What is the proper extent of vigorous advocacy in a civil case?

We have read the argument in its entirety and in context and have concluded that it was entirely within the proper bounds of vigorous advocacy (see People v. Bandhauer, 66 Cal.2d 524, 58 Cal.Rptr. 332, 426 P.2d 900) and consisted of simply an appraisal of the evidence which was in the record. The statements were not expressions of personal belief. In fact the prosecutor told the jury that 'I might state that when I indicate to you that under what theory the various defendants are guilty as charged, these are the reasonable inferences that should be drawn from the evidence that I've reviewed for you and that you've heard in the court.'