With no explanation, chose the best option from "A", "B", "C" or "D". to instruct the jury that defendant had been acquitted on prior charges stemming from the narcotics transactions); United States v. Smith, 145 F.3d 458 (1st Cir.1998)(Dowling does not require an acquittal instruction when evidence of acquitted conduct is introduced); United States v. Tirrell, 120 F.3d 670 (7th Cir.1997)(Dowling does not require that jury be told of acquittal; therefore, appellate court would afford substantia] deference to trial court’s decision that prior acquittals were irrelevant); State v. Bell, 164 N.C.App. 83, 594 S.E.2d 824 (2004)(evidence of subsequent assault committed by defendant was admissible under Dowling, and trial court was not required to admit evidence of defendant’s acquittal on assault charge); but see Hess v. State, 20 P.3d 1121 (Alaska 2001) (<HOLDING>). Two reasons have been cited to explain why

A: holding in a criminal context that the probative value of evidence of other crimes is not substantially outweighed by danger of unfair prejudice where the court will give a limiting jury charge
B: holding without deciding applicability of dowling that evidence of acquittal should have been admitted where it had substantial probative value regarding issues other than defendants innocence of prior charge and its exclusion hampered defendants ability to respond to sexual assault victims propensity testimony
C: holding that a prior conviction may be a bad act for purposes of rule 404b if substantial evidence supports a finding that defendant committed both acts and the probative value is not limited solely to tending to establish the defendants propensity to commit a crime such as the crime charged
D: holding evidence of sexual assault relevant to show defendants motive in kidnapping victim
B.