Evidence of an accused's generosity towards non-complainant witnesses is irrelevant to charges of entering agreements for sexual services where the non-complainants did not depose to any such agreements, even if the accused treated them similarly to the victims in other respects. A trial judge must require the Crown to identify uncharged acts evidence and its relevance before trial, and must give adequate directions including anti-substitution warnings and standard of proof directions. Drug trafficking counts not laid as Giretti counts must not be left to the jury on a basis permitting conviction on any one of multiple unspecified acts.
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