program; (D) A court ordered educational and rehabilitation program; (E) A fine; (F) A dead docket; or (G) Death of the principal.” Subsection (f), however, provides that “‘No judgment shall be rendered on any appearance bond if it is shown to the satisfaction of the court that the surety was prevented from returning the principal to the jurisdiction because such principal was on active military duty.’ This subsection, unlike subsection (d), is not couched in terms of releasing the bondsman from liability; it prohibits entry of judgment on an appearance bond if the condition in the subsection is met. … Subsection (f) of the statute involves a situation in which the contract has not been fully performed; it has been canceled because of the impossibility of performance by the bondsman. ‘If the nonperformance of a party to a contract is caused by the conduct of the opposite party, such conduct shall excuse the other party from performance.’ OCGA § 13-4-23. Rolack's conduct in obeying his orders to move to Germany brought the contract within the purview both of OCGA § 17- 6-31(f) and of OCGA § 13-4-23. Raburn was prevented from performing its part of the contract because Rolack was on duty with the Army in Germany. And because it was impossible for Raburn to perform because of Rolack's conduct, Raburn's performance was excused. No judgment should have been entered on the bond in the first place, and no gratuity is involved in remitting the bond, because the contract is unenforceable.” Distinguished, Gomez-Ramos v. State , 297 Ga.App. 113, 676 S.E.2d 382 (March 11, 2009) (bond forfeiture proper where defendant was deported). Vargas v. State , 243 Ga.App. 725, 534 S.E.2d 173 (April 27, 2000). In defendant’s forgery prosecution, trial court properly issued judgment absolute forfeiting defendant’s cash bond, although defendant was prevented from appearing due to her deportation to Mexico. Contrary to defendant’s argument, her deportation was not “the functional equivalent of a ‘sentence’ and resulting ‘detention’ as contemplated by OCGA § 17-6-72(b). …. OCGA § 17-6-72(b) states in pertinent part that: ‘[n]o judgment shall be rendered on a forfeiture of any appearance bond if it is shown to the satisfaction of the court that the principal on the bond was prevented from attending because he or she was detained by reason of arrest, sentence or confinement in a penal institution or jail in the State of Georgia, or so detained in another jurisdiction.... An official written notice of the holding institution in which the principal is being detained or confined shall be considered proof of the principal's detention or confinement.’ (Emphasis supplied.) … Here, Vargas is not being detained in a penal institution. She is not being detained at all. That she cannot reenter the United States does not make her “detained” in Mexico. Under the plain language of the statute, the forfeiture exception provided by OCGA § 17-6- 72(b) does not apply in the instant case. The trial court did not err in entering a final judgment ordering the forfeiture of

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