☢ test - Í

Here, the victim's testimony about Jones' prior suicide attempt was part of the res gestae of the prior difficulties evidence and thus was relevant and admissible, even if it incidentally placed Jones' character in issue. See id.” Accord, Parker v. State , 296 Ga. 199, 766 S.E.2d 60 (November 17, 2014) (evidence “showed a history of domestic violence between appellant and the [murder] victim.”); Lopez v. State , 332 Ga.App. 518, 773 S.E.2d 787 (June 16, 2015) (“the victim's testimony about [intervening in Lopez's fights with others] was part of the res gestae of the prior difficulties evidence and thus was relevant and admissible, even if it incidentally placed [Lopez's] character in issue.”). Taylor v. State, 328 Ga.App. 551, 759 S.E.2d 892 (July 9, 2014). Kidnapping and related convictions affirmed; under pre- 2013 Evidence code, no error in admitting evidence of defendant’s prior act of breaking into victim’s home, two years earlier. “[E]vidence of a defendant's prior acts toward the victim, ‘be it a prior assault, a quarrel, or a threat, are evidence of the relationship between the victim and the defendant and may show the defendant's motive, intent, and bent of mind in committing the act against the victim which results in the charges for which the defendant is being prosecuted.’ Thompson v. State, 295 Ga. 96, 102(3)(b) 757 S.E.2d 846 (April 22, 2014) (citation and punctuation omitted). [ FN: This case, like Thompson, was tried under Georgia's old Evidence Code. Under the new Evidence Code, which applies to trials beginning on or after January 1, 2013, the admissibility of this sort of ‘[e]vidence of other crimes, wrongs, or acts’ is governed by OCGA § 24–4–404(b). ] Moreover, prior difficulties ‘do not implicate independent acts or occurrences, but are connected acts or occurrences arising from the relationship between the same people[.] ... Thus, the admissibility of evidence of prior difficulties does not depend upon a showing of similarity to the crime for which the accused is being tried.’ Dixon v. State, 275 Ga. 232, 232–233(2) (564 S.E.2d 198) (2002) (citation and punctuation omitted).” Dyer v. State, 295 Ga. 173, 758 S.E.2d 301 (May 5, 2014). Felony murder conviction, based on child cruelty, affirmed; evidence of child’s prior injuries was properly admitted as “part of the constellation of injuries considered by the expert medical witnesses in determining whether the baby's condition was the result of accident.” Thomas v. State, 318 Ga.App. 849, 734 S.E.2d 823 (November 28, 2012). Child molestation and related convictions affirmed; no error in admitting evidence of prior difficulties between defendant and victim “in which Thomas fondled the victim's buttocks and the incident involving the pillow fight.” Contrary to defendant’s argument, State wasn’t required to show that the prior incidents were similar to the charged offense. “‘Unlike similar transactions, prior difficulties do not implicate independent acts or occurrences, but are connected acts or occurrences arising from the relationship between the same people involved in the prosecution and are related and connected by such a nexus. Thus, the admissibility of evidence of prior difficulties does not depend upon a showing of similarity to the crime for which the accused is being tried. ’ (Citation and punctuation omitted; emphasis supplied.) Stokes v. State, 289 Ga. 702, 705(3), 715 S.E.2d 81 (2011). Instead, evidence demonstrating prior difficulties between the victim and the accused is ‘generally admissible when the crime was perpetrated against the victim and the evidence demonstrates: (1) the relationship between the defendant and the victim, and (2) the defendant's motive, intent or bent of mind.’ (Footnote omitted.) Tuff [ v. State, 278 Ga. 91, 92(2), 597 S.E.2d 328 (2004)]. Accordingly, the evidence regarding both incidents was admissible, as it showed both Thomas's ‘bent of mind towards and course of conduct with’ the victim. Stokes, supra.” Accord, Tela v. State , 320 Ga.App. 465, 740 S.E.2d 204 (March 18, 2013). Hall v. State, 313 Ga.App. 670, 722 S.E.2d 392 (January 25, 2012). Aggravated assault conviction affirmed; victim’s testimony about defendant’s “excessive alcohol consumption, his treatment for alcohol addiction, his mental health problems, his suicide threat, his possession of the handgun, or the 1995 incident in which he argued with the police and was arrested,” was properly admitted as “part of the res gestae of the numerous incidents of prior difficulties between the parties.” Hernandez v. State, 304 Ga.App. 435, 696 S.E.2d 155 (June 15, 2010). Defendant’s convictions for child molestation affirmed; evidence of acts of domestic violence between defendant and victim’s mother was properly admitted to explain why she waited several months to report the molestation in question. “Hernandez's defense consisted of discrediting [mother] Luz and [victim] K.H. and drawing the inference that Luz had coached K.H. and concocted the incident because Luz wanted a divorce; therefore, the probative value of her testimony concerning fear of physical retribution from Hernandez in the event that she disclosed K.H.'s outcry outweighed the prejudicial effect of placing his character in evidence.” Accord, Brown v. State , 324 Ga.App. 718, 751 S.E.2d 517 (November 14, 2013) (similar facts). Page v. State, 304 Ga.App. 59, 695 S.E.2d 379 (May 12, 2010). Defendant’s conviction for child molestation affirmed, although questions about prior alleged violent behavior toward wife was improper. State contended evidence was admissible to illustrate relationship between parties; “however, the state did not lay a foundation for the witnesses'