Gertsenshteyn v. Mukasey, 544 F.3d 137 (2d Cir. Sept. 25, 2008) ("[T]he INA premises removability not on what an alien has done, or may have done, or is likely to do in the future (tempting as it may be to consider those factors), but on what he or she has been formally convicted of in a court of law. Thus "[f]or nearly a century," the BIA recently observed, "the Federal circuit courts of appeals have held that where a ground of deportability is premised on the existence of a conviction for a particular type of crime, the focus of the immigration authorities must be on the crime of which the alien was convicted, to the exclusion of any other criminal or morally reprehensible acts he may have committed." In re Velazquez-Herrera, 24 I. & N. Dec. 503, 513 (B.I.A.2008).").