United States v. Bonilla, 524 F.3d 647 (5th Cir. Apr. 10, 2008) (sentencing court could rely on a New York "Certificate of Disposition" to identify the subsection of conviction, but here, it did not do so, so the evidence was insufficient to establish that the defendant was convicted under the portion of New York Penal Law 125.15 [(1) "recklessly causes the death of another" or (2) commits abortion or (3) intentionally aids a suicide] that qualified as "manslaughter" within the meaning of USSG 2L1.2(b)(1)(A)(ii), for purposes of imposing a 16-level enhancement of illegal reentry sentence), citing United States v. Neri-Hernandes, 504 F.3d 587, 591-592 (5th Cir. 2007) (Certificate of Disposition specified subsection of conviction).