What is the standard of conduct in a closing statement at a personal injury trial?

...counsel should ask every question she thinks will help her client’s case and make every argument in her client’s favour that is legitimately open on the evidence. In contrast to an opening statement, which should be purely informational, a closing jury submission is argument (see [Brophy v. Hutchinson, 2003 BCCA 21, 48 B.C.L.R. (4th) 349], para. 41) and the object of argument is persuasion. Thus, counsel should state her client’s positions as forcefully as the evidence reasonably permits and without fear of offending the sensibilities of witnesses and other parties. Drama and pathos are permissible, though their use may be risky before modern sophisticated juries who may resent theatrical attempts to divert them from a reasoned analysis. Competent counsel will marshal the evidence in as favourable a light as possible for her client, analyze the evidence, relate the evidence to the law, and suggest inferences while leaving it to the jury to draw the desired inferences. She will not make irrelevant and prejudicial appeals designed to provoke hostility to or prejudice the jury against her opponent.