What is the test for establishing that a defendant committed a criminal offence against an employee who witnessed the crime?

"New York", United States of America

The following excerpt is from People v. Rosenburg, 203 Misc. 22 (N.Y. Dist. Ct. 1952):

With respect to the other employee witnesses, it would permit the People to prove other distinct offenses in order to raise an inference that the defendant had committed the crime in question or had a tendency to commit such crimes. (People v. Grout, 174 App. Div. 608.) This the law does not permit.

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