The following excerpt is from U.S. v. Ponce, 51 F.3d 820 (9th Cir. 1995):
A denial of a severance motion is reviewed for an abuse of discretion. United States v. Tootick, 952 F.2d 1078, 1080 (9th Cir.1991). "Defendants must meet a heavy burden to show such an abuse, and the trial judge's decision will seldom be disturbed." Id.
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