The best argument for the defendant would likely be:
3) Your honor, we acknowledge that there is some probative value to Sam's prior convictions, but the substantial danger of unfair prejudice is too high to overcome. As such, we are asking that this court preclude the government from admitting Sam's prior convictions.
This argument acknowledges the potential relevance of Sam's prior convictions but argues that admitting them would lead to unfair prejudice against the defendant. By addressing both sides of the issue and advocating for the exclusion of the prior convictions based on the risk of prejudice, this argument presents a balanced and persuasive case for the defendant.