15.011 2/1/1989 Reckless Driving (misdemeanor), Ak. Stat. § 28.35.030 6/7/2005 For the reasons set forth below, the Court should enter an Order excluding the introduction of any evidence or inquiry related to these prior convictions or arrests. ARGUMENT I. Legal Standard Rule 609(a) of the Federal Rules of Criminal Procedure states: For the purpose of attacking the character for truthfulness of a witness, (1) evidence that a witness other than an accused has been convicted of a crime shall be admitted, subject to Rule 403, if the crime was punishable by death or imprisonment in excess of one year under the Case 1:08-cr-00231-EGS Document 21 Filed 08/14/2008 Page 2 of 11 -3- law under which the witness was convicted, and evidence that an accused has been convicted of such a crime shall be admitted if the court determines that the probative value of admitting this evidence outweighs its prejudicial effect to the accused; and (2) evidence that any witness has been convicted of a crime shall be admitted regardless of the punishment, if it readi