IIRC, EN-EL3e have an extra connector for reporting battery power status and hole that D70 will simply ignore them. But, the battery for D70 can not fit to D200 because no hole on the battery. Somebody already trying to make a hole on battery to fit it on D200. It can fit, but it doesn't work since no extra connector on the battery for reporting battery power status.
Regards,
Arto.