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Justice Department's indictment of Semion Mogilevich

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UNITED TRADE and MAGNEX RT to be approximately $40 million.<br />

• In reality, the defendants knew this was a false and inflated value, and<br />

indeed the value <strong>of</strong> the machinery and equipment at the Budapest plant as<br />

<strong>of</strong> May 1999 was not more than approximately $3,080,000;<br />

(j) YBM sold ARBAT, a Russian joint venture company and a subsidiary <strong>of</strong><br />

ARIGON, for the sum <strong>of</strong> $250,000, and realized a pr<strong>of</strong>it <strong>of</strong> $70,000.<br />

Management and Control<br />

• In reality, the defendants knew YBM did not realize a pr<strong>of</strong>it, rather the<br />

purchase was paid for with monies funneled to closely-related straw parties<br />

from <strong>Mogilevich</strong>’s ARIGON bank account and from monies from the sale<br />

<strong>of</strong> MOGILEVICH’s YBM stock.<br />

(k) YBM’s core operations, including production, sales, marketing and corporate<br />

finance, were primarily directed and controlled by a North American-based Board <strong>of</strong><br />

Directors and corporate management team.<br />

• In reality, the defendants knew the core operations were directed and<br />

controlled by the defendants MOGILEVICH, FISHERMAN and TSOURA<br />

from Budapest, Hungary, and other locations in combination with<br />

BOGATIN; and<br />

(l) Certain individuals held various titles and positions <strong>of</strong> authority for<br />

companies within the Network <strong>of</strong> YBM companies, including Treasurer, Sales and<br />

Marketing Director, and Director <strong>of</strong> Industrial Relations.<br />

• In reality, the defendants knew these individuals performed minimal<br />

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