Justice Department's indictment of Semion Mogilevich

productive between September and December of 1994;
(c) YBM maintained a sales office and staff in Canada which promoted and sold
millions of dollars of its magnet products.
Sales
• In reality, the defendant BOGATIN and an unindicted conspirator set up a
sham sales office in Canada in or about January 1995 to foster the illusion
that YBM maintained a viable customer base in Canada, when it did not.
(d) YBM MAGNEX's net magnet sales totalled approximately $110 million for
the years 1992, 1993, 1994, and through September 1995.
• In reality, the defendants knew that the books and records were "cooked,”
that is, the financial statements for those years contained bogus sales and
inventory figures in order to create the false appearance that YBM had a
viable customer base with significant sales of its magnet products;
(e) Sales of YBM magnets in Canada between 1992 and May 1994 amounted to
$4.2 million (U.S.).
• In reality, the defendants knew sales of YBM magnets in Canada during
that period were virtually nonexistent and the valuation of the distribution
rights to sell YBM products in Canada based upon these bogus sales
figures was artificially inflated;
(f) YBM had penetrated the North American magnet market, primarily in the
United States, and sales revenues from North American customers were approximately
$13.6 million in 1996.
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