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battery conviction vacated and remanded for new trial. Trial court abused its discretion in excluding prior difficulties evidence proffered by defendant to show that victim was the aggressor. Husband (defendant) and wife fought; evidence was uncontroverted that wife hit husband first, but she “testified that she ‘had to hit him’ to express her frustration at his act of dropping [their special needs child and that] such hitting was ‘normal’ for their relationship.” Husband testified that wife “started throwing punches in his face and hit him with a pail.” He sought to introduce evidence of wife’s “history of unprovoked violence” toward him, which the trial court denied. Held, this was an abuse of discretion; contrary to trial court’s ruling, the evidence was not substantially more prejudicial than probative, especially considering wife’s admission “at trial that she had hit Agyemang in the past after disagreements in their marriage and that she was the initial aggressor during the present incident. In light of such evidence, it would not be unfairly prejudicial to allow the jury to hear of specific acts of violence she committed towards her husband in the past. … Further, the evidence of prior difficulties was probative for its impeachment value. [Wife] testified that although she first hit Agyemang, that such hitting was not forceful.” Powell v. State, 286 Ga. 14, 685 S.E.2d 79 (October 19, 2009). At defendant’s trial for murder of his wife, trial court properly excluded evidence of victim’s alleged extramarital affairs. “Contrary to defendant's assertion, evidence of a prior extramarital affair does not constitute evidence of a previous difficulty or encounter. See McWilliams v. State, 280 Ga. 724, 725(3) (632 S.E.2d 127) (2006). Moreover, unless a defendant can show that he killed his wife under a violent, sudden impulse of passion due to his wife's adultery, the evidence is irrelevant and inadmissible. Compare Culmer v. State, 282 Ga. 330, 335(4) (647 S.E.2d 30) (2007) (adulterous conduct can give rise to sufficient provocation if it occurred immediately prior to killing in such a way as to incite sudden irresistible passion) with Burger v. State, 238 Ga. 171 (231 S.E.2d 769) (1977) (adulterous conduct alone does not justify killing of spouse).” Peck v. State, 300 Ga.App. 375, 685 S.E.2d 367 (October 7, 2009). In defendant’s prosecution for sexual exploitation of a child and distributing obscene material, “the trial court erred by admitting evidence of the victim's history of drug use as ‘prior difficulty evidence.’ … Peck correctly points out that the victim's history of drug use was not relevant to prove a material issue in dispute and failed to show any prior difficulties between Peck and the victim.” Smart v. State, 277 Ga. 111, 587 S.E.2d 6 (September 22, 2003). Prior offenses of victim involving third parties, not defendant, not admissible where not “violent” – here, no evidence that prior conviction for public indecency “caused any physical harm.” See also “ Bennett v. State, 265 Ga. 38, 40-41 (453 S.E.2d 458) (1995) (victim’s conviction for burglary not admissible as prior act of violence against a third-party because there was no evidence of physical harm); Lowe v. State, 267 Ga. 410, 414 (478 S.E.2d 762) (1996) (threats of harm do not qualify as prior act of violence against a third party); Smith v. State, 270 Ga. 240, 243 (510 S.E.2d 1) (1998) (carrying sawed off shotgun and soliciting aid to commit a crime are not prior acts of violence).” Graham v. State, 274 Ga. 696, 558 S.E.2d 395 (January 14, 2002). Defendant was convicted of the malice murder of the victim. Defendant contended that he acted in self-defense, based on prior acts and threats of the victim towards him and his family. This night, when the defendant was using a pay phone, he saw victim stop his car nearby and approach him. Fearing the victim had a gun, defendant testified that he (defendant) fired at victim twice. Victim reached defendant, they struggled for defendant’s gun, the gun discharged, and victim was killed. At trial, defendant sought to present evidence of victim’s prior violent acts against 1) defendant, and 2) others. Held, evidence of prior difficulties between defendant and victim are admissible as evidence of the relationship between the two and may show the defendant’s motive, intent and bent of mind in committing the act for which he is accused; however, victim's prior acts of violence against third parties are not admissible unless a prima facie case of justification is first made out by showing that in the instant matter, the victim was the aggressor, the victim assaulted the defendant, and the defendant was honestly trying to defend himself. Defendant’s testimony here as outlined above did not establish a prima facie case that victim was the aggressor; thus, trial court properly excluded evidence of victim’s prior acts of violence against others. Accord, Robinson v. State , 277 Ga. 75, 586 S.E.2d 313 (September 15, 2003). Carter v. State, 270 Ga. 637, 514 S.E.2d 19 (March 8, 1999). No abuse of discretion in exclusion of prior difficulties evidence proffered by defendant (alleging that victim fired a gun at defendant less than two months prior to defendant shooting and killing victim). Defense at trial was insanity, not self-defense. Defendant “contends that this evidence was relevant to show his emotional state and thus to support his insanity defense. Considering the limited relevance of this evidence to [the] defense that he did not have the ability to distinguish between right and wrong on the day of the shooting, and considering the prejudicial impact of this evidence on Marie’s character, we cannot conclude that the trial court abused its discretion in excluding this evidence. See Carr v. State, 267 Ga. 701, 706-707(4), 482 S.E.2d 314