The following excerpt is from U.S.A v. Doss, DC. No. CR-05-00627-SGL-01, No. 07-50334 (9th Cir. 2011):
[10] We review the denial of a severance motion for an abuse of discretion. United States v. Lewis, 787 F.2d 1318, 1320 (9th Cir. 1986). A defendant must show that the failure
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