The following excerpt is from United States v. Hilts, 17-2998-cr (2nd Cir. 2018):
The first statement, "viewed against the entire argument to the jury," United States v. Sheehan, 838 F.3d 109, 128 (2d Cir. 2016), was not personal vouching for witnesses, but another attempt to focus the jury on the evidence. Rivera, 971 F.2d at 883. Viewed in context, the statement follows a summary of the evidence that undermines the defense theoryincluding extensive strip searches and ample corroborating video recordings. The use of "I submit" is not improper where the defense has "specifically attacked [a government witness's] credibility and veracity in [its] summations." United States v. Eltayib, 88 F.3d 157, 173 (2d Cir. 1996).
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