Is a prosecutor permitted to make disparaging remarks in summation about the integrity of defense counsel?

carefully constructed . . . before the event." Farhane, 634 F.3d at 167 (internal quotation marks omitted) (second omission in original). "A prosecutor is not precluded from vigorous advocacy, or the use of colorful adjectives, in summation." United States v. Rivera, 971 F.2d 876, 884 (2d Cir. 1992).

Similarly, in the context of a summation focused on the evidence, and on demonstrating for the jury why the prosecution established proof beyond a reasonable doubt, we do not deem a prosecutor's fleeting remarks to the effect that defense counsel was attempting to distract the jury to be improper. Here, the prosecutor twice cautioned the jury that defense counsel was trying "to take your eyes off the ball." This is a far cry, indeed, from the sort of sustained attack on the integrity of defense counsel that we held to be reversible error in United States v. Friedman, 909 F.2d 705, 708 (2d Cir. 1990) (reversing a conviction where, inter alia, the prosecution stated in summation that "some people [defense counsel] would have you pull down the wool over your eyes and forget all that, because while some people . . . go out and investigate drug dealers and prosecute drug dealers and try to see them brought to justice, there are others who defend them, try to get them off, perhaps even for high fees") (omission in original). See also United States v. Millar, 79 F.3d 338, 343-344 (2d Cir. 1996) (refusing to reverse a conviction where the prosecution stated in summation that the defense case was "hog wash" and a "smoke screen," and suggested that

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