The following excerpt is from U.S. v. Lafradez, 980 F.2d 739 (9th Cir. 1992):
We review decisions to admit evidence of other crimes or bad acts for abuse of discretion. United States v. Spillone, 879 F.2d 514, 518 (9th Cir.1989), cert. denied, 111 S.Ct. 210 (1990). A four-part test provides the rule of decision: (1) there must be sufficient evidence that the defendant committed the act; (2) the act must be probative of a material fact in this case; (3) the act must not be too remote in time; and (4) if admitted to prove intent, it must be similar to the offense charged. Id. at 518-20.
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