See OCGA § 5–7–1 et seq. If the motion for new trial is denied, the judgment from which the State now seeks to appeal will stand, and the notice of appeal previously filed by the State then will ripen. See, e.g., Heard v. State, 274 Ga. 196, 197(1), n. 2, 552 S.E.2d 818 (2001); Miller v. State, 273 Ga. 831, n. 1, 546 S.E.2d 524 (2001); Hann v. State, 292 Ga.App. 719, 720(1), 665 S.E.2d 731 (2008); Hearst v. State, 212 Ga.App. 492, 494(2), 441 S.E.2d 914 (1994); O'Kelly v. State, 196 Ga.App. 860(1), 397 S.E.2d 197 (1990); Hope v. State, 193 Ga.App. 202, 203(1)(a), 387 S.E.2d 414 (1989). In the meantime, however, this case properly remains within the jurisdiction of the trial court.

See Osborne, supra. 6. Osborne, supra at 189–190 (criminal trespass conviction reversed where there was no evidence that when a police officer working security at a movie theater gave notice to the defendant to not return to the premises, he was acting as the authorized representative of the theater owner; no one from the theater testified at trial; court noted that notice given the following night however, was sufficient, when the manager had signed a criminal trespass warning forbidding the defendant from returning to the theater and the warning was served upon the defendant by a security officer); Jackson v. State, 242 Ga.App. 113, 114, 528 S.E.2d 864 (2000) (criminal trespass conviction reversed because there was no evidence that patrolman was acting as the authorized representative of the owner or rightful occupant of the apartment when patrolman warned defendant to stay away from the apartment); Hope v. State, 193 Ga.App. 202, 204(1)(b), 387 S.E.2d 414 (1989) (criminal trespass conviction affirmed where city owned the airport and defendant argued that the police officer who prohibited his return to the airport was not the owner, rightful occupant, or authorized representative of the owner or rightful occupant; we held that a police officer, whether possessing power of arrest or not, is a representative of the city of which he is a sworn officer while protecting the property of that city and is authorized to bar him from property); Rayburn, supra at 657–658(2), 300 S.E.2d 499 (criminal trespass conviction affirmed where security officer, as an authorized representative of the owner of a bus station, warned defendant to stay off the premises); see also W.L.N. v. State, 170 Ga.App. 689, 690(1), 318 S.E.2d 80 (1984) (affirming adjudication of delinquency for violation of OCGA § 16–7–21(b)(2) where appellant remained on premises upon being given notice by an apartment complex maintenance supervisor, as an authorized

For the reasons that follow we affirm. Hope v. State, 239 Ga. App. 331 ( 521 S.E.2d 372) (1999); Hope v. State, 226 Ga. App. 392 ( 486 S.E.2d 658) (1997); Hope v. State, 193 Ga. App. 202 ( 387 S.E.2d 414) (1989). The evidence at trial showed that Williams was arrested and convicted numerous times in the past for criminal trespass after repeatedly offering limousine services without a license to passengers at the airport and being asked not to return.

In conjunction with this enumeration of error, Hope argues that City of Atlanta police officers had no authority to arrest him for these offenses. This Court rejected a similar contention in Hope v. State, 193 Ga. App. 202, 203 (1), 204 (b) ( 387 S.E.2d 414) (1989), in which Hope argued Atlanta detectives had no authority to arrest him for criminal trespass at the Atlanta airport. See also State v. Giangregorio, 181 Ga. App. 324, 325 ( 352 S.E.2d 193) (1986) (physical precedent only).

In this case, Elrod's motion for new trial was not timely filed; this is not a case where Elrod's notice of appeal was premature, but later ripened when the denial of his motion for new trial was entered. Compare Hope v. State, 193 Ga. App. 202 203 (1) (a) ( 387 S.E.2d 414) (1989). Hence, the order denying the motion for new trial is a nullity, and Elrod's third notice of appeal, filed on January 25, 1996 and based on this order, is also a nullity.

Such a premature notice of appeal ripens upon the filing of the order and there is no jurisdictional impediment to our review. Hope v. State, 193 Ga. App. 202, 203 (1a) ( 387 S.E.2d 414) (1989). (b) The allegations of ineffective assistance are that trial counsel failed to file a motion to suppress, did not subpoena witnesses for Hearst, allowed Hearst's character to be put into evidence without objection, and did not object to the "expert testimony" of the officer working the police dog.

This is true even if the arrest is outside his jurisdiction. State v. Giangregorio, 181 Ga. App. 324, 325 ( 352 S.E.2d 193) (1986); see Hope v. State, 193 Ga. App. 202, 204 (1) ( 387 S.E.2d 414) (1989). Even treating Hitchcock as a private citizen, he was authorized to make a citizen's arrest for the simple battery committed in his presence.

Atkinson v. State, 170 Ga. App. 260 (1) ( 316 S.E.2d 592) (1984). Hope v. State, 193 Ga. App. 202, 203 (1) ( 387 S.E.2d 414) (1989). The second notice of appeal is a legal nullity.

Under Georgia law, a sheriff's deputy is a law-enforcement or peace officer, O.C.G.A. §§ 15-16-1 et seq., and thus may make arrests outside of his or her county of residence. O.C.G.A. § 17-4-25; Nyane v. State, 306 Ga. App. 591, 594, 703 S.E.2d 53, 57 (2010); Wells, 206 Ga. App. at 515, 426 S.E.2d at 233 ("A law enforcement officer may make an arrest without a warrant for an offense committed in his presence. . . . This is true even if the arrest is outside his jurisdiction.") (citing O.C.G.A. § 17-4-20; State v. Giangregorio, 181 Ga. App. 324, 325, 352 S.E.2d 193, 194 (1986); Hope v. State, 193 Ga. App. 202, 204, 387 S.E.2d 414, 416 (1989)). Cf. State v. Heredia, 252 Ga. App. 89, 91, 555 S.E.2d 91, 93 (2001) (describing law enforcement's authority to arrest for traffic violation outside of jurisdiction pursuant to O.C.G.A. §§ 17-4-23(a), 40-13-30).