Justice Department's indictment of Semion Mogilevich

(b) On or about November 20, 1997, approval was obtained from the OSC to
register for sale approximately 7.2 million common shares to the investing public which
raised approximately $100 million (CDN) in proceeds ("1997 Offering"). The $100
million raised was used to fund and promote the fraudulent operations of the company and
to carry out the scheme to defraud. This stock was sold in two stages, as follows:
(1) 3.2 million shares of YBM stock were sold to the public for $16.50
(CDN) share in a public offering approved by the OSC and
completed on November 26, 1997, which generated approximately
$52 million (CDN); and
(2) 4 million shares of YBM stock, at $12 (CDN) per share, were
issued in connection with a private placement of convertible notes
on or about August 20, 1997, which were purchased primarily by
institutional investors. This raised approximately $48 million
(CDN). The notes were convertible into the 4 million shares of
YBM common stock on November 20, 1997.
41. From approximately July 1994, when PRATECS stock was sold in the
IPO at $.10 (CDN) per share, until approximately March 1998, when PRATECS/YBM’s stock
reached a peak of $20.15 (CDN) per share, the price of stock rose approximately 2,000 percent in
less than four years. On May 13, 1998, when the trading in YBM stock was suspended by the
OSC, the stock was trading at approximately $14.35 (CDN) per share.
I. EFFORT TO EXPLOIT THE UNITED STATES SECURITIES MARKETS
42. In furtherance of the scheme to defraud, defendants MOGILEVICH,
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