The following excerpt is from Smulley v. Fed. Hous. Fin. Agency, Fed. Nat'l Mortg. Ass'n, Mortg. Elec. Registration Sys., Inc., 17-2666 (2nd Cir. 2018):
1341, 1343). These crimes thus require "(1) a scheme to defraud, (2) money or property as the object of the scheme, and (3) use of the mails or wires to further the scheme." Id. (internal quotation marks omitted). A scheme to defraud is defined as "a plan to deprive a person of something of value by trick, deceit, chicane or overreaching." United States v. Autuori, 212 F.3d 105, 115 (2d Cir. 2000) (internal quotation marks omitted).
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