ON REHEARING EN BANC
BELSON, Senior Judge:
A jury convicted appellant Thomas E. Harris of distribution of phencyclidine (PCP) and marijuana and of possession with intent to distribute PCP and marijuana in violation of D.C.Code § 38-541(a)(l) (1988). On appeal Harris contends that prosecutorial “misconduct,” primarily in questioning Harris and arguing to the jury regarding “missing witnesses” without first seeking the permission of the trial court, denied Harris a fair trial and substantially prejudiced the jury. At trial Harris did not object to the prosecutor’s conduct. We hold that Harris has failed to demonstrate plain error, and therefore affirm.
I.
Our application of the plain error rule will require an evaluation of the strength of the government’s case. Therefore, we recite the salient facts in some detail. The government’s evidence showed that on August 21, 1984, Officer Byron Wallace, working in plain clothes, was assigned to attempt to purchase illegal drugs. At approximately 1:30 p.m., Wallace drove down the 1800 block of 6th Street, N.W., Washington, D.C., in his personal vehicle. He saw Harris standing on the east side of the street. At that time, Harris was the only person visible in that particular block of 6th Street. Wallace asked him if he had any “loveboat,” a street term for PCP. Harris indicated that he did and told Wallace that it would cost $15.00. After Wallace agreed to the purchase price, Harris removed a tin foil packet from a brown paper bag and gave the packet to Wallace. Wallace checked the contents of the packet and discovered that it contained a brownish weed with a strong chemical odor of PCP. Wallace gave Harris a twenty dollar bill drawn from Metropolitan Police Department funds that had been prerecorded by Officer Dwight Mitchell, Wallace’s partner.1 Harris then handed Wallace five dollars in change. Wallace drove away from [157]*157the area and met Officer Mitchell in the 600 block of 0 Street, N.W. Wallace described Harris to Officer Mitchell as 5'9" to 5'10" tall, approximately 160-170 pounds, wearing green pants, a white pinstriped shirt, and a golf hat.
Officer Mitchell then called for assistance. In addition to Officers Washington and Davis in a uniformed patrol unit, Officer Sovonick and Sergeant Marshall from the vice unit assisted Officer Mitchell. The officers saw Harris in the 1800 block of 6th Street, N.W., and detained him because he matched the lookout description. Officer Mitchell searched where Harris had been standing, “an elevated area higher than the sidewalk,” and found a brown paper bag containing three tinfoil packets of POP.
Officer Washington placed Harris in the prisoner transport cruiser and drove him to 6th and O Streets, N.W., where Wallace positively identified him as the person who had sold him the POP. Two officers then transported Harris to the First District. After Harris got out of the car, Officer Washington searched it and found a folded twenty dollar bill in the back of the transport cruiser where Harris had been seated. Officer Washington testified that according to police department procedures, the transport vehicle must be searched at the beginning of each tour and immediately after a prisoner has been transported to a station. According to Officer Washington, Harris was the only person who had been transported in that vehicle that day. Officer Mitchell compared serial numbers of the twenty dollar bill he had given Wallace to purchase drugs and the twenty dollar bill found in the transport cruiser. The serial numbers matched. The government adduced evidence that the substance recovered included usable amounts of marijuana and POP.
Harris presented the defense of mistaken identity. Harris denied that he had lived at the address written on the arrest report and that he had given the false name, James Harris, to Wallace.2 Harris further testified that on August 21, 1984, between noon and 12:30 p.m., he was in the 1800 block of 6th Street, N.W., playing dice for money with other men in an alley and heard two persons on the street selling drugs. After losing forty-five of the fifty-one dollars he had, he went to a nearby store to get something to drink or change for the telephone. Upon returning from the store, Harris stated, he noticed that everyone who previously had been on the block was gone, except for one person, and that an officer then approached and arrested him. Harris asserted that the officer then searched him, took six dollars from him, and placed him in the back of a police cruiser. He was driven to M Street, taken out of and placed back in the vehicle, and then driven to 13th and H Streets where a white male was also placed in the back seat of the vehicle. Harris stated that next he and the other man were driven to the First District, handcuffed at all times.
During cross-examination, Harris denied selling drugs to Wallace.3 He stated that he arrived at the scene of his later arrest around 12 noon or 12:30. When asked how he had gotten there, he responded that he had walked from 11th & Florida Avenue, volunteering that he had been at the Florida Avenue Grill visiting a friend. He also answered that he had left that place around 11:30 or 11:45. After Harris stated that he still knew that the friend in question, the prosecutor asked Harris, “Did you try to see if you could get that friend to come in here and testify?” Harris answered:
Yes, I did but they don’t want to be— like, okay, I even seen one of the guys that I was gambling with but they don’t want to get caught up in no cases whereas they might can get another charge for testifying or they don't want to be able to like — like no police to see them where [158]*158they could can have to be like harassing them. Because the police harass people.
******
They wouldn’t testify. I'm saying I just got caught up in something, you know, and I got to deal with it. They won’t testify for me.
The prosecutor then asked Harris to name the persons with whom he had been playing dice. In the ensuing colloquy, Harris acknowledged knowing one of those playing dice as Raymond Jones and stated that he had asked him to testify at trial but that the witness said he would not come.4 Defense counsel did not object to this line of questioning.
Wallace testified on rebuttal stating that at the time he purchased drugs from Harris no one else was in the area selling drugs and he did not see anyone playing dice. Officer Mitchell corroborated Wallace’s testimony by stating that no one else was in the area. Officer Mitchell further stated that he did not remember removing any money from Harris’ possession at the time he was arrested. Similarly, Officer Washington testified that although Harris was frisked for weapons before he was placed in the transport cruiser, no money was taken from him. He also demonstrated how Harris, with his hands cuffed behind his back, could have placed his hands in his pockets. In surrebuttal testimony, Harris demonstrated how the use of his left hand had been limited by a gunshot wound.
II.
Harris contends that the prosecutor committed “misconduct” by failing to secure permission from the trial court before making what amounted to a missing witness argument by his cross-examination of Harris.5 In this way, Harris contends, the prosecutor jeopardized the fairness and integrity of the trial and substantially prejudiced the jury, requiring reversal.
We will identify first the standard by which we will measure any such impro[159]*159priety by the prosecutor in this case, next evaluate the claim that the prosecutor actually committed any impropriety in his cross-examination of Harris, and finally measure any demonstrated impropriety against that standard. When reviewing allegations that a prosecutor conducted an examination or argument improperly, we determine first whether the prosecutor’s statements or actions actually were improper. Gray v. United States, 589 A.2d 912, 916 (D.C. 1991); Hammill v. United States, 498 A.2d 551, 554 (D.C.1985). Normally, where we find that an impropriety has occurred and that the defendant has made appropriate objection, we then determine whether we can say “with fair assurance, after pondering all that happened without stripping the erroneous action from the whole, that the judgment was not substantially swayed by the error.” (Phillip) Dyson v. United States, 418 A.2d 127, 132 (D.C.1980) (quoting Gaither v. United States, 134 U.S.App. D.C. 154, 172, 413 F.2d 1061, 1079 (1969) (footnote omitted) (quoting in turn Kotteakos v. United States, 328 U.S. 750, 765, 66 S.Ct. 1239, 1248, 90 L.Ed. 1557 (1946))). This is done based on “the gravity of the misconduct, its relationship to the issue of guilt, the effect of any corrective action by the trial judge, and the strength of the government’s case.” Gray, supra, 589 A.2d at 916 (quoting Dixon v. United States, 565 A.2d 72, 75 (D.C.1989)); accord, Mitchell v. United States, 569 A.2d 177, 183 n. 5 (D.C.), cert. denied, — U.S.-, 111 S.Ct. 521, 112 L.Ed.2d 532 (1990); Sherrod v. United States, 478 A.2d 644, 655 (D.C.1984).
The government contends here, however, and we agree, that because Harris made no objection at trial concerning the errors he asserts on appeal, the appropriate standard to apply here is the more demanding plain error doctrine. Watts v. United States, 362 A.2d 706, 709 (D.C. 1976) (en banc); accord, Jones v. United States, 512 A.2d 253, 258 (D.C.1986); Mitchell, supra, 569 A.2d at 183 n. 5; see also Super.Ct.Crim.R. 52(b).
It is well settled that reversal under the plain error doctrine is justified only in exceptional circumstances where “a miscarriage of justice would otherwise result.” United States v. Frady, 456 U.S. 152, 163 n. 14, 102 S.Ct. 1584, 1592 n. 14, 71 L.Ed.2d 816 (1982). Stated otherwise, “error[s] complained of must be so clearly prejudicial to substantial rights as to jeopardize the very fairness and integrity of the trial.” Watts, supra, 362 A.2d at 709; accord, Allen v. United States, 495 A.2d 1145, 1152 (D.C.1985) (en banc); (Frank) Arnold v. United States, 467 A.2d 136, 137-38 (D.C.1983). “An error, of course, must be more than obvious or readily apparent in order to trigger appellate review” under the plain error standard. United States v. (Billy) Young, 470 U.S. 1, 17 n. 14, 105 S.Ct. 1038, 1047 n. 14, 84 L.Ed.2d 1 (1985).6 As we recently stated, “[t]he Supreme Court has cautioned that reversal for plain error in cases of alleged prosecutorial misconduct should be confined to ‘particularly [160]*160egregious’ situations.” Doe v. United States, 583 A.2d 670, 676 (D.C.1990) (citations omitted).
This court, when addressing allegations of plain error, must review the entire record because “[i]t is simply not possible for an appellate court to assess the seriousness of the claimed error by any other means.” (Billy) Young, supra, 470 U.S. at 16, 105 S.Ct. at 1047.
In reviewing criminal cases, it is particularly important for appellate courts to relive the whole trial imaginatively and not to extract from episodes in isolation abstract questions of evidence and procedure. To turn a criminal trial into a quest for error no more promotes the ends of justice than to acquiesce in low standards of criminal prosecution.
Id. (quoting Johnson v. United States, 318 U.S. 189, 202, 63 S.Ct. 549, 555, 87 L.Ed. 704 (1943) (Frankfurter, J., concurring)).
Relaxation of the “exacting definition of plain error,” (Billy) Young, supra, 470 U.S. at 15, 105 S.Ct. at 1046, should be avoided; to do otherwise “would skew the ... ‘careful balancing of our need to encourage all trial participants to seek a fair and accurate trial the first time around against our insistence that obvious injustice be promptly redressed.’ ” Id. (quoting Frady, supra, 456 U.S. at 163, 102 S.Ct. at 1592 (footnote omitted)).
Our ultimate focus in this case, therefore, is on whether the asserted errors jeopardized the very fairness and integrity of the trial and contributed to a miscarriage of justice rather than simply on the propriety of the prosecutor’s actions. See Black v. United States, 506 A.2d 1130, 1131 (D.C.1986).
III.
We turn to a discussion of the missing witness rule. It has been recognized for almost a century that “if a party has it peculiarly within his power to produce witnesses whose testimony would elucidate the transaction, the fact that he does not do it creates the presumption that the testimony, if produced, would be unfavorable.” Graves v. United States, 150 U.S. 118, 121, 14 S.Ct. 40, 41, 37 L.Ed. 1021 (1893). This court has clarified the circumstances in which the missing witness argument may be permitted and has established the procedure to be followed by counsel who wish to make the argument. We have emphasized that the trial court must first determine both “that the witness in question is peculiarly available to the party against whom the inference is sought, and ... that the witness’ testimony would have elucidated the transaction at issue.” Lemon v. United States, 564 A.2d 1368, 1375 (D.C.1989) (quoting Lawson v. United States, 514 A.2d 787, 789 (D.C.1986)); see also German v. United States, 525 A.2d 596, 611 (D.C.), cert. denied, 484 U.S. 944, 108 S.Ct. 331, 98 L.Ed.2d 358 (1987); Thomas v. United States, 447 A.2d 52, 57 (D.C.1982); Conyers v. United States, 309 A.2d 309, 312-13 (D.C.1973); United States v. (James) Young, 150 U.S.App.D.C. 98, 103-05, 463 F.2d 934, 939-41 (1972).
The first requirement, peculiar availability, is satisfied if “the party had the physical ability to locate and produce the witness and there was such a relationship, in legal status or on the facts as claimed by the party as to make it natural to expect the party to have called the witness.” Thomas, supra, 447 A.2d at 57 (quoting (James) Young, supra, 150 U.S.App.D.C. at 107, 463 F.2d at 943); accord Lawson, supra, 514 A.2d at 791. Two aspects of peculiar availability must be met. First, a witness must be physically available, i.e., capable of being brought to court. If not, “no factual conclusion can be drawn from the failure to produce him. In general, a witness is not physically available unless he can be located ... and is within the subpoena power of the court.” Thomas, supra, 447 A.2d at 57 (citations omitted). Second, practical availability is required. The party’s ability or reasons for producing the witness “must be stronger than those of the party seeking an inference in his favor.” Id. at 58.
To meet the second requirement, it must be demonstrated that the absent witness’ testimony would elucidate the trans[161]*161action. This is determined by inquiring whether the testimony is “relevant and material to a disputed issue in the case[,] ... noncumulative, and an ‘important part’ of the case of the party against whom the inference is drawn.” Id. at 57 (citations omitted).
Both requirements must be met before counsel may be permitted to make even a partial or incomplete missing witness argument. Lemon, supra, 564 A.2d at 1375. Counsel makes a partial or incomplete missing witness argument when counsel notes the absence of a witness but fails to take the additional step of asking the jury to infer that the witness’ testimony would have been adverse to the other party. If counsel takes that step, the argument becomes a complete missing witness argument. Id.; Lawson, supra, 514 A.2d at 789-90; (James) Arnold v. United States, 511 A.2d 399, 415-16 (D.C.1986). Unless the party seeking to use a missing witness argument can meet both requirements, the trial court must preclude counsel from making either type of missing witness argument, and the trial court itself must not give a missing witness instruction. See Dent v. United States, 404 A.2d 165, 169-70 (D.C.1979).
It has long been clear in this jurisdiction that before making a missing witness argument, counsel must obtain advance consent from the trial court. See Chappell v. United States, 519 A.2d 1257, 1259 (D.C.1987); accord (James) Arnold, supra, 511 A.2d at 415; Parks v. United States, 451 A.2d 591, 614 (D.C.1982), cert. denied, 461 U.S. 945, 103 S.Ct. 2123, 77 L.Ed.2d 1303 (1983). “When counsel, either for the prosecution or the defense, intends to argue to the jury for an inference to be derived from the absence of a witness, an advance ruling from the trial court should be sought and obtained.” Gass v. United States, 135 U.S.App.D.C. 11, 19, 416 F.2d 767, 775 (1969) (footnote omitted). “[T]o avoid injecting prejudicial error into the trial,” advance permission from the trial court is needed even before counsel makes an incomplete missing witness argument. (James) Arnold, supra, 511 A.2d at 416. By so doing, the trial court can “ensure that the foundational issues are addressed before possibly improper inferences are suggested to the jury.” Id. (emphasis in original) (quoting Thomas, supra, 447 A.2d at 58).
We note that in closing argument the prosecutor made no mention of any of the potential defense witnesses discussed here, i.e., the persons Harris said were playing dice with him before his arrest or the friend Harris had seen at the Florida Avenue Grill. This court has recognized, however, that the impact of some techniques of cross-examination can be substantially the same as an incomplete missing witness argument. See Chappell v. United States, 519 A.2d 1257, 1259 (D.C.1987); Sherrod v. United States, 478 A.2d 644, 654 (D.C. 1984). Thus, Judge Nebeker wrote for the court in Price v. United States:
The [prosecutor’s] questions suggested that the jury draw an adverse inference from the fact that the witnesses had not testified. The resulting adverse inference may have been that the absent witnesses’ testimony would have been unfavorable to Price. In this way, the cross-examination of Price operated in much the same manner as an incomplete missing witness argument. We conclude that the government’s inquiry should not have taken place without the trial court first determining that the same preconditions necessary for an incomplete missing witness argument were also present here.
531 A.2d 984, 993-94 (D.C.1987); accord, Lemon, supra, 564 A.2d at 1375.7
We have recognized that it is permissible for counsel to cross-examine with a view toward establishing that a purported witness does not exist and that this is different from a missing witness implication. See generally Alston v. United States, 552 A.2d 526, 528 (D.C.1989). Be[162]*162cause, however, counsel may explore whether, in fact, a witness actually exists in such a fashion as to suggest a missing witness inference, advance permission from the trial court should be sought. The trial court, when exercising its discretion whether to permit such questioning, should give consideration to our holdings that it is permissible for counsel to attempt to establish by cross-examination the non-existence of a purported witness.
Finally, we reiterate that the trial court has the discretion, even if the requirements of both peculiar availability and elucidation are met, to deny a request for a missing witness argument and instruction. As we stated in Thomas, supra:
This discretionary decision should be guided by reference to the underlying rationale for the doctrine, by considering “whether from all circumstances an inference of unfavorable testimony from an absent witness is a natural and reasonable one.”
Thomas, supra, 447 A.2d at 58 (quoting Dent v. United States, 404 A.2d at 165, 171 (D.C.1979)); see also German, supra, 525 A.2d at 611; Lawson, supra, 514 A.2d at 791; Miles v. United States, 483 A.2d 649, 658 (D.C.1984).
In the instant case, the government violated the Gass rule, as it appropriately concedes,8 when the prosecutor cross-examined Harris concerning his failure to call witnesses who supposedly could have given testimony favorable to Harris, without first obtaining the permission of the trial court. See Arnold, supra, 511 A.2d at 416. The government argues, however, that the prosecutor did not engage in a complete missing witness argument or equivalent interrogation and that the prosecutor’s failure to obtain the trial court’s consent before questioning appellant regarding the absence of Raymond Jones and other witnesses amounted to a “mere procedural error.”
We agree with the government that the prosecutor’s questions did not amount to a complete missing witness argument. This is so because the prosecutor did not directly urge the jury to infer from the fact that Harris did not call Raymond Jones as a witness that, if called, Jones would have testified adversely to Harris. See Black, supra, 506 A.2d at 1132.9
We are also satisfied, for the reasons we explain below, that had the prosecutor sought the trial court’s permission to question Harris about the persons he said he was playing dice with, it would have been within the trial court's “considerable discretion” to allow cross-examination on this matter. See Garris v. United States, 465 A.2d 817, 822 (D.C.1983), cert. denied, 465 U.S. 1012, 104 S.Ct. 1013, 79 L.Ed.2d 243 (1984). We reach a contrary conclusion about the prosecutor’s brief questioning concerning the friend Harris had visited at the Florida Avenue Grill, but find that lapse of little consequence, as we will also explain.
With respect to whether the dice game witnesses were peculiarly available to Harris, he answered on cross-examination at trial that he had asked Raymond Jones and his friends, who were allegedly playing dice with Harris just before he was arrested, to come to court to testify and that they refused. This response, however, did not automatically foreclose the inquiry of whether Raymond Jones was peculiarly available as a witness for Harris. It is true, of course, that if a witness such as Jones cannot be located or is not within the subpoena power of the court, he is not physically available. But Harris never testified that Raymond Jones could not be located; to the contrary, Harris merely stated that he did not know where Raymond Jones lived.10 That fact, standing [163]*163alone, is insufficient to counter the government’s argument that Raymond Jones was peculiarly available to Harris. Reasonably diligent efforts to produce Raymond Jones would have included investigation and the use of compulsory process provided by the court, means apparently not employed by Harris.
It would distort the missing witness doctrine if a court were to find that a witness is not peculiarly available to a party based merely upon that party’s testimony that an absent witness preferred not to come to court to testify or that the party did not know the witness’ address. Under the circumstances, we cannot say that Harris made a “bona fide reasonable effort[] to produce the witness without success.” See Thomas, supra, 447 A.2d at 57.
We turn now to the second requirement, that the witness’ testimony would elucidate the transaction. With respect to Raymond Jones, for example, the court would have to be satisfied that his testimony would be “relevant and material to a disputed issue in the case.” Id. Harris testified that just prior to being arrested he played dice in the alley with some men and that he saw two men on the street selling drugs. Because Harris stated that Raymond Jones was one of the men with whom Harris was playing dice, Raymond Jones could have corroborated Harris’ testimony, bolstered his credibility, and supported his defense theory of mistaken identity. If Raymond Jones had been' called as a witness for the defense, his testimony would have been relevant and material to Harris’ case. See generally (John) Harris v. United States, 430 A.2d 536, 543 (D.C.1981) (missing witness’ testimony would have been material to explain defendant’s presence in the vicinity of the crime, and it is not important that witness be eyewitness to the event at issue). The sum of this discussion is that under the circumstances of this case it would have been within the trial court’s broad discretion to permit the prosecutor to engage in the missing witness interrogation that he conducted concerning the persons Harris said were engaged in the dice game with him.
The same, however, cannot be said of the prosecutor’s questions concerning the friend who was with Harris at the Florida Avenue Grill fifteen minutes or more before Harris arrived at the location where he was arrested about an hour and half later. Given the circumstances, it is doubtful that that friend could have shed light upon the transactions or occurrences that led to Harris’ arrest. There is nothing in the record to suggest that the friend Harris met at the Grill was anywhere in the vicinity of the scene of the Harris’ arrest at any point between their encounter at the restaurant and Harris’ arrest some one and a half hours later. Given this degree of remoteness, the trial court would not have acted within its discretion in permitting a missing witness argument, or interrogation to the same effect, concerning this witness. But because it was obviously unlikely that this friend could shed any light on the circumstances surrounding Harris’ arrest, it is also highly unlikely that the jury attached much significance to the absence from trial of the friend who had seen Harris at a distant restaurant well before the time of the arrest.
To proceed with our assessment of Harris’ claim of plain error, we must also evaluate the strength of the government’s case. Jones v. United States, 512 A.2d 253, 258 (D.C.1986). We find it a reasonably strong case, even though we recognize that there were questions of credibility that the jury had to resolve. Wallace, an experienced police officer, made an undercover [164]*164buy of marijuana laced with PCP from Harris and then gave Officer Mitchell a description of Harris. Several other officers soon located and detained Harris who matched the description. An officer searched the area where Harris had been standing and found a brown paper bag containing three additional packets of marijuana treated with PCP. Wallace positively identified Harris at another location as the individual who sold Wallace the illegal drugs. Wallace had paid for the drugs with a twenty dollar bill pre-recorded by his partner. The serial number of the twenty dollar bill found by Officer Washington in the back seat of the police cruiser which transported Harris matched the serial number of the money used in the undercover buy.
These facts make the government’s case reasonably strong. The defense theory that all the officers involved agreed, for some reason, to conspire to fabricate from whole cloth a case against Harris, while not impossible, finds virtually no support in the record other than Harris’ own testimony. The defense suggested no reason why the police would wish to fabricate a case against him. The defense did raise questions about the loss of the record of the serial number of the twenty dollar bill used for the buy and about the transport log that referred to a second back seat passenger. But government witnesses gave explanations for those matters and, more significantly, other circumstances lent plausibility to the government’s case. Harris was the only individual in the vicinity of the place of his arrest who matched the description given the officer who made the buy. Indeed, he was the only person visible in the block at that time. Additionally, it is unlikely that another drug dealer had just happened to abandon his valuable stash near where appellant happened to be standing. In sum, having assessed the strength of the government’s case as a part of our plain error analysis, we deem it, as we have said, a reasonably strong case.
We also observe that the questioning at issue most likely did not create an “unfair prejudicial impact on the jury’s deliberations,” Young, supra, 470 U.S. at 17 n. 14, 105 S.Ct. at 1047 n. 14, because, even if the prosecutor did not raise this matter, the jury would have been aware from Harris’ testimony that the men playing dice with Harris just prior to his arrest had not come to testify in court. It would have been apparent to the jury that Harris had been the only person who testified that he had been engaged in this relatively innocuous activity shortly before his arrest while another person was hawking drugs nearby.
It is also significant that, when Harris answered the prosecutor’s questions, he used the opportunity to give his explanation for the absence of the men, viz., they did not want to come to court to testify and place themselves in a position where the police might harass them or bring charges against them. The jury might well have found this explanation plausible.11
Thus, while we find that the prosecutor injected at least some error into this case by failing to obtain the advance permission of the trial court before questioning appellant about persons who did not appear at trial, we cannot find that the error was of a serious nature. It is clear that the missing witness questioning here did not of itself bring about a miscarriage of justice.
IV.
Harris also argues that during rebuttal closing argument the prosecutor im-permissibly argued that the testimony of the police officers should be believed over the testimony of Harris because police officers had too much at stake to risk committing perjury. This conduct, Harris argues, was an improper declaration about credibility and occasioned cumulative prejudice which, coupled with the missing witness questioning, jeopardized the fairness and integrity of his trial. We disagree.
In disagreeing, we do not overlook the fact that the issue of credibility was important. Defense counsel stated in closing [165]*165argument that the government had introduced Harris’ prior convictions to demonstrate that Harris was not a credible person, and pointed out that at the same time the police officers’ in-court testimony and certain documentary evidence were in conflict. The prosecutor, in rebuttal closing argument, stated that in order to find Harris not guilty the jury would have to believe that the police officers perjured themselves, risking their careers, their futures, and their retirements. The prosecutor further observed that if the officers had decided to fabricate their testimony, they could easily have made up an air-tight case against Harris.
The prosecutor’s rebuttal argument was at least arguably a fair response to defense counsel’s closing. But even if we assume that the prosecutor should have refrained from making these statements because they were not based on record evidence, the resulting prejudice, if any, was slight. It would be reasonable for jurors to think that the consequences facing an officer who is caught giving perjured testimony are severe enough to deter such conduct. Finally, the trial court instructed the jury that the arguments of counsel could not be considered as evidence and that in a criminal case the burden of proof never shifts to the defendant. The jury is presumed to have followed these instructions, Clark v. United States, 593 A.2d 186, 193 (D.C. 1991), and this court will not “upset the verdict by assuming the jury declined to do so.” Gray, supra, 589 A.2d at 918.
Considering both Harris’ argument concerning the police officers’ motivation for avoiding perjury and the arguments Harris makes on the missing witness issue, it is clear to us that Harris has not even approached a showing of the prejudice that would be required to undermine its essential fairness of the trial and to constitute a miscarriage of justice. Although the prosecutor injected error into the proceedings to the limited extent we have discussed in the missing witness area, and assuming that the argument about the police officers’ careers was objectionable, the error did not reach the level of plain error.
V.
We also reject Harris’ contention that the prosecutor’s comments during rebuttal closing argument completed the missing witness argument and shifted the burden of proof. The prosecutor stated:
Furthermore, each police officer as they testified, each officer’s testimony corroborated different parts of another officer’s testimony, where they met, how they met, what they decided to do, what happened to Mr. Harris when they arrested him. Was there any kind of corroboration for Mr. Harris’s testimony. Is there anything to corroborate or support what he told you. There’s not.
Such argument, we hold, was permissible because it merely conveyed to the jury that when evaluating the credibility of a witness, corroboration or a lack thereof of the testimony should be considered. The government, by its missing witness interrogation of Harris and subsequent argument, did not shift the burden of proof. The government had the right to argue the strength of its case and contrast it with the weakness of Harris’ defense. That mode of argument did not, of itself, shift the burden of proof to Harris. Moreover, the trial court properly instructed the jurors that they could “consider whether the witness has been contradicted or corroborated by other credible evidence in the case.” See Criminal Jury Instructions for the District of Columbia, No. 2.11 (3d ed. 1978); see also United States v. Sensi, 279 U.S.App.D.C. 42, 53-54, 879 F.2d 888, 899-900 (1989); United States v. Glantz, 810 F.2d 316, 321 (1st Cir.), cert. denied, 482 U.S. 929, 107 S.Ct. 3214, 96 L.Ed.2d 701 (1987); United States v. Gotchis, 803 F.2d 74, 79-81 (2d Cir.1986).
Based on the foregoing, Harris’ conviction is
Affirmed.