The following excerpt is from U.S. v. Wilds, 993 F.2d 887 (9th Cir. 1993):
The denial of a motion for discovery is reviewed for abuse of discretion, and the district court's decision to refuse discovery may be overturned only when the defendant shows prejudice to substantial rights. United States v. Michaels, 796 F.2d 1112, 1115 (9th Cir.), cert. denied, 479 U.S. 1038 (1987).
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