In State v. Cofield, 127 N.J. 328, 605 A.2d 230 (1992), the Court stressed the need for a careful weighing and balancing of the probative value of "other crimes" evidence against its prejudicial effect. To be admissible, the Court held, such evidence must be offered for a proper purpose, must be relevant, must have probative value that is not substantially outweighed by the danger of unfair prejudice to the defendant, and must be coupled with a limiting instruction. A proper application of those rules balances the State's interest in presenting the evidence of "other crimes or wrongs" against the possibility of unfair prejudice to the defendant.Id. at 334, 605 A.2d 230. The Court also acknowledged the difficulty of that weighing and balancing process: The admissibility of uncharged misconduct has been described as "the single most important issue in contemporary criminal evidence law" . . . . The analogous Federal Rule of Evidence 404(b) has "generated more published opinions than any other subsection of the Federal Rules and errors in the introduction of uncharged misconduct are the most frequent basis for reversal in criminal cases." Id. at 335, 605 A.2d 230. The Court dealt with "other crimes" evidence under N.J.R.E. 404(b). It held that one seeking the admission of such evidence must satisfy four requirements: (1) the evidence of the other crime must be relevant to a material issue in the case being tried; (2) the evidence must be similar in kind and reasonably close in time to the offense charged; (3) the evidence of the other crime must be clear and convincing; (4) the probative value of the evidence must not be outweighed by its apparent prejudice.