Justice Department's indictment of Semion Mogilevich

(b) Defendants FISHERMAN, BOGATIN and TSOURA, in order to
conceal the falsification of the books and records of the Network of YBM companies
described below at paragraph 35(c), at various times between 1994 and 1998, routinely
deceived, obstructed, and lied to the auditors, and to the forensic examiners who examined
the books and records of YBM and its subsidiaries by, among other things:
(1) falsely representing that the books and records of YBM and the
Network of YBM Companies were accurate when they were not;
(2) providing false financial records, bank statements, invoices,
contracts, customer lists, shipping documentation and audit
confirmations, which were created to support false claims of sales
activity and revenues;
(3) systematically withholding access to records and documentation
essential to substantiate the accuracy of YBM’s statements of its
financial condition, by using “put-offs,” stalling tactics, and false
promises of production; and
(4) failing to disclose to the auditors the material matters as set forth in
paragraph 37 below.
Falsification of Books and Records
(c) Defendants MOGILEVICH, FISHERMAN, BOGATIN and
TSOURA, in order to make YBM’s financial statements look profitable and attractive to
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