Bobb v. Atty Gen. of the United States, __ F.3d __ (9th Cir. Aug. 3, 2006) (to constitute aggravated felony "forgery" under INA 101(a)(43)(R) the offense must be "related to" forgery, i.e., show or establish a logical connection with forgery; a forgery offense does not necessarily require proof of an intent to defraud; 18 U.S.C. 510(b) [exchange of forged Treasury instruments] given as example of a forgery offense that is "related to" forgery, but does not involve fraud), following Drakes v. Zimski, 240 F.3d 246 (3d Cir. 2001).
http://caselaw.lp.findlaw.com/data2/circs/3rd/052891p.pdf