Justice Department's indictment of Semion Mogilevich

Budapest manufacturing plant and was the primary company through which magnet sales
and other commercial transactions were conducted. Defendant FISHERMAN served as
President of UNITED TRADE from its inception until at least August 1998, when he was
forced to resign.
C. CONTROL OVER YBM
Control of Management
33. At all times relevant to the period of the Superseding Indictment,
defendants FISHERMAN, BOGATIN and TSOURA used their various executive positions
within the Network of YBM companies to control the operations of the Network of YBM
companies and, thereby, carry out the scheme to defraud. As a result, defendants FISHERMAN,
BOGATIN and TSOURA were able to act for, and on behalf of, defendant MOGILEVICH, and
to follow his directives and implement his objectives in executing the scheme.
Control Through Ownership of Stock
34. Between approximately February 1994 and November 1995, defendants
MOGILEVICH, FISHERMAN and BOGATIN, and others known and unknown to the grand
jury, orchestrated a series of corporate and financial transactions (see paragraphs 32(b)-32(d)
above) that, among other things, were designed to enable MOGILEVICH, FISHERMAN and
BOGATIN to acquire a controlling stock interest in PRATECS/YBM that continued until at least
May 1998.
(a) As a result of the said corporate transactions that occurred in 1994
and 1995, MOGILEVICH and five close Russian business associates, the ARIGON
shareholders, received approximately 18.7 million shares of PRATECS stock in exchange
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