Penuliar v. Mukasey, 523 F.3d 963 (9th Cir. Apr. 22, 2008) ("Similarly, the abstracts of judgment for both convictions, which simply recite that Penuliar pled guilty to 10851(a), cannot establish what facts Penuliar admitted in his guilty plea. See Vidal, 504 F.3d at 1087 ("In order to identify a [ 10851] conviction as the generic offense through the modified categorical approach, when the record of conviction comprises only the indictment and the judgment, the judgment must contain the critical phrase "as charged in the Information." "). Without a plea transcript or other evidence demonstrating the theory under which Penuliar pled guilty, we cannot find that Penuliar pled guilty to 10851(a) as a principal."), distinguishing Arteaga v. Mukasey, 511 F.3d 940, 947 (9th Cir. 2007) (without describing the record before it, this case distinguished Vidal because "applying the Taylor modified categorical approach to the facts here reveals that Arteaga was convicted of a theft offense.").