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objections not made at trial are waived on appeal even when raised in a motion for new trial).” Accord, Adams v. State , 288 Ga. 695, 707 S.E.2d 359 (February 7, 2011). Campbell v. State, 282 Ga.App. 854, 640 S.E.2d 358 (December 12, 2006). Crawford does not apply to prohibit admission of victim’s prior consistent statements where witness is available to testify. Or to available witness’s prior inconsistent statements, see McKnight v. State , 283 Ga. 56, 656 S.E.2d 830 (January 28, 2008). Accord, Williams v. State , 290 Ga.App. 841, 660 S.E.2d 740 (March 4, 2008) (child molestation victim was subpoenaed by defendant and available to testify); Williams v. State , 335 Ga.App. 841, 783 S.E.2d 362 (February 26, 2016). Richard v. State, 281 Ga. 401, 637 S.E.2d 406 (November 6, 2006). Admission of missing witness’s statement violated Crawford , but cumulative given similar evidence from other witnesses – even though those other witnesses recanted or denied their incriminating statements. Distinguishing Brawner (September 13, 2004, below): “ Brawner does not stand for the proposition that calling into question the credit of any evidence means that such evidence cannot be considered when determining whether there is a reasonable possibility that improperly admitted evidence contributed to a guilty verdict. ” Three justices dissent, saying the error cannot be deemed harmless as a matter of law given that jurors specially asked to re-hear the improper evidence during deliberations, and returned their verdict a few minutes later. Accord, Moore v. State , 283 Ga.App. 533, 642 S.E.2d 163 (February 9, 2007). Rice v. State, 281 Ga. 149, 635 S.E.2d 707 (October 2, 2006). On State’s motion, testimony of murder victim’s husband was taken by deposition, due to his medical condition. On conclusion of State’s direct examination, trial court granted defendant a continuance to allow additional time to prepare for cross. Witness died before the date set to resume the deposition. Trial court denied defense motion to exclude the testimony on grounds that defendant had no opportunity to cross-examine the witness. Held, trial court properly denied the motion. “We agree with the trial court that Rice waived his opportunity to cross-examine Mincher on the day of his deposition. Rice was on notice from the statute governing pretrial depositions that the trial court could order that the deposition occur at any time within 30 days of the hearing. See OCGA § 24-10-130(f). Although Rice’s opportunity for cross-examination was perhaps not ideal given the fact that he had only six days’ notice of the hearing, we find that Rice was afforded a sufficient opportunity for cross-examination and that the lack of cross-examination in this case is the result of his waiving that opportunity.” Brooks v. State, 281 Ga. 14, 635 S.E.2d 723 (October 2, 2006). 1. Admission of co-conspirator statements did not violate defendant’s Confrontation Clause rights. “‘The admission of a co-conspirator’s statement does not violate the Confrontation Clause as long as there are “sufficient indicia of reliability.” Factors indicating reliability include (1) the absence of express assertion of past facts, (2) the co-conspirator had personal knowledge of the facts he was stating, (3) the possibility that the co-conspirator’s recollection was faulty or remote, and (4) the co-conspirator had no reason to lie about the defendant’s involvement in the crime.’ Redwine v. State, 280 Ga. 58, 64 (623 S.E.2d 485) (2005) (quoting Neason v. State, 277 Ga. 789 (596 S.E.2d 120) (2004)).” Here, only the first factor favored defendants. “However, where only the first factor weighs against admission, and the other factors illustrate the reliability of the statement, it does not violate the Confrontation Clause to admit the statements against all co-conspirators. Copeland v. State, 266 Ga. 664, 665- 666 (469 S.E.2d 672) (1996); see also Fetty v. State, 268 Ga. 365, 371-372 (489 S.E.2d 813) (1997) (first factor not dispositive if other factors favor admission); Ottis [ v. State, 269 Ga. 151, 155-156 (496 S.E.2d 264) (1998)] (same).” 2. Statements by co-defendants to fellow inmates while awaiting trial were not testimonial in nature. See also Mathis (May 20, 2009), above (letters between co-conpirators awaiting trial not testimonial). Dickson v. State, 281 Ga.App. 539, 636 S.E.2d 721 (September 13, 2006). Murder conviction reversed based on Crawford violation; trial court erred in admitting witness’s statement to police where defendant’s only opportunity to cross-examine witness was at defendant’s bond hearing. “ In order ‘to insure that the party against whom the testimony is later offered had an adequate opportunity to cross-examine the witness at the previous proceeding,’ the prior hearing must have addressed ‘substantially the same issues’ as those presented at trial. Craft v. State, 154 Ga.App. 682, 683(1) (269 S.E.2d 490) (1980).” The reasonable doubt standard and the significant risk standard cannot be equated; and determining whether a specific crime was committed reaches different issues than determining the possibility of future bad conduct by the defendant,” citing OCGA § 17-6-1(e). Error here was not harmless because the statement of the witness (defendant’s now-deceased father) gave a first-hand account of defendant’s killing of his brother. Lott v. State, 281 Ga.App. 373, 636 S.E.2d 102 (August 30, 2006). Admission of unavailable witness’s statement to police violated defendant’s right to confront witness, however, error was cured by witness’s subsequent appearance at trial. “The State located Jackson the day after her statement was read to the jury. She was placed into custody, brought to
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