The following excerpt is from U.S. v. Butterbaugh, 46 F.3d 1146 (9th Cir. 1994):
The prosecution may have been unnecessarily personal in its response to the defense's charge that the government's calculations were incorrect, but the rebuttal generally challenged perceived misrepresentations of the record in defense attorney's closing argument, a subject within the scope of permissible argument. See United States v. Gwaltney, 790 F.2d 1378, 1385 (9th Cir.1986). If the rebuttal overstepped proper bounds, it did not rise to the level of plain error necessary to justify reversal. See United States v. Falsia, 724 F.2d 1339, 1342 (9th Cir.1983).
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