United States v. Esparza-Ponce, 7 F.Supp.2d
1084 (S.D.Cal. May 18, 1998) (California conviction of theft,
in violation of California Penal Code § 484, could constitute
an "aggravated felony" under INA § 101(a)(43)(G),
8 U.S.C. § 1101(a)(43)(G), for purposes of the illegal re-entry
sentence enhancement, even though the California statute is
overbroad with respect to the common-law aggravated felony
definition of theft since the statute includes theft of services),
affirmed, 193 F.3d 1133 (9th Cir. Oct. 19, 1999), cert. denied,
531 U.S. 842 (2000).