What is the test for establishing multiple conspiracies?

However, whether the evidence has established multiple conspiracies rather than a single one is ordinarily a question of fact for the jury, United States v. Finkelstein, 526 F.2d 517, 522 (2d Cir. 1975), cert. denied,425 U.S. 960, 96 S.Ct. 1742, 48 L.Ed.2d 205 (1976); and, accepting the proof in the light most favorable to the Government, United States v. McCarthy,473 F.2d 300, 302 (2d Cir. 1972), we think it was sufficient to permit the jury to find the existence of but a single conspiracy. Evidence was introduced to show that the "brains" of the smuggling operation were

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