In a second-degree murder trial, what is the defense counsel's strategy in the closing argument?

request an instruction that does not advance the defense's theory of the case. (People v. Wader (1993) 5 Cal.4th 610, 643 [defense counsel could have had a rational tactical purpose for not requesting an instruction that was inconsistent with the defense's theory of the case that the defendant did not intend to kill the victim].) Here, defense counsel's closing argument showed that she was focused on convincing the jury to rely on a heat of passion theory to reduce murder to voluntary manslaughter. Additional jury instructions on provocation as a basis for second degree murder as set forth in CALCRIM No. 522 would have been contrary to that strategy because the expanded instruction would have focused the jury on using the heat of passion theory to reach a verdict of second degree murder rather than to reach a verdict of voluntary manslaughter.