Counts Five through Eight was the same scheme described in detail in Counts One through Four. I would therefore affirm Schmitz’s convictions, on all counts. 1 . The majority cites cases from several other circuits to support its conclusion that, absent express incorporation, we may not look to factual allegations in other counts of the indictment. As in Huff, however, most of these cases seem to turn on the failure to include an essential element of the offense under the count at issue. See United States v. Knowles, 29 F.3d 947, 952 (5th Cir.1994) (explaining that the failure to allege a nexus to interstate commerce under a count charging a violation of the Gun Free Schools Act "render[ed] that charge fundamentally defective”); United States v. Miller, 774 F.2d 883, 883 (8th Cir.1985) (<HOLDING>); United States v. Fulcher, 626 F.2d 985, 988
holding that an allegation as to the time of the offense is not an essential element of the offense charged in the indictment and within reasonable time limits proof of any date before the return of the indictment and within the statute of limitations is sufficient holding an indictment legally insufficient when it failed to inform the defendant of the gravamen of the alleged offense holding that in relation to is an element of 18 usc  924c holding the indictment was insufficient in that it failed to cite the state statute alleged to have been violated an essential element of the offense described in 18 usc section 1955 holding that petitioner could not challenge his conviction on the grounds that the indictment failed to charge an essential element of the crime through a writ of habeas corpus