closing statements, in which he discussed the jury instructions regarding the definition of an enterprise: Did, in fact, [the Eme] have rules that were followed? Did it have a mechanism for making decisions on anything other than an ad hoc basis[?] Do you know what “ad hoc " means? It means that people get together to make decisions, but it's not continuous. When you have ad hoc committees and organizations, you set up the committee to deal with a particular problem. Once that problem is solved it dissolves. That's what "ad hoc ” means. 33 . The question of whether an instruction on multiple conspiracies is warranted is related to the issues of ''spillover” or transference of guilt that are raised by trial severance, as discussed above. See Anguiano, 873 F.2d at 1317-18 & n. 2 (<HOLDING>). 34 . Our precedents require a
holding that written instructions did not cure erroneous oral instruction recognizing that evidence may be legally insufficient where there is variance between indictment allegations and proof holding variance between enhancement allegation and proof renders evidence legally insufficient only if variance is material recognizing double jeopardy bar is inapplicable where a variance between indictment and proof necessitated prosecution under a new indictment holding that multiple conspiracies instruction is required where there is possibility of prejudicial variance between indictment and trial proof and noting that such an instruction is designed precisely to cure the problem of kotteakos spillover  and would not cure other prejudicial variance problems