How have the courts treated a prosecutor's criticism of defense counsel's argument in a civil case?

To be sure, the prosecutor used blunt, colloquial language. He summarized the defense theory as being that the girls and their mother were lying and had engaged in a conspiracy to defraud both the court and immigration officials. He cautioned the jury that defense counsel "doesn't even have a little bit of evidence of any impropriety other than what's come out of his mouth." He characterized this theory as "garbage." He described defense counsel's attempts to convince the jury to accept the theory in terms of defense counsel "selling" and the jury "buying" it. But the prosecutor's characterization and critique of defense counsel's argument was fair comment and his choice of words was not improper. (See People v. Huggins (2006) 38 Cal.4th 175, 207 [no misconduct where "[t]he prosecutor simply used colorful language to permissibly criticize counsel's tactical approach"].)