What is the test for establishing that there are six separate conspiracies?

MultiRegion, United States of America

The following excerpt is from U.S. v. Jabara, 618 F.2d 1319 (9th Cir. 1980):

The essence of the defendants' argument is that there were six separate and independent acts or activities proved at trial all of which constituted six separate conspiracies. According to the defendants these six separate conspiracies were separated by time, persons, places and overt acts. In United States v. Kearney, 560 F.2d 1358, 1362 (9th Cir.) cert. denied, 434 U.S. 971, 98 S.Ct. 522, 54 L.Ed.2d 460 (1977), this circuit rejected a similar contention, stating:

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