Matter of Islam, 25 I&N Dec. 637, 639 (BIA 2011) (New York convictions of criminal possession of stolen property (involving a credit or debit card), under N.Y. Penal 165.45(2), and forgery in the third degree, under N.Y. Penal 170.05, constituted multiple convictions of crimes of moral turpitude, for purposes of deportation under INA 237(a)(2)(A)(ii), 8 U.S.C. 1227(a)(2)(A)(ii), rejecting a claim that these convictions should be treated as a single scheme of criminal misconduct, where they arose from respondents use of two credit and debit cards at four locations, including different retail outlets, in adjoining counties over the course of a few hours); following Matter of Adetiba, 20 I&N Dec. 506 (BIA 1992) (separate crimes involving the unauthorized use of four different credit cards obtained in four different fictitious names, which resulted in harm to different victims, did not arise out of a single scheme of criminal misconduct, even if they were committed pursuant to an elaborate plan and the same modus operandi was used for each offense: when an alien has performed an act, which, in and of itself, constitutes a complete, individual, and distinct crime, he is deportable when he again commits such an act, even though one may closely follow the other, be similar in character, and even be part of an overall plan of criminal misconduct. . . . the single scheme exception refers to acts, which although separate crimes in and of themselves, were performed in furtherance of a single criminal episode, such as where one crime constitutes a lesser offense of another or where two crimes flow from and are the natural consequence of a single act of criminal misconduct.).