The judge has the discretion to deny a party the right to recall a witness who testified previously if the testimony to be given by the witness would be repetitious of the witness' earlier testimony. Farley v. State, 314 Ga. App. 660 (2012).
It is within the judge's discretionary power to reopen a case and permit the introduction of further evidence even though the testimony is not in rebuttal of evidence offered by defendant. Davenport v. State, 308 Ga. App. 140 (2011); Riley v. State, 311 Ga. App. 445 (2011). The judge can even re-open the evidence after the jury has started deliberations. Adorno v. State, 314 Ga. App. 509 (2012); State v. Roberts, 247 Ga. 456 (1981). The failure to include in the record a proffer of the testimony for which a party seeks to have the evidence re-opened prevents
an appeals court from considering the issue.
Danenberg v. State, 291 Ga. 439 (2012).