As discussed below, Ward fails to overcome the limitations in § 2254(d) and therefore cannot show that his requested funds for the development of new evidence would be reasonably necessary. E.g., Caudill v. Conover, 871 F. Supp. 2d 639, 650 (E.D. Ky 2012); Soto Fong v. Ryan, No. CV 04-68-TUC-DCB, 2011 WL 3439237, at *15 (D. Ariz. Aug. 5, 2011) (denying requests for discovery, expansion of the record, and evidentiary hearing because petitioner failed to satisfy either prong of § 2254(d)). B. Factual Background