As was correctly stated in Jackson: Slakman v. State, 272 Ga. 662, 667 ( 533 SE2d 383) (2000); Paul S. Milich, Georgia Rules of Evidence § 17.3, p. 349 (2d ed. 2002).Momon v. State, 249 Ga. 865, 867 ( 294 SE2d 482) (1982); Teague v. State, 252 Ga. 534, 534-536 ( 314 SE2d 910) (1984); Slakman, 272 Ga. at 667; Vega v. State, 285 Ga. 32 ( 673 SE2d 223) (2009).

We find no reversible error. Howell cites Slakman v. State, 272 Ga. 662, 533 S.E.2d 383 (2000), for the proposition that a court reporter should not be allowed to testify as a witness in any proceeding in which she is also serving as the official transcriber of witness testimony because the jury would automatically perceive her as a credible witness. However, our Supreme Court's holding in Slakman did not paint this issue with such a broad brush.

Although the trial court correctly set out these legal principles governing the admission of hearsay statements under the residual exception, the State contends that the court abused its discretion because, in ruling on whether Dixon's statements were admissible under the exception, it improperly relied on Georgia cases applying the former Evidence Code's "necessity exception" to the hearsay rule. Specifically, the State notes that the trial court cited Slakman v. State , 272 Ga. 662, 533 S.E.2d 383 (2000), and Navarrete v. State , 283 Ga. 156, 656 S.E.2d 814 (2008), both of which addressed the former necessity exception.

However, when, as here, the testimony concerning prior difficulties is hearsay, it is not admissible unless it meets an exception to the rule against the admission of hearsay. Slakman v. State, 272 Ga. 662(3) 533 S.E.2d 383) (2000). For hearsay to be admitted under the "necessity" exception, the proponent must establish that the testimony is necessary and that there are particular guarantees of trustworthiness connected to the declarant's statements.

It is uncontroverted that the transcript correctly reports what DeToma said at the plea hearing. Compare Slakman v. State, 272 Ga. 662, 665(2), 533 S.E.2d 383 (2000). What DeToma contends is that the recording would allow the trial court to discern nuances in his plea hearing testimony so as to aid that court in evaluating his claim that he did not voluntarily plead guilty, and also this Court in reviewing the trial court's decision.

It is uncontroverted that the transcript correctly reports what DeToma said at the plea hearing. Compare Slakman v. State, 272 Ga. 662, 665(2), 533 S.E.2d 383 (2000). What DeToma contends is that the recording would allow the trial court to discern nuances in his plea hearing testimony so as to aid that court in evaluating his claim that he did not voluntarily plead guilty, and also this Court in reviewing the trial court's decision.

See also Hall, supra, 287 Ga. at 757(2), 699 S.E.2d 321 (evidence of 13– and 15–year–old similar transactions admissible); Phillips v. State, 287 Ga. 560(4), 697 S.E.2d 818 (2010) (evidence of 18–year–old similar transaction admissible); Wright v. State, 259 Ga.App. 74(1), 576 S.E.2d 64 (2003) (34–year–old similar transaction evidence admissible); Bryson v. State, 210 Ga.App. 642(2), 437 S.E.2d 352 (1993) (31–year–old similar transaction evidence admissible). Compare Slakman v. State, 272 Ga. 662, 669(4), 533 S.E.2d 383 (2000) (absence of evidence that defendant abused second wife created “significant break in the ‘course of criminal conduct’ ” affecting admissibility of similar transaction evidence). (b) Appellant also contends the court erred by admitting the testimony of Jose Cruz–Hernandez, appellant's cellmate while awaiting trial in this case, regarding an incident in which appellant stabbed Cruz–Hernandezin the neck with a pencil.

See Pareja v. State, 286 Ga. 117, 119-121 ( 686 SE2d 232) (2009). Compare Slakman v. State, 272 Ga. 662 (4) ( 533 SE2d 383) (2000) (event more than 30 years old may be too remote to be admitted as evidence of a similar transaction). Given that the similar transaction evidence reflects appellant's behavior towards prior spouses, we conclude that any prejudice from the age of these prior incidents was outweighed by the probative value of the evidence under the particular facts of this case and the purpose for which the similar transactions were offered.

Id. at 799 (1) (b). Similarly, in Slakman v. State, 272 Ga. 662 (4) ( 533 SE2d 383) (2000), we found that, based upon the facts in that case, 30-year-old similar transaction evidence was inadmissible. In both Gilstrap and Slakman, the prejudice to the defendant caused by defending against alleged crimes occurring in the far distant past outweighed any probative value the alleged crimes may have in a prosecution for a current crime. It must be noted, however, that neither Gilstrap nor Slakman creates a bright-line rule that similar transactions more than 30 years old are automatically inadmissible.

As Scott's remaining enumerations of error could occur on re-trial, we will address them. See Slakman v. State, 272 Ga. 662, 666 (2) ( 533 SE2d 383) (2000). 4. On direct examination, the State asked West if, when she first became romantically involved with Scott, she knew that he was married, and she responded that she did not. The State asked if she had ever talked to Scott about that, and Scott objected, challenging the relevancy of the questioning.