The following excerpt is from U.S. v. Means, 999 F.2d 545 (9th Cir. 1993):
Viewed in context, the prosecutor's remarks were not elegant, but neither were they so egregious as to constitute plain error. It is permissible for a prosecutor to argue that the defense is lying as long as the argument is a comment on the evidence. See United States v. Laurins, 857 F.2d 529, 539 (9th Cir.1988), cert. denied, 492 U.S. 906 (1989).
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