California, United States of America
The following excerpt is from People v. Njoku, C082166 (Cal. App. 2018):
prosecutor's comment was aimed solely at the persuasive force of defense counsel's closing argument, and not at counsel personally"], disapproved on another ground by People v. Doolin (2009) 45 Cal.4th 390, 421, fn. 22.) There is no reasonable likelihood that jurors misunderstood the prosecutor's argument.
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