In Dennis v. State, 178 S.W.3d 172 (Tex. App.--Houston 1st Dist. 2005, pet. ref'd), a jury convicted Dennis of sexually assaulting F.S. See Dennis, 178 S.W.3d at 175. Dennis argued that "F.S. fabricated the sexual assault allegations because she was angry at him for taking away her cellular telephone and for disciplining her because of her poor grades in school" and solicited testimony that "F.S. was angry when he took her cellular telephone from her and that children may fabricate allegations out of anger." Id. at 178. The State sought to introduce M.W.'s testimony to rebut this theory. See id. at 176. Before M.W.'s testimony was introduced, the trial court gave an oral instruction limiting the jury's consideration of M.W's testimony to "rebut the defensive theory of fabrication, if any, in connection with this offense, if any, alleged against him in the indictment and for no other purpose." Id. at 176-77. The First Court held that "M.W.'s testimony is relevant rebuttal evidence showing that under similar circumstances, Dennis sexually assaulted another child." Id. at 178. The extraneous and charged offenses were similar enough "to allow use of the extraneous-offense evidence to rebut Dennis's theory that F.S. framed him." Id. at 179.