Kamagate v. Ashcroft, 385 F.3d 144 (2d Cir.
Sept. 21, 2004) (federal conviction of conspiracy to utter
and possess counterfeit securities in violation of 18 U.S.C.
§§ 371, 513(a), constitutes an aggravated felony, as "an
offense relating to . . . counterfeiting," under INA
§ 101(a)(43)(R), (U), 8 U.S.C. § 1101(a)(43)(R), (U), triggering
deportability under INA § 237(a)(2)(A)(iii), 8 U.S.C. § 1227(a)(2)(A)(iii),
rejecting an argument that an offense relates to counterfeiting
only if it involves the creation of counterfeit instruments
or a scheme to do so, and that the present conviction cannot
be a crime "related to counterfeiting" because a
defendant can be guilty of such a conspiracy without proof
that the conspirators ever dealt in counterfeit securities,
much less that they made or intended to make such instruments).