In Millard v. Commonwealth, 34 Va. App. 202, 539 S.E.2d 84 (Va. Ct. App. 2000), the court addressed whether the defendant could be convicted of multiple counts of larceny by false pretenses for presenting three checks with forged endorsements to a bank teller and receiving a single payment from the bank. See id. 539 SE.2d at 85.
The court concluded that there was no evidence in the record from which to infer that the defendant's actions were not "done pursuant to a single criminal impulse and in the execution of a general fraudulent scheme." Id. 539 SE.2d at 86.
Thus, the court remanded the case to the trial court with instructions to set aside two of the defendant's three convictions. See id.