United States v. Snellenberger, 548 F.3d 699 (9th Cir. Oct. 28, 2008) (per curiam) (en banc) (to determine the nature of a conviction, when applying the modified categorical approach of Taylor v. United States, 495 U.S. 575 (1990), the reviewing court may consider a clerk's minute order that conforms to certain essential procedures as establishing a plea to Count I, as opposed to Count II), overruling United States v. Diaz-Argueta, 447 F.3d 1167, 1169 (9th Cir. 2006).