Justice Department's indictment of Semion Mogilevich

operated businesses, described herein as "the Network of YBM
companies," see paragraphs 10 to 19 of the Introduction below;
(c) acquired millions of shares of YBM stock at minimal cost to the
defendants;
(d) deceived securities regulators through efforts to secure approval for listing
and sale of YBM stock on securities exchanges and markets in Canada and
the United States; and
(e) fraudulently inflated the price of YBM stock by falsely reporting and
representing to investors and securities regulators that YBM was a highly
profitable and investment-worthy enterprise which generated high
revenues from the worldwide sale and distribution of magnets and other
products.
3. It was a further part of the plan and purpose of the scheme to defraud that
the defendants were to carry out the conduct referenced above in paragraph 2, through the
manner and means of the scheme to defraud as set forth in paragraphs 29 to 46 of the
Introduction, in order to:
(a) defraud the investing public into purchasing millions of shares of YBM
stock on the Canadian exchanges and through brokers in the United States;
(b) enable the defendants to profit unjustly, and enrich themselves, by selling
millions of dollars of YBM stock at fraudulently inflated prices;
(c) enable certain of the defendants to enrich themselves by paying themselves
large salaries and bonuses and granting themselves stock options and
3