Matter of Islam, 25 I&N Dec. 637 (BIA 2011) (crimes of moral turpitude did not arise out of a single scheme of criminal misconduct where respondent was convicted in two different counties of forgery and possession of stolen property based on his use of multiple stolen credit or debit cards to obtain items of value from several retail outlets on five separate occasions over the course of a day).
http://www.justice.gov/eoir/vll/intdec/vol25/3733.pdf