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Counsel has an absolute right to argue to a jury in a jury trial. The trial judge has the discretion to control the duration and the manner of the argument to the jury. Other limitations placed on counsel's argument include (1) Any comments made by counsel must be based on the evidence presented at trial. Counsel may not argue facts not in evidence. (2) The argument that counsel uses must be within the limits of the substantive law that governs the controversy. (3) The argument may not appeal to the passions of the jurors.

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