Justice Department's indictment of Semion Mogilevich

payment of expenses associated with the operation of the scheme; (ii) the
purchase of large blocks of PRATECS/YBM stock, by the defendants and
others, to insure a controlling interest in YBM and to profit from the sale
of YBM stock; and (iii) the creation of the false and fraudulent appearance
of commercial activity on YBM's books and records.
Mailings
11. The defendants, and others known and unknown to the grand jury, for the
purpose of executing the scheme to defraud caused, and attempted to cause, certain matters and
things to be sent and delivered, to and from the Eastern District of Pennsylvania, by the United
States Postal Service and by private and commercial interstate carriers. These items included, but
were not limited to, materially false and fictitious statements of YBM's financial condition and
business operations, audit confirmations, correspondence and filings with the ASC, ASE, OSC,
TSE, SEC and NASDAQ.
Securities Transactions
(Fraud in Connection with the Purchase and Sale of YBM Securities)
12. The defendants, and others known and unknown to the grand jury,
unlawfully, willfully, and knowingly, by the use of the means and instrumentalities of interstate
commerce and of the mails, directly and indirectly, in connection with the purchase and sale of
YBM securities:
(a) employed devices, schemes, and artifices to defraud;
(b) made untrue statements of material facts and omitted to state material facts
necessary in order to make the statements made, in the light of the
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