Justice Department's indictment of Semion Mogilevich

COUNT THIRTY-TWO
(Filing False Report with the Securities and Exchange Commission)
THE GRAND JURY FURTHER CHARGES:
1. Paragraphs 1 through 46 of the Introduction to this Superseding Indictment
are incorporated by reference herein.
and elsewhere, defendants
2. On or about November 27, 1996, in the Eastern District of Pennsylvania
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
willfully and knowingly caused, and aided and abetted, the filing by YBM of an SEC Form 6-K (A
Report of Foreign Issuer), which contained statements of material fact that were false and
misleading and that failed to contain material information necessary to make the required
statements, in light of the circumstances under which they were made, not misleading, in that YBM
reported, among other things, that its net sales for the nine-month period ending September 30,
1996, were approximately $64 million, which were generated primarily from its core business, the
sale of magnets, when the defendants well knew that YBM's net sales were materially
misrepresented as to the nature, the amount, and the geographic location of the sales
In violation of Title 15, United States Code, Sections 78m(a), 78ff(a) and 17 C.F.R.,
Sections 240.12b-20, 240.13a-1, 240.13a-3, 240.13a-16, and Title 18, United States Code,
Section 2.
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