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27. PURPOSE – OPPORTUNITY Amey v. State, 331 Ga.App. 244, 770 S.E.2d 321 (March 18, 2015). Armed robbery and related convictions reversed; trial court erred by admitting evidence of prior armed robbery as similar transaction under 2013 Evidence Code. Evidence was offered to prove identity, motive and opportunity. Opportunity. “ Professor Milich characterizes opportunity as ‘probably the most rarely used purpose of those listed in [Rule] 404(b). It admits evidence that relates to the defendant's specific ability or wherewithal to commit the crime charged.’ (Emphasis supplied.) Milich § 11:13 at 318. In this case, the prior attempted robbery has no connection to the charged robbery that took place almost three years later; it therefore did not provide evidence of Amey's specific ability to commit the charged crime. Compare United States v. DeJohn, 638 F.2d 1048, 1051–1052(II) (7 th Cir., 1980) (defendant's prior bad act of taking a check from an internal YMCA mailbox provided evidence of his opportunity to take different checks from the same area that he later attempted to cash). While the State presented evidence showing that Amey was living in close proximity to the location of the charged offense at the time it was committed, it did not present corresponding evidence of Amey's proximity in connection with the prior robbery at the time it was committed almost three years before. Consequently, opportunity was not a proper ground for admission of the prior robbery evidence.” 28. REMOTENESS OF OFFENSES/LAPSE OF TIME Dunham v. State, 315 Ga.App. 901, 729 S.E.2d 45 (May 17, 2012). Aggravated battery conviction affirmed; similar transaction evidence wasn’t too remote in time despite 15-year lapse. Both batteries involved severe bites, drawing blood and inflicting visible injuries. “In both incidents Dunham used the tools at hand — an axe in 1995 and a metal bar he picked up in this case — and involved multiple other parties.” Rogers v. State, 290 Ga. 401, 721 S.E.2d 864 (January 23, 2012). Murder and related convictions affirmed; similar transaction evidence was properly admitted. Contrary to defendant’s argument, length of time between similar transaction and trial isn’t the proper measure of remoteness; rather, “the relevant measure has virtually always been the lapse of time between the prior similar offense and commission of the offense for which the defendant is being tried. See Henry v. State, 278 Ga. 554, 556(3) (604 S.E.2d 469) (2004); Evans v. State, 287 Ga.App. 74, 76(2) (651 S.E.2d 363) (2007); Alexander Scherr, Green Ga. Law of Evidence § 71.4 (6 th ed.). … Moreover, because Appellant spent most of the time between the assault on [similar transaction victim] Keys and the trial in this case in prison, the interval is acceptable even if measured to the time of trial. … ‘“(T)he lapse of time generally goes to the weight and credibility of the evidence, not to its admissibility. (Cits.)”’ Hinton v. State, [280 Ga. 811, 817(6) (631 S.E.2d 365) (2006)]. ‘This has been especially true in cases where,[ as here,] there has been a continuous course of criminal conduct or the defendant has been incarcerated for some period between acts. [Cits.]’ Pareja v. State, 286 Ga. 117, 120 (686 S.E.2d 232) (2009).” Hall v. State, 287 Ga. 755, 699 S.E.2d 321 (September 20, 2010). In defendant’s prosecution for malice murder of her husband, “the 15 and 13 year lapses of time between the prior incidents and the crimes at issue here do not require exclusion of the evidence. [Cits.] Given that the similar transaction evidence reflects appellant's behavior towards prior spouses, we conclude that any prejudice from the age of these prior incidents was outweighed by the probative value of the evidence under the particular facts of this case and the purpose for which the similar transactions were offered.” Accord, Neal v. State , 290 Ga. 563, 722 S.E.2d 765 (February 27, 2012) (13-year lapse, citing Hall ); Wheeler v. State , 290 Ga. 817, 725 S.E.2d 580 (March 23, 2012) (in murder prosecution, 18-30 year lapse between prior events, citing Neal ); Day v. State , 315 Ga.App. 824, 728 S.E.2d 337 (May 10, 2012); Reeves v. State , 294 Ga. 673, 755 S.E.2d 695 (March 3, 2014). Pareja v State, 286 Ga. 117, 686 S.E.2d 232 (November 2, 2009). Affirming Court of Appeals at 295 Ga.App. 871 (673 S.E.2d 343) (2009), in defendant’s prosecution for child molestation, no abuse of discretion where trial court admitted evidence of prior molestation committed 26 years earlier . “As a general rule, ‘the lapse of time generally goes to the weight and credibility of the evidence, not to its admissibility. [Cits.]’ Swanson v. State, 269 Ga.App. 826 (605 S.E.2d 425) (2004). Nonetheless, where similar transactions are particularly remote because they were committed decades in the past, ‘the passage of time is one of the more important factors to weigh in considering the admissibility of the evidence in question, [although] it is not wholly determinative.’ (Citation omitted; emphasis supplied.) Mullins v. State, 269 Ga. 157, 158(2) (496 S.E.2d 252) (1998). This factor takes on heightened significance when the similar transaction evidence is comprised of alleged acts for which there is no prior record of their occurrence,” that is, no criminal prosecution. Distinguishing Gilstrap v. State, 261 Ga. 798(1) (410 S.E.2d 423) (1991) (31-year old similar transaction), and Slakman v. State, 272 Ga. 662(4) (533 S.E.2d 383) (2000) (30-year old similar transaction). “In both Gilstrap and Slakman, the prejudice to the defendant caused by defending against alleged crimes occurring in the far distant past outweighed any