Forrester v. State, 315 Ga. App. 1

Forrester was convicted by a jury of three counts of forgery in the first degree and one count of theft by deception.
Evidence showed she leased a rental house in Flowery Branch, signed a lease, and paid with three money orders totaling $2,760 and later attempted additional payment with a $2,000 check that was not cashed.
The money orders were later dishonored as counterfeit and police were contacted.
The State relied on bank records and stamps marking counterfeitness as proof of forgery, and on venue for the theft charge.
The trial court admitted the counterfeit stamps as business records and allowed a signed acknowledgment to go with the jury; the defense objected to the continuing witness rule.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Venue for forgery in Hall County established?	Forrester	Forrester	Yes; Hall County venue was established.
Whether Forrester lacked authority to possess/deliver counterfeit money orders	Forrester lacked authority	Counterfeit status unexplained; no authority shown	Convictions reversed for forgery (lack of authority not proven).
Admissibility of counterfeit stamps as business records and Confrontation Clause impact	Stamps admissible as business records	Stamp conclusions by third party improper	Reversed forgery convictions due to improper admission and lack of foundation.
Whether signed acknowledgment accompanying jury deliberations was proper under continuing witness rule	Should have been excluded	Not a confession; original documentary evidence	Admission proper; no error.

Bowen v. State, 304 Ga.App. 819 (2010) (venue proof and county as essential element in criminal venue)
Ross v. State, 298 Ga.App. 525 (2009) (business records foundation and admissibility of copies with stamps)
Miller v. State, 266 Ga. 850 (1996) (confrontation clause limits on hearsay with third-party conclusions)
Kesler v. State, 249 Ga. 462 (1982) (hearsay and business records limitations)
Davis v. State, 285 Ga. 343 (2009) (continuing witness rule)