Aggravated Felonies
§ 4.27 (B)
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(B) Clerk’s Certificate. A certificate of the clerk of court also may be deemed part of the conviction record.[256]
[256] Wadman v. INS, 329 F.2d 812, 813-814 (9th Cir. 1964) (receiving stolen goods). But see Dashto v. INS, 59 F.3d 697, 701-702 (7th Cir. 1995) (reversing deportation order based on certificate of clerk of court as to criminal record).