• The Ninth Circuit, like other Circuits and the BIA, accepted as a generic definition of theft, the ??taking of property or an exercise of control over property without consent with the criminal intent to deprive the owner of rights and benefits of ownership, even if such deprivation is less than total or permanent.?? Penuliar v. Gonzales, 435 F. 3d 961, 969 (2006) (internal quotation marks omitted