Padilla-Martinez v. Holder, ___ F.3d ___, 2014 WL 5421219 (9th Cir. Oct. 27, 2014) (failure to fully comply with the terms of the statute and regulation [8 U.S.C. 1229a(c)(3); 8 C.F.R. 1003.41] does not render electronic conviction records inadmissible; holding admissible an uncertified facsimile copy of a transcript of the state court felony change-of-plea proceedings to establish drug-trafficking aggravated felony conviction); citing Sinotes"Cruz v. Gonzales, 468 F.3d 1190, 1195"96 (9th Cir. 2006) (admitting copies of criminal convictions that were stamped by an immigration agent and appeared to be official state-court records even though certification by a state official was lacking); 8 U.S.C. 1229a(c)(3)(C) instead establishes the maximum standard for authentication of electronically transmitted records of conviction, but it does not establish a minimum standard. The BIA may therefore admit evidence under either the requirements of the INA statute or through any procedure that comports with common law rules of evidence. [Admissibility is generally warranted so long as there is] some sort of proof that the document is what it purports to be.); quoting Iran v. I.N.S., 656 F.2d 469, 472 n. 8 (9th Cir.1981) (as amended)).