California, United States of America
The following excerpt is from People v. Washington, A126548 (Cal. App. 2012):
Defendant argues that no evidence was presented regarding "common defense strategies" and, therefore, this argument was improper. In addition, defendant contends that this argument impugned the integrity and honesty of defense counsel and the defense. (People v. Jones (1997) 15 Cal.4th 119, 168, overruled on other grounds in Hill, supra, 17 Cal.4th at p. 823, fn. 1).
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