California, United States of America
The following excerpt is from People v. Jackson, F064563 (Cal. App. 2013):
The prosecutor has the right to open the closing argument and to close it by rebuttal argument. ( 1093, subd. (e).)2 Further, the prosecutor has the right to waive the initial closing argument while maintaining the right to give a rebuttal argument. (People v. Martin (1919) 44 Cal.App. 45, 47.)
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