The legal principle of relevance

United States v. Bell, 516 F.3d 432, 441 (6th Cir. 2008) (reversing convictions for possession of marijuana and cocaine base with intent to distribute and remanding for new trial because, even though the trial court correctly concluded that there was sufficient evidence to show that accused had committed...Evidence of another crime, wrong, or act is admissible if there is sufficient evidence to support a finding by a reasonable juror that the other crime, wrong, or act occurred. Clear and convincing evidence is unnecessary; "sufficient" means only that there must be enough evidence to make the other crime, wrong, or act relevant.

United States v. Arnold, 467 F.3d 880, 884-885 (5th Cir. 2006) (upholding trial court's admission into evidence of accused's prior arrest and conviction for possession of crack because accused made his intent and knowledge the critical issues at trial and his "prior convictions were expressly offered,...Evidence of a criminal or wrongful act apart from the act that at issue at trial Is not barred by the prohibition against circumstantial use of character if intent, knowledge, mistake, or accident is a legally-material factual issue, the opposing party suggests the non-existence of knowledge or urges mistake or accident as a defense, and evidence of another crime, wrong, or act is offered to prove the knowledge or the absence of mistake or accident by a criminal defendant or other person.

Malta v. Schul Merich Carillons, Inc., 952 F.2d 1320, 1343 (Fed. Cir. 1991) (citing Wigmore on Evidence ? 1(b), at p. 7 (P. Tillers rev. 1983) for ?truism that attorney argument is not evidence?).Statements and argument by lawyers in litigation while functioning as counsel are not evidence.