The following excerpt is from Mark v. Curry, No. CIV S-09-CV-1260 CHS P (E.D. Cal. 2011):
F.2d 1411, 1417 (9th Cir. 1989). "[Prosecutors] may strike 'hard blows,' based upon the testimony and its inferences, although they may not, of course, employ argument which could fairly be characterized as foul or unfair." United States v. Gorostiza, 468 F.2d 915, 916 (9th Cir. 1972).
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