The defense phase of a trial occurs after the prosecution phase, that is, after the prosecution "rests". Other parts of the defense include the opening and closing arguments and the cross-examination during the prosecution phase. Since a defense is raised by the defendant in a direct attempt to avoid what would otherwise result in liability, the defendant typically holds the burden of proof. For example, if a defendant in an assault and battery case attempts to claim provocation, the victim of said assault and battery would not have to prove that he did not provoke the defendant; the defendant would have to prove that the plaintiff did. The information can be published in our peer reviewed journal with impact factors and are calculated using citations not only from research articles but also review articles (which tend to receive more citations), editorials, letters, meeting abstracts, short communications, and case reports. The inclusion of these publications provides the opportunity for editors and publishers to manipulate the ratio used to calculate the impact factor and try to increase their number rapidly. Impact factor plays a major role for the particular journal. Journal with higher impact factor is considered to be more important than other ones.