Franco-Delgado

MEMORANDUM ***

Defendant argues that by stating the words “hide” and “trick,” the prosecutor intentionally disparaged the defense counsel in order to characterize him as a liar in the crucial, final moments of trial. However, the context in which this analogy was made renders its use a permissible attempt to point out the defense counsel’s tactics. See United States v. Santiago, 46 F.3d 885, 892 (9th Cir.1995) (finding comments about defense tactics, including *724 statement that counsel tried “to sully and dirty up two ... government ] witnesses,” permissible).

Defendant also contends that the prosecution misstated the law regarding reasonable doubt by incorrectly implying that Defendant’s sole presence in a vehicle containing illicit drugs raised a presumption of guilt. The prosecution’s comments in no way reference a presumption; the statements correctly illustrate evidence sufficient to warrant an inference of knowledge. See United States v. Hursh, 217 F.3d 761, 767 (9th Cir.2000) (“[I]t is well-settled that mere possession of a substantial quantity of narcotics is sufficient evidence to support a finding that a defendant knowingly possessed the narcotics.” (internal…