The following excerpt is from U.S. v. Carter, 804 F.2d 508 (9th Cir. 1986):
Other circuits have acknowledged the principle that a series of shipments must be logically related in order to constitute a single offense. See United States v. Markus, 555 F.Supp. 375, 378 (D.N.J.1983), aff'd, United States v. Markus, 721 F.2d 442 (3d Cir.1983) ("it is permissible to aggregate a series of related transactions described in a single count so long as the series is alleged to constitute a single offense"); United States v. Lagerquist, 758 F.2d 1279, 1282 (8th Cir.1985) (the facts that all the fraudulently induced shipments were received, and the checks in payment issued within a two-week period, that the same pair of business partners were defrauded by each shipment and that the defendant sold each shipment to the same buyer provided "enough relationship among the transactions so that they were properly charged as a single offense").
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