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Justice Department's indictment of Semion Mogilevich

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THE GRAND JURY CHARGES:<br />

INTRODUCTION<br />

The Scheme to Defraud<br />

1. From in or about 1993, and continuing up to and including in or about<br />

September 1998, in the Eastern District <strong>of</strong> Pennsylvania and elsewhere, defendants<br />

SEMION MOGILEVICH,<br />

a/k/a "Simeon Mogilevitch"<br />

a/k/a "Semjon Mogilevcs"<br />

a/k/a "Shimon Makhelwitsch"<br />

a/k/a "Seva"<br />

IGOR FISHERMAN,<br />

JACOB BOGATIN,<br />

a/k/a "Yakov"<br />

ANATOLY TSOURA<br />

together with others known and unknown to the grand jury, devised and intended to devise a<br />

scheme and artifice to defraud thousands <strong>of</strong> investors in the United States, Canada, and<br />

elsewhere, and to obtain money and property by means <strong>of</strong> false and fraudulent pretenses,<br />

representations and promises ("the scheme to defraud").<br />

defendants:<br />

Plan and Purpose <strong>of</strong> the Scheme To Defraud<br />

2. It was part <strong>of</strong> the plan and purpose <strong>of</strong> the scheme to defraud that the<br />

(a) created and controlled a publicly-owned company in North America which<br />

became known as YBM MAGNEX INTERNATIONAL, INC. (“YBM”);<br />

(b) used a network <strong>of</strong> companies in the Eastern District <strong>of</strong> Pennsylvania,<br />

Canada, Eastern Europe and elsewhere, which included fraudulently<br />

2

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