.3d 105, 115 (2d Cir. 2000); see 18 U.S.C. §§ 1341, 1343. 'The gravamen of the offense is the scheme to defraud." United States ex rel. O'Donnell v. Countrywide Home Loans, Inc., 822 F.3d 650, 657 (2d Cir. 2016). A "scheme to defraud" is "a plan to deprive a person of something of value by trick, deceit, chicane or ov

ations to third parties, and (ii) the analysis regarding the predominance of legal advice in the communications at issue and Ambac Assur. Corp. v. Countrywide Home Loans, Inc.6 both expand the scope of privilege to protect certain content unrelated to ongoing litigation. See infra S IV. Indeed, Defendant refers to