What is the standard of summation in a personal injury case?

An attorney's summation to the jury generally "'must be based solely upon those matters of fact of which evidence has already been introduced or of which no evidence need ever be introduced because of their notoriety as judicially noticed facts.' [Citations.] He may state matters not in evidence that are common knowledge, or are illustrations drawn from common experience, history, or literature. [Citations.]" (People v. Love (1961) 56 Cal.2d 720, 730; accord, People v. West, supra, 139 Cal.App.3d at p. 611.) However, "'he may not dwell on the particular facts of unrelated, unsubstantiated cases.'" (People v. West, supra, at p. 611.)