Dissenting opinion by
Justice KELLER.I respectfully dissent from the majority opinion and vote to reverse Appellant’s convictions and remand this indictment to the McCreary Circuit Court for a new trial. In my view, Appellant was substantially prejudiced by the erroneous admission of: (1) April Sexton’s (“Sexton”) irrelevant testimony as to Jean Ferrier’s (“Ferrier”) and Crystal Conaster’s (“Co-naster”) fears of Appellant; and (2) both Jeannette Musgrove’s (“Musgrove”) and Gary Roberts’s (“Roberts”) testimony as to uncharged prior bad acts — specifically, previous occasions upon which Appellant allegedly discharged firearms in Ferrier’s direction — which the Commonwealth introduced in violation of a trial court order prohibiting it from introducing such evidence because it had not provided the reasonable pretrial notice required by KRE 404(c). Additionally, although I agree with the majority’s bottom-line conclusion that the inadmissible “investigative hearsay” that was erroneously introduced during Detective McKinney’s testimony was harmless in this case, I write separately as to that allegation of error to caution the bench and bar to avoid the introduction of such hearsay evidence in future cases.
I. VICTIMS’ STATES OF MIND
A common thread appears to exist when interpreting whether hearsay statements about the murder victim’s fear of a defendant falls under the state-of-mind exception, KRE 803(3), or whether the hearsay statements are relevant. Where a victim’s state of mind is not at issue, the testimony is not allowed to be admitted into evidence. Specifically, where a defendant did not claim self-defense, an accidental death, or suicide, such statements usually have “little relevancy except toward providing a strong inference of appellant’s intent, actions, or culpability.”1
Because Appellant’s alibi defense did not put the victims’ states of mind at issue, it was not relevant that Sexton, Conaster, and Ferrier circled the parking lot at the dance hall “because they was afraid that [Appellant] was going to be there,”2 or that Ferrier had expressly identified her fear as the reason for the decision to circle the lot.3 Although the majority opinion suggests that this evidence was relevant *549because it invited speculation as to “why [the victims] would have such fear[,]”4 the fact that such evidence might lead to conjecture that the Appellant was a “bad guy” whom persons might justifiably fear — i.e., to infer evidence of bad character that is prohibited by KRE 404(a) — is precisely the reason that such evidence is inadmissible. Although this evidence, standing alone, might not warrant reversal of Appellant’s convictions, it was clearly prejudicial, and, in combination with the erroneous introduction of prior bad acts evidence, it deprived Appellant of his right to a fair trial.
II. REASONABLE NOTICE OF PRIOR BAD ACTS EVIDENCE
KRE 404(c) provides:
Notice requirement. In a criminal case, if the prosecution intends to introduce evidence pursuant to subsection (b) of this rule as a part of its case in chief, it shall give reasonable pretrial notice to the defendant of its intention to offer such evidence. Upon failure of the prosecution to give such notice the court may exclude the evidence offered under subsection (b) or for good cause shown may excuse the failure to give such notice and grant the defendant a continuance or such other remedy as is necessary to avoid unfair prejudice caused by such failure.5
KRE 404(c)’s notice requirement is designed “to assure that the defense is given an adequate opportunity to investigate the factual basis for evidence of [prior bad acts] and to deal with the dangers of unreliability and prejudice.”6 And, regardless of whether proffered evidence could otherwise be admitted under KRE 404(b), the KRE 404(c) notice requirement operates as a separate hurdle that protects the defendant’s right to a fair trial:
[T]he integrity of the trial is jeopardized when previously unknown witnesses appear at the eleventh hour with evidence of uncharged collateral crimes. Even in cases where evidence of prior uncharged criminal activity between the defendant and third persons is admissible, fundamental fairness dictates, and we hold, that the defendant is entitled to be informed of the names of the non-complaining witnesses and the nature of their allegations so far in advance of trial as to permit a reasonable time for investigation and preparation. See KRE 404(c).7
Approximately eighteen (18) months before the trial in this case, Appellant filed a motion asking the trial court “to enter an order that the Commonwealth provide sufficient notice to the defense of any evidence it intends to present relating to alleged ‘bad acts’, ‘uncharged misconduct’, prior convictions (if any), and similar evidence.” A week later, after a hearing at which the Commonwealth acknowledged that it would disclose any such evidence that it intended to introduce, the trial court entered a discovery order that provided, in part, that “[t]he Commonwealth shall disclose any and all evidence it intends to present in this case which is in the nature of ‘bad act’ evidence, uncharged misconduct evidence, and evidence of a similar nature.”
*550Eleven (11) months later, Appellant filed a motion to compel discovery in which Appellant’s trial counsel indicated that the Commonwealth had not disclosed its intention to introduce any such evidence. Accordingly, Appellant also filed a motion that asked the trial court to enter an order precluding the Commonwealth “from introducing any KRE 404(b) (prior bad act) evidence during both the guilt phase and penalty phase portions (if any), of the trial in this matter ... because it has not provided the defendant with notice of its intention to present [the] evidence and any attempt to do so now would be untimely and severely prejudice the defendant.” There is no indication in the record that the Commonwealth ever notified the defense that it intended to introduce KRE 404(b) evidence, and Appellant’s motion was resolved by an agreed order of record that provided: “By agreement of the parties, IT IS HEREBY ORDERED that the Commonwealth will present no evidence pursuant to KRE 404(b), relating to John Roscoe Garland, during the guilt phase portion of the trial in the above captioned case.”
At trial, however, during the Commonwealth’s culpability phase case-in-chief, two (2) different witnesses, Musgrove and Roberts, testified to paradigmatic KRE 404(b) evidence8 — ie., Appellant’s prior acts of violence towards Ferrier on occasions when Appellant allegedly fired shots at Ferrier’s home. Appellant argues that the introduction of this evidence was erroneous because the Commonwealth had not complied with KRE 404(c) by providing reasonable pretrial notice of its intention to introduce the evidence. The majority opinion first holds that the error was not properly preserved for our review because there was no contemporaneous objection at trial on KRE 404(c) grounds. Then, the majority concludes that the prior bad acts evidence was properly admitted at trial because it satisfied KRE 404(b)(l)’s relevancy requirements. I disagree with the majority’s analysis.
First, the Kentucky Rules of Evidence compel a different conclusion regarding preservation. KRE 103(d) provides:
Motions in limine. A party may move the court for a ruling in advance of trial on the admission or exclusion of evidence. The court may rule on such a motion in advance of trial or may defer a decision on admissibility until the evidence is offered at trial. A motion in limine resolved by order of record is sufficient to preserve error for appellate review. Nothing in this rule precludes the court from reconsidering at trial any ruling made on a motion in limine.9
KRE 103(d)’s motion in limine rule promotes trial efficiency by, among other things, eliminating the need for unnecessary trial objections when the trial court has already ruled upon an evidentiary admissibility issue:
A formal mechanism for obtaining advance rulings on the admissibility of evidence would seem to serve at least the following ends: (i) facilitate trial preparations by providing information pertinent to strategic decisions; (ii) reduce distractions during trial and provide for a smoother presentation of evidence to the jury; (iii) enhance the possibility of settlement of disputes without trial; (iv) provide some additional insulation of the *551jury from prejudicial inadmissible evidence; and (v) improve the conditions under which the trial judge must address evidence issues by reducing the need for hasty decisions during the heat of trial. The purpose of subdivision (d) is to acknowledge the value of motions in limine and to encourage a more widespread use of the device in the courts of Kentucky.10
The Commentary to KRE 103 makes it clear that, if a motion in limine has been resolved by an order of record, no trial objection is necessary to preserve an allegation of error raised in the motion in limine:
In some jurisdictions the case law leaves doubt about the extent to which motions in limine may be used to preserve errors for review. As a result litigants are forced to renew objections or offers of proof at trial even though brought to the attention of the judge and opposing counsel prior to trial. Subdivision (d) eliminates this doubt by providing that motions in limine resolved by order of record are sufficient to preserve errors for appellate review. By requiring that such motions be resolved by “order of record,” an adequate record for the appeals court should be assured.11
Accordingly, Appellant’s allegation of error was preserved for our review by the trial court’s agreed order prohibiting the Commonwealth from introducing KRE 404(b) evidence at the culpability phase of Appellant’s trial.12
The majority acknowledges KRE 103(d), but instead of applying the language of the rule, relies upon Tucker v. Commonwealth 13 and concludes that the allegation of error was unpreserved because Appellant did not object to the testimony at trial. I question the majority’s reliance on Tucker and observe that both of the cases that Tucker cited as support for this questionable proposition predate our adoption of the Kentucky Rules of Evidence. Moreover, the leading authorities on Kentucky evidence law have questioned the Tucker holding and characterized it as “plainly at odds with KRE [103(d) ]”14 and “in direct conflict with the language of KRE 103(d)!”15 Thus, to the extent that Tucker stands for a proposition that is directly contrary to the language of KRE 103(d), the opinion should be overruled. However, additional language in Tucker— specifically the two (2) sentences that appear just before the language quoted in today’s majority opinion — render Tucker’s holding somewhat opaque and suggest that, in context, Tucker may have turned upon differences between Tucker’s argument on appeal and the objection he raised in his motion in limine: “An objection made prior to trial will not be treated in *552the appellate court as raising any question for review which is not strictly within the scope of the objection as made, both as to the matter objected to and as to the grounds of the objection. It must appear that the question was fairly brought to the attention of the trial court.”16 Although I would agree that a motion in limine would not preserve an objection if the trial court could not have anticipated that the specific evidence in question fell within the scope of the objection raised in the motion in limine,17 the evidence in this case as to the alleged prior shooting episodes was quintessential KRE 404(b) evidence — simply stated, the evidence could not have been admitted under any rule other than KRE 404(b) — and Appellant’s motion in limine preserved his claim for appellate review.
The majority’s conclusion that the evidence introduced would have satisfied KRE 404(b)(l)’s relevancy requirements is a non sequitur to the issue in this case, which is whether the evidence should have been excluded because of the Commonwealth’s failure to provide the notice required by KRE 404(c). Unlike other cases where the record has demonstrated that the defendant had actual notice of the Commonwealth’s intention to introduce KRE 404(b) evidence,18 there is no suggestion in this record that the Commonwealth ever gave notice of its intention to introduce this evidence and, in fact, the record reflects that the Commonwealth affirmatively agreed that it would not introduce any' KRE 404(b) evidence during the culpability phase of Appellant’s trial. Although KRE 103(d) permits a trial court to reconsider its ruling in limine, the Commonwealth did not ask the trial court to do so before it introduced the evidence. Thus, the KRE 404(b) evidence was erroneously admitted in violation of the trial court’s order sustaining the Appellant’s pretrial KRE 404(c) reasonable notice objection, and the pretrial ruling removed any need for a contemporaneous objection. Although this evidence would likely have been admissible if the Commonwealth had provided the defendant with reasonable notice of its intention to introduce it, the Commonwealth’s failure to provide reasonable notice made its introduction improper, and the nature of the evidence belies any suggestion that its erroneous admission could be harmless.
III. INVESTIGATIVE HEARSAY
It was hoped that Sanborn v. Commonwealth19 was the death-knell for the so-called “investigative hearsay exception” to the hearsay rule.20 I fear that today’s *553majority opinion’s analysis of the investigative hearsay issues presented here will either resuscitate the “exception” or, by suggesting that subsequent testimony from the declarant “erases” such errors, otherwise pave the way for the introduction of hearsay evidence.
Accordingly, as to the “investigative hearsay” introduced during Detective McKinney’s testimony, I wish to emphasize two (2) things. First, Detective McKinney should not have been permitted to testify as to out-of-court statements made by Clayton Stephens (“Stephens”) and Chuck Lanham (“Lanham”). Although the majority opinion describes Detective McKinney’s testimony as to Stephens’s out-of-court statements as “technically hearsay,” it was unquestionably error to permit Detective McKinney to “give a preview of’ Stephens’s testimony by relating Stephens’s previous out-of-court statements. Moreover, a prosecutor’s expectation that a declarant will testify later in the trial is wholly irrelevant to the admissibility of hearsay evidence as to the declarant’s statements, and Stephens’s subsequent in-court testimony could not “erase” the previous error. Similarly, Detective McKinney’s testimony as to Lanham’s out-of-court statements was inadmissible, and the fact that Lan-ham’s conclusion was supported by an entirely different expert, Dwight Deskins, did not eliminate the erroneously-admitted hearsay evidence.
Second, although I agree with the majority’s conclusion that the improper hearsay evidence was harmless in this case, I do so because, in my view, Appellant was not prejudiced by the substance of the erroneously admitted hearsay testimony. I wish to emphasize, however, that, in many cases, the erroneous admission of “investigative hearsay” will not be rendered harmless merely because the declar-ant subsequently testifies at the trial. Here, Detective McKinney’s testimony improperly bolstered Stephens’s testimony regarding Appellant’s son’s purchase of a .357 Magnum handgun and erroneously supplied an additional expert’s opinion that the handgun purchased from Stephens did not fire the rounds that killed the victims in this ease. Because the “issue” of whether this handgun was used in the commission of this offense was not seriously disputed and, in my estimation, was largely inconsequential to the resolution of this case, I agree with the majority that the erroneous introduction of this hearsay evidence was harmless on these facts. However, in a case where the improperly admitted hearsay testimony bolsters or adds testimony on an issue of more substance, investigative hearsay of this type may warrant a new trial.
COOPER and STUMBO, JJ., join.
. Partin v. Commonwealth, Ky., 918 S.W.2d 219, 222 (1996) (citations omitted and emphasis added). I observe that Partin, which the majority cites in support of its claim that "[gjenerally, when a victim’s state of mind is not at issue, the hearsay testimony is not admissible,” Garland v. Commonwealth, Ky., 127 S.W.3d 529, 540, 2003 WL 22429532 *5 (2003) (emphasis added) does not contain the language of equivocation ("generally”) that is added by today's majority opinion.
. This was indirect hearsay evidence. See Sherley v. Commonwealth, Ky., 889 S.W.2d 794, 801-802 (1994) (Leibson, J., concurring).
. Bray v. Commonwealth, Ky., 68 S.W.3d 375, 381-2 (2002).
. Garland v. Commonwealth, supra note 1 at 539, at *5 (quoting Partin v. Commonwealth, supra note 1).
. KRE 404(c).
. Commentary to KRE 404, Kentucky Evidence Rules Study Commission, Final Draft (1989).
. Gray v. Commonwealth, Ky., 843 S.W.2d 895, 897 (1992).
. See Moseley v. Commonwealth, Ky., 960 S.W.2d 460, 461 (1998); Parker v. Commonwealth, Ky., 952 S.W.2d 209, 214 (1997); Smith v. Commonwealth, Ky., 904 S.W.2d 220, 223-224 (1995).
. KRE 103(d) (emphasis added).
. Commentary to KRE 103, Kentucky Evidence Rules Study Commission, Final Draft (1989).
. Id.
. See Prater v. Cabinet for Human Resources, Ky., 954 S.W.2d 954, 959 (1997). Cf. O’Bryan v. Hedgespeth, Ky., 892 S.W.2d 571, 574-5 (1995) (holding that motion in limine preserved error for appeal and that the objecting party did not waive the allegation of error when it subsequently introduced the evidence to which it had objected).
. Ky., 916 S.W.2d 181 (1996).
. Robert G. Lawson, KENTUCKY EVIDENCE LAW HANDBOOK, § 1.'10(V) (3d. ed. Michie 1993, 2000 supp.).
. Richard H. Underwood and Glen Weissen-berger, KENTUCKY EVIDENCE: 2004 COURTROOM MANUAL, at 11 (Anderson Publishing Co.2003).
. Tucker v. Commonwealth, supra note 13 at 183 (emphasis added).
. See Commentary to KRE 103, Kentucky Evidence Rules Study Commission, Final Draft (1989) (“It should be noted that a motion in limine would not be sufficient to preserve errors for appellate review unless it provided the trial court with the type of information which would be required to preserve errors raised at trial[.]”); Sherley v. Commonwealth, supra note 2 at 803 (Leibson, J., concurring) ("We should not extend the reach of protection by motion in limine to cases where we cannot infer the trial court knew evidence excluded by motion in limine was being introduced anyway. Present circumstances called for defense counsel to speak up if he wished to preserve error.”).
. See Walker v. Commonwealth, Ky., 52 S.W.3d 533, 538 (2001); Tamme v. Commonwealth, Ky., 973 S.W.2d 13, 31-32 (1998); Bowling v. Commonwealth, Ky., 942 S.W.2d 293, 300 (1997).
. Ky., 754 S.W.2d 534 (1988).
. Id. at 541 (“Perhaps it would help to state forcefully at the outset that hearsay is no less hearsay because a police officer supplies the evidence. In short, there is no separate rule, as such, which is an investigative hearsay exception to the hearsay rule.”)