In Matter of George L., 85 NY2d 295 (1995) the Court of Appeals set forth a non-exhaustive list of ways in which the prosecution might meet its burden of proving a defendant dangerous under CPL 330.20. Such evidence might include "proof of a history of prior relapses into violent behavior, substance abuse or dangerous activities upon release or termination of psychiatric treatment", evidence of the necessity of continued medication, a history of prior noncompliance with medication or threats of future noncompliance. The Court held that "dependence on such factors as these clearly evidencing a defendant's threat to himself or society is warranted to justify the significant limitations on an insanity acquitee's liberty interest which accompany secure confinement." Id. at 308. Moreover, while not dispositive in itself, a court may consider "the nature and recency of the criminal act [for which the detainee was acquitted] in deciding whether a defendant remains dangerous at the time of his commitment." Matter of George L., supra, at 306. Thus, "because persons acquitted of a crime by reason of mental disease or defect have demonstrated past antisocial behavior, the state is permitted to engage in what may be broadly termed a presumption that the causative mental illness or defect continues beyond the date of the criminal conduct.'" Id., at 306. Indeed, the entry of a plea of not guilty by reason of mental disease or defect for a crime of violence is itself "certainly evidence that [an insanity acquittee] remains a danger to society." Id., at 307. The Court of Appeals noted: "The recent commission of a violent act significantly increases the probability that an individual will commit further such acts in the future. This judgment is not simply a popular notion; the clinical consensus is that a history of violent behavior in an individual is the single best predictor of future violence." (85 NY2d at 306, quoting Ingber, Note, Rules for an Exceptional Class: The Commitment and Release of Persons Acquitted of Violent Offenses by Reason of Insanity, 57 NYU L Rev 281, 295-296 [1982].) In that case, the determination of whether the defendant suffered from a dangerous mental disorder took place a mere 17 months after the defendant attempted to murder his father. Whereas, in the instant matter, the crimes defendant committed took place approximately 12 years ago with no further acts of violence since that time.