ten-day rule in Georgia

2017Cockrell v. State, 281 Ga. 536, 539 (3) ( 640 SE2d 262 ) (2007) (Lab report that was not provided to defense counsel more than ten days before trial, but was provided as soon as the State received it on the third day of trial, was nevertheless admissible, as “the severe sanction of exclusion of evidence [for violation of the ten-day rule] applies only where there has been a showing of bad faith by the State and prejudice to the defense”) (emphasis in original).

2017Cockrell v. State, 281 Ga. 536, 539 (3) ( 640 SE2d 262 ) (2007) (Lab report that was not provided to defense counsel more than ten days before trial, but was provided as soon as the State received it on the third day of trial, was nevertheless admissible, as “the severe sanction of exclusion of evidence [for violation of the ten-day rule] applies only where there has been a showing of bad faith by the State and prejudice to the defense”) (emphasis in original).

2022For these reasons, we see no need to employ a special test or framework different than that which generally applies to any claim of good cause made in support of a motion for protective order under 4 See, e.g., Moody, 308 Ga. at 80 (2) (upholding trial court’s finding that plaintiffs did not establish good cause entitling it to a protective order because, among other things, the finding was supported by discovery responses); DeVaughn v. State, 296 Ga. 475, 478 (3) (769 SE2d 70) (2015) (trial court “did not abuse its discretion in ruling that the State had established good cause for allowing an

2022For these reasons, we see no need to employ a special test or framework different than that which generally applies to any claim of good cause made in support of a motion for protective order under 4 See, e.g., Moody, 308 Ga. at 80 (2) (upholding trial court’s finding that plaintiffs did not establish good cause entitling it to a protective order because, among other things, the finding was supported by discovery responses); DeVaughn v. State, 296 Ga. 475, 478 (3) (769 SE2d 70) (2015) (trial court “did not abuse its discretion in ruling that the State had established good cause for allowing an

2017“Failure to make a meritless objection cannot be evidence of ineffective assistance.” Hayes v. State, 262 Ga. 881, 884 (3) (c) ( 426 SE2d 886 ) (1993).

2017“Failure to make a meritless objection cannot be evidence of ineffective assistance.” Hayes v. State, 262 Ga. 881, 884 (3) (c) ( 426 SE2d 886 ) (1993).

2015See Puga-Cerantes v. State, 281 Ga. 78, 80 ( 635 SE2d 118 ) (2006) (finding that good cause was shown where a witness fled prior to trial and was not located again until the first day of trial).

2015See Puga-Cerantes v. State, 281 Ga. 78, 80 ( 635 SE2d 118 ) (2006) (finding that good cause was shown where a witness fled prior to trial and was not located again until the first day of trial).

2022For these reasons, we see no need to employ a special test or framework different than that which generally applies to any claim of good cause made in support of a motion for protective order under 4 See, e.g., Moody, 308 Ga. at 80 (2) (upholding trial court’s finding that plaintiffs did not establish good cause entitling it to a protective order because, among other things, the finding was supported by discovery responses); DeVaughn v. State, 296 Ga. 475, 478 (3) (769 SE2d 70) (2015) (trial court “did not abuse its discretion in ruling that the State had established good cause for allowing an

2022For these reasons, we see no need to employ a special test or framework different than that which generally applies to any claim of good cause made in support of a motion for protective order under 4 See, e.g., Moody, 308 Ga. at 80 (2) (upholding trial court’s finding that plaintiffs did not establish good cause entitling it to a protective order because, among other things, the finding was supported by discovery responses); DeVaughn v. State, 296 Ga. 475, 478 (3) (769 SE2d 70) (2015) (trial court “did not abuse its discretion in ruling that the State had established good cause for allowing an

2022For these reasons, we see no need to employ a special test or framework different than that which generally applies to any claim of good cause made in support of a motion for protective order under 4 See, e.g., Moody, 308 Ga. at 80 (2) (upholding trial court’s finding that plaintiffs did not establish good cause entitling it to a protective order because, among other things, the finding was supported by discovery responses); DeVaughn v. State, 296 Ga. 475, 478 (3) (769 SE2d 70) (2015) (trial court “did not abuse its discretion in ruling that the State had established good cause for allowing an

2022For these reasons, we see no need to employ a special test or 4 See, e.g., Moody, 308 Ga. at 80 (2) (upholding trial court’s finding that plaintiffs did not establish good cause entitling them to a protective order because, among other things, the finding was supported by discovery responses); DeVaughn v. State, 296 Ga. 475, 478 (3) ( 769 SE2d 70 ) (2015) (trial court “did not abuse its discretion in ruling that the State had established good cause for allowing an exception to the ten-day rule” in OCGA § 17-16-8 (a) that requires disclosure of a witness at least ten days before trial where, af

2022For these reasons, we see no need to employ a special test or framework different than that which generally applies to any claim of good cause made in support of a motion for protective order under 4 See, e.g., Moody, 308 Ga. at 80 (2) (upholding trial court’s finding that plaintiffs did not establish good cause entitling it to a protective order because, among other things, the finding was supported by discovery responses); DeVaughn v. State, 296 Ga. 475, 478 (3) (769 SE2d 70) (2015) (trial court “did not abuse its discretion in ruling that the State had established good cause for allowing an

2022For these reasons, we see no need to employ a special test or framework different than that which generally applies to any claim of good cause made in support of a motion for protective order under 4 See, e.g., Moody, 308 Ga. at 80 (2) (upholding trial court’s finding that plaintiffs did not establish good cause entitling it to a protective order because, among other things, the finding was supported by discovery responses); DeVaughn v. State, 296 Ga. 475, 478 (3) (769 SE2d 70) (2015) (trial court “did not abuse its discretion in ruling that the State had established good cause for allowing an

2022For these reasons, we see no need to employ a special test or framework different than that which generally applies to any claim of good cause made in support of a motion for protective order under 4 See, e.g., Moody, 308 Ga. at 80 (2) (upholding trial court’s finding that plaintiffs did not establish good cause entitling it to a protective order because, among other things, the finding was supported by discovery responses); DeVaughn v. State, 296 Ga. 475, 478 (3) (769 SE2d 70) (2015) (trial court “did not abuse its discretion in ruling that the State had established good cause for allowing an

2022For these reasons, we see no need to employ a special test or framework different than that which generally applies to any claim of good cause made in support of a motion for protective order under 4 See, e.g., Moody, 308 Ga. at 80 (2) (upholding trial court’s finding that plaintiffs did not establish good cause entitling it to a protective order because, among other things, the finding was supported by discovery responses); DeVaughn v. State, 296 Ga. 475, 478 (3) (769 SE2d 70) (2015) (trial court “did not abuse its discretion in ruling that the State had established good cause for allowing an

1997However, in Love v. State, 214 Ga. App. 351, 352 (1) ( 447 SE2d 698 ) (1994), we clarified such holding so that, when Williams has been complied with in a USCR 31.3 (B) hearing, the trial court has made a determination of admissibility, and a limiting instruction specifies the legitimate purpose or purposes for which the jury may consider the prior similar crime, under such circumstances there is no error in a broader jury charge which encompasses multi-purposes.

1997However, in Love v. State, 214 Ga. App. 351, 352 (1) ( 447 SE2d 698 ) (1994), we clarified such holding so that, when Williams has been complied with in a USCR 31.3 (B) hearing, the trial court has made a determination of admissibility, and a limiting instruction specifies the legitimate purpose or purposes for which the jury may consider the prior similar crime, under such circumstances there is no error in a broader jury charge which encompasses multi-purposes.

1997This Court is aware that in Stephan v. State, 205 Ga. App. 241, 243-244 (2) ( 422 SE2d 25 ) (1992), we held that where the prosecutor introduces a similar transaction at trial in violation of the ten-day rule under Uniform Superior Court Rule 31.1, fails to state the purpose for which the evidence was admitted and the trial court instructs the jury on all permissible purposes, such combination of factors requires reversal.

1997This Court is aware that in Stephan v. State, 205 Ga. App. 241, 243-244 (2) ( 422 SE2d 25 ) (1992), we held that where the prosecutor introduces a similar transaction at trial in violation of the ten-day rule under Uniform Superior Court Rule 31.1, fails to state the purpose for which the evidence was admitted and the trial court instructs the jury on all permissible purposes, such combination of factors requires reversal.

1995Thaxton v. State, 260 Ga. 141, 144 (6) ( 390 SE2d 841 ) (1990).

1995Thaxton v. State, 260 Ga. 141, 144 (6) ( 390 SE2d 841 ) (1990).