Joseph v. United States Atty Gen., 465 F.3d 123 (3d Cir. Oct. 2, 2006) (even where statute may be divided into discreet subsections, court cannot and need not look to the record of conviction to determine subsection of conviction where none of the subsections identified qualifies as an aggravated felony applying minimum conduct analysis). See also Ng. v. Atty Gen., 436 F.3d 392 (3d Cir. 2006) (divisible statute); Canada v. Gonzales, 448 F.3d 560 (2d Cir. 2006) (minimum conduct).