probative value outweighs its prejudicial effect.” Id. at 124-25. The court, however, did not articulate a precise alternative standard applicable in the context of intrafamilial sexual battery cases for determining the sufficiency of similarity between the collateral acts and the charged crime. It is noteworthy that in support of the general strict standard of relevance the Heuring court cited two Florida cases, Thompson v. State, 494 So.2d 203 (Fla.1986), and Drake v. State, 400 So.2d 1217 (Fla.1981), and a California case, People v. Haston, 69 Cal.2d 233, 70 Cal.Rptr. 419, 444 P.2d 91 (1968). All three cases dealt with circumstances where similar fact evidence was introduced to establish the identity of the perpetrator by showing modus operandi. See Thompson, 494 So.2d at 204 (<HOLDING>); Drake, 400 So.2d at 1219 (stating that the
holding that collateral crime evidence used to identify defendant as perpetrator was improperly admitted where the facts did not have some special character and were not so unusual as to point to the defendant holding improperly admitted evidence was harmless error given the overwhelming evidence of guilt holding that even if the statements were improperly admitted any error was harmless since there was overwhelming evidence connecting the defendant to the conspiracy holding improperly admitted testimony was cumulative to the other properly admitted evidence and was therefore harmless holding evidence not to be material within the meaning of brady when the evidence did not eliminate the defendant as the perpetrator