...a prima facie showing of a fraud that satisfies the first element of the showing necessary to apply the crime-fraud exception to the attorney-client privilege”).” DECLARATION, Case 1:11-cv-00691-LAK, Document 400, Filed 03/02/12, pages 1-2 (footnotes not included) See also Chevron v. Donziger, 768 F. Supp. 2d 581, 636 (S.D.N.Y. 2011), rev’d on other grounds, 303 F.3d 470 (2d Cir.
2012)(footnotes not included)(emphasis supplied) “Chevron thus is likely to prevail on its contention that the Ecuadorian judgment in this case "was rendered under a system which does not provide impartial tribunals...