Summation:

► SUMMATION: "In summation, 'counsel is to be afforded "the widest latitude by way of comment, denunciation or appeal in advocating his cause"' (People v Ashwal, 39 NY2d 105, 109 [1976], quoting Williams v Brooklyn E.R. Co., 126 NY 96, 103 [1891]), though within limits that are principally those of relevance (see Ashwal, 39 NY2d at 109-110)" (People v Santiago, 22 NY3d 740, 750 [2014]). Said another way, in Ashwal (39 NY2d 105) the Court of Appeals "explained that it is 'fundamental' that counsel must stay within 'the four corners of the evidence' during summation and that the prosecutor 'may not refer to matters not in evidence or call upon the jury to draw conclusions which are not fairly inferable from the evidence' (id. at 109 [citations omitted]; see also CJI2d[NY] Pre-Summation Instructions ['(s)ummations provide each lawyer an opportunity to review the evidence and submit for (the jury's) consideration the facts, inferences, and conclusions that they contend may...