Justice Department's indictment of Semion Mogilevich

THE GRAND JURY FURTHER CHARGES:
COUNT THIRTY
(Securities Fraud)
1. The allegations contained in Paragraphs 1 through 46 of the Introduction to
this Superseding Indictment are incorporated by reference herein.
2. From on or about July 27, 1994, up to and including on or about May 13,
1998, in the Eastern District of Pennsylvania and elsewhere, defendants
SEMION MOGILEVICH,
a/k/a "Simeon Mogilevitch"
a/k/a "Semjon Mogilevcs"
a/k/a "Shimon Makhelwitsch"
a/k/a "Seva"
IGOR FISHERMAN,
JACOB BOGATIN,
a/k/a "Yakov"
ANATOLY TSOURA
together with 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, used and employed manipulative and deceptive devices and contrivances, by
(a) employing devices, schemes, and artifices to defraud;
(b) making untrue statements of material facts and omitting to state material
facts necessary in order to make the statements made, in the light of the
circumstances under which they were made, not misleading; and
(c) engaging in acts, practices, and courses of business which operated and
would operate as a fraud and deceit upon a person, in connection with the
purchase and sale of Pratecs/YBM securities by the investing public.
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