Hernandez-Cruz v. Holder, ___ F.3d ___, ___ (9th Cir. Jul. 7, 2011) (A generic theft offense, in turn, is defined as: [1] a taking of property or an exercise of control over property [2] without consent [3] with the criminal intent to deprive the owner of rights and benefits of ownership, even if such deprivation is less than total or permanent.); quoting Carrillo-Jaime v. Holder, 572 F.3d 747, 750 (9th Cir. 2009) (citation and quotation marks omitted, alterations in original).