Medina-Lara v. Holder, 771 F.3d 1106, 1113 (9th Cir. Oct. 10, 2014) (When a court using the modified categorical approach to determine whether an underlying conviction is a predicate offense relies solely on the link between the charging papers and the abstract of judgment, that link must be clear and convincing. Put another way, where, as here, the government bears the burden of proof to show by clear and convincing evidence that the 11351 conviction is a predicate offense [citations omitted], the government must demonstrate that the abstract clearly and convincingly shows that Medina pleaded guilty to the element as alleged in the complaint.).