Ferreira v. Ashcroft, 390 F.3d 1091 (9th Cir. Dec. 1, 2004) (California conviction of welfare fraud, in violation of Welf. & Inst. Code 10980(c)(2), constitutes an offense involving fraud or deceit with a loss to the victim in excess of $10,000, for purposes of qualifying as an aggravated felony as defined under INA 101(a)(43)(M)(i), 8 U.S.C. 1101(a)(43)(M)(i) triggering deportation, where the plea agreement - part of the record of conviction - sets the amount of restitution at $22,305 and where the California courts are required under California Penal Code 1202.04(f) to set restitution based on the loss to the victim).