Justice Department's indictment of Semion Mogilevich

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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. 62
3. The defendants violated those provisions by committing the acts set forth in the scheme as discussed in the Introduction to this Superseding Indictment, including, among other things, making materially false and misleading statements about YBM's core business, its financial condition, and the ownership and control of the company. In violation of Title 15, United States Code, Sections 78j(b) and 78ff(a), 17 C.F.R. § 240.10b-5 and Title 18, United States Code, Section 2. 63
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IN THE UNITED STATES DISTRICT COURT
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operated businesses, described here
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Indictment, MOGILEVICH resided in B
Page 7 and 8:
The Network of YBM Companies YBM Ma
Page 9 and 10:
YBM Network of companies and did no
Page 11 and 12: ORIGON's bank account in Israel wer
Page 13 and 14: 25. The Toronto Stock Exchange (“
Page 15 and 16: Network of YBM companies, including
Page 17 and 18: company ARIGON between approximatel
Page 19 and 20: for stock in YBM MAGNEX. As a resul
Page 21 and 22: investors, recorded, and caused to
Page 23 and 24: UNITED TRADE had a diverse customer
Page 25 and 26: productive between September and De
Page 27 and 28: UNITED TRADE and MAGNEX RT to be ap
Page 29 and 30: ARBAT, ARIGON, and MAGNEX RT; (2) e
Page 31 and 32: (b) On or about November 20, 1997,
Page 33 and 34: 43. At various times during the sch
Page 35 and 36: listed: Defendant Amount (a) FISHER
Page 37 and 38: and investing money received from t
Page 39 and 40: The Scheme To Defraud 9. The defend
Page 41 and 42: circumstances under which they were
Page 43 and 44: Bank of Scotland, London, England (
Page 45 and 46: 18 1/26/97 Facsimile of false audit
Page 47 and 48: (ph# 215-579-5695) to FISHERMAN, in
Page 49 and 50: Solis-Cohen, 111 South 15 th Street
Page 51 and 52: Overt Act Date Description Transfer
Page 53 and 54: Overt Act Date Description Transfer
Page 55 and 56: COUNTS TWO THROUGH TWENTY-THREE (Wi
Page 57 and 58: 8 7/2/97 Facsimile of false “sale
Page 59 and 60: 21 5/12/98 4:50 p.m. 22 5/13/98 9:1
Page 61: Count 24 Date 3/5/95 Description Fa
Page 65 and 66: COUNT THIRTY-TWO (Filing False Repo
Page 67 and 68: THE GRAND JURY FURTHER CHARGES: COU
Page 69 and 70: transportation, transmission and tr
Page 71 and 72: 10/28/96 Proceeds totaling approx.
Page 73 and 74: Date Description Transferred from T
Page 75 and 76: Date(s) Description Sold & Transfer
Page 78 and 79: COUNTS THIRTY-SIX THROUGH THIRTY-NI
Page 80: COUNTS FORTY THROUGH FORTY-FIVE (Mo
Page 83 and 84: THE GRAND JURY FURTHER CHARGES: NOT
Page 85 and 86: NOTICE OF FORFEITURE (Money Launder
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Justice Department's indictment of Semion Mogilevich

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