In People v. Robertson (2012) 208 Cal.App.4th 965, the defendant was charged with kidnap for rape and related offenses. The evidence at trial showed that in 2009, the defendant lured his victim into a garage, locked it, and sexually assaulted her. (Id. at pp. 972-973.) The court also admitted evidence under Evidence Code section 1108 that approximately 34 years earlier, in 1974, the defendant committed a rape and kidnapping. (People v. Robertson, supra, 208 Cal.App.4th at pp. 987-988, 992.) During that incident, the defendant picked up a hitchhiker, drove her to an isolated field, and raped her. (Ibid.) In affirming the admission of the 1974 incident, the appellate court rejected a contention that the prior incident was too remote, stating that "'"substantial similarities between the prior and the charged offenses balance out the remoteness of the prior offenses."'" (Id. at p. 992.) Applying that standard, the appellate court determined that the similarities between the 1974 and 2009 crimes were sufficient to support the trial court's ruling. (Id. at pp. 992-994.)