Justice Department's indictment of Semion Mogilevich

FISHERMAN.
(b) The Arion Investment Club ("Arion") was established at First
Marathon Securities in or about May 1996. Proceeds derived from the sales of YBM stock
through Arion totaled approximately $12 million, which monies were concealed in foreign bank
accounts held in the name of an unindicted co-conspirator, a close associate of defendant
MOGILEVICH.
(c) In or about March 1996, defendant BOGATIN, at the direction and
with the assistance of defendants MOGILEVICH and FISHERMAN, opened approximately 48
brokerage accounts at Dean Witter Reynolds located in the Eastern District of Pennsylvania
(“Dean Witter Accounts") over which BOGATIN held power of attorney. One of these accounts
was called the Poseidon Investment Club (“PIC”), a stock investment club which traded
exclusively YBM stock. There were approximately 30 members of PIC, the membership of which
was limited to defendants MOGILEVICH and FISHERMAN, the ARIGON shareholders, and
nominees controlled by the defendants. Through his power of attorney, defendant BOGATIN
managed and coordinated the trading in the Dean Witter accounts on behalf of himself, the other
defendants MOGILEVICH, FISHERMAN, and TSOURA, and their nominees. Proceeds derived
from the sales of YBM stock through the Dean Witter accounts totaled approximately $1.9
million.
Salaries and other compensation
46. In addition to the millions of dollars of stock profits the defendants took
from YBM, the following defendants further benefitted from the scheme to defraud described
herein, by taking salary, bonuses and other compensation totaling the approximate amounts
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