Kamagate v. Ashcroft, 385 F.3d 144 (2d Cir.
Sept. 21, 2004) (federal conviction of conspiracy to utter
and possess counterfeit securities, in violation of 18 U.S.C.
§ 371, 513(a), constitutes an aggravated felony, as "an
offense relating to . . . counterfeiting," under INA
§ 101(a)(43)(R), (U), 8 U.S.C. 1101(a)(43)(R), (U), triggering
deportability under INA § 237(a)(2)(A)(iii), 8 U.S.C. 1227(a)(2)(A)(iii),
rejecting an argument that an offense relates to counterfeiting
only if it involves the creation of counterfeit instruments
or a scheme to do so, and that the present conviction cannot
be a crime "related to counterfeiting" because a
defendant can be guilty of such a conspiracy without proof
that the conspirators ever dealt in counterfeit securities,
much less that they made or intended to make such instruments).