The following excerpt is from U.S. v. Cardascia, 951 F.2d 474 (2nd Cir. 1991):
Aside from controlling the order of appearances in the closing arguments, inasmuch as the prosecution must go first, Rule 29.1 does not limit the discretion of the trial judge whose obligation it is to ensure a fair and orderly procedure in the closing arguments to the jury. See United States v. Gleason, 616 F.2d 2, 26 (2d Cir.1979) (defendants offered opportunity for surrebuttal in face of eleventh hour surprise). In light of the blameshifting and peripheral inconsistencies in defense strategies that prevailed at trial, defense rebuttals were well within the ambit of a trial court's broad discretion in such matters.
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