conduct). Lacking explicit precedent in this state, we turn to other jurisdictions to seek guidance. In doing so, we find many other jurisdictions, particularly federal courts, including the Fourth Circuit Court of Appeals, have addressed the issue of the admissibility during the trial of threats against a witness made by the defendant. The federal court cases generally conclude such threats indicate the defendant’s “consciousness of guilt” and are therefore admissible pursuant to Rule 404(b) of the Federal Rules of Evidence. See U.S. v. Van Metre, 150 F.3d 339, 352 (4th Cir.1998); U.S. v. Guerrero-Cortez, 110 F.3d 647, 652 (8th Cir.1997) (acknowledging that “[a]n effort to intimidate a witness tends to show consciousness of guilt”); U.S. v. Gatto, 995 F.2d 449, 454-55 (3d Cir.1993) (<HOLDING>); U.S. v. Maddox, 944 F.2d 1223, 1230 (6th
holding that evidence of threats or intimidation of a witness is admissible under rule 404b to show consciousness of guilt holding evidence of prior witness intimidation admissible to show criminal intent and guilty conscience holding defendants false exculpatory statements admissible to show consciousness of guilt holding that rule 404b evidence is admissible in rebuttal holding criminal acts designed to reduce the likelihood of conviction including threats against witnesses are admissible under rule 404b as showing consciousness of guilt