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Parks v. State, 294 Ga.App. 646, 669 S.E.2d 684 (November 18, 2008). Charged with “theft by deception for obtaining money belonging to the victim by ‘depositing a stolen check in [her] bank account and then withdrawing United States currency,’” Parks contends that the trial court erred in admitting “evidence of his bad character” – evidence that he also withdrew $200 from victim’s account by ATM, and evidence of the theft of the check. Defendant complains that these incidents were similar transactions for which “he had not received a similar transaction notice under USCR 31.1 and 31.3.” Held, trial court committed no error in admitting the evidence. “‘Surrounding circumstances constituting part of the res gestae may always be shown to the jury along with the principal fact, and their admissibility is within the discretion of the trial court. Hence, acts and circumstances forming a part or continuation of the main transaction are admissible as res gestae and it does not matter that the act is another criminal offense.’ (Citations, punctuation and footnotes omitted.) McLendon v. State, 258 Ga.App. 133, 134-135(2) (572 S.E.2d 763) (2002). Moreover, ‘[t]he State is entitled to present evidence of the entire res gestae of a crime even though the defendant is not charged with every crime committed during the entire criminal transaction.’ (Citation omitted.) Flowers v. State, 191 Ga.App. 396, 399(2) (381 S.E.2d 768) (1989). Here, Parks' withdrawal from the Fulton County ATM and the check theft were sufficiently connected in time and event to the theft by deception charge that all of the offenses were part of a single transaction, and the trial court did not err in admitting the evidence.” Waters v. State, 294 Ga.App. 442, 669 S.E.2d 450 (November 7, 2008). Evidence of crimes committed in another county as part of same “course of conduct” as offenses on trial were properly admitted as res gestae . “Here, the incidents in Gwinnett County occurred within two hours of the attack and armed robbery in Hall County, and showed a pattern of conduct related to his criminal acts committed during the night in question. Furthermore, these acts were relevant to show Water's frame of mind in the time period immediately preceding and following the Hall County crimes. When there is evidence of other criminal transactions ‘which show a course of conduct pointing toward and leading to the crime, such evidence is admissible as an exception to the general rule that evidence of independent crimes is inadmissible.’ Spurlin v. State, 228 Ga. 2, 4, 183 S.E.2d 765 (1971); see OCGA § 24-3-3.” Bubrick v. State, 293 Ga.App. 502, 667 S.E.2d 666 (September 9, 2008). At defendant’s trial for obstruction and other charges, not improper character evidence to admit defendant’s repeated statements “that he was not going to jail.” “Here, the words Bubrick repeatedly screamed as he refused to comply with the officers' commands and resisted restraint by them demonstrated his intent to commit the counts of obstruction and hindering underlying this case. Evidence of Bubrick's utterances, therefore, was not rendered inadmissible merely because it incidentally put his character at issue. See Richie v. State, 258 Ga. 361, 362(3) (369 S.E.2d 740) (1988).” Gassett v. State, 289 Ga.App. 792, 658 S.E.2d 366 (January 31, 2008). Defendant was arrested in a hotel room, charged with possession of cocaine with intent to distribute; defendant told police that the drugs weren’t his, and that he went to the hotel room to have sex with one of the two women there. Held, this “statement was relevant and admissible to support the state’s theory that he was at the hotel room to exchange sex for drugs. Indeed, Gassett relied upon this statement himself to explain his purpose for being at the hotel room, although he denied knowing about the drugs.” Thrasher v. State, 289 Ga.App. 399, 657 S.E.2d 316 (January 30, 2008). Physical precedent only. Trial court properly admitted evidence of arrest warrant issued for defendant “to explain why the police were able to detain, handcuff, and search Thrasher,” leading to the discovery of drugs on her person. “Here, the officers’ testimony regarding the arrest warrant was limited to the existence of the warrant and was part of the circumstances surrounding Thrasher’s subsequent arrest.” Hampton v State, 287 Ga.App. 896, 652 S.E.2d 915 (October 23, 2007). At the end of a traffic stop (for a tail light violation), deputy saw a probation card in defendant’s wallet. Deputy asked and learned that defendant was on probation for “cocaine.” Deputy then asked for permission to search defendant. Deputy and defendant got in an altercation during the search, and defendant was charged with felony obstruction. Defendant moved in limine to prohibit mention that he was on probation and the basis therefor. Held, trial court properly denied the motion in limine. “Here, as noted by the trial court, ‘the conduct of the officer flows very directly from the statements made during the consensual encounter[,]’ and were therefore part of the res gestae.” Also admissible as part of circumstances of arrest. Roberts v. State, 282 Ga. 548, 651 S.E.2d 689 (October 9, 2007). At defendant’s murder trial, trial court properly admitted evidence that defendant “was a drug dealer and gave police a false name when questioned after the shooting. In Johnson v. State, 264 Ga. 456(1) (448 S.E.2d 177) (1994), this Court held that a statement ‘as to what