The following excerpt is from U.S. v. New, 911 F.2d 739 (9th Cir. 1990):
We review the district court's decision to admit evidence of other crimes for an abuse of discretion. United States v. Conners, 825 F.2d 1384, 1390 (9th Cir.1987). New argues that the evidence did not meet the fourth requirement for admission under the test set forth in United States v. Bailleaux, 685 F.2d 1105 (9th Cir.1982): "the prior criminal conduct must be introduced to prove an element of the charged offense that is a material issue in the case." Id. at 1110.
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