Justice Department's indictment of Semion Mogilevich

THE GRAND JURY FURTHER CHARGES:
COUNT THIRTY-FOUR
(Falsification of Books and Records)
1. Paragraphs 1 through 46 of the Introduction to this Superseding Indictment
are hereby incorporated by reference herein.
2. From in or about the Fall of 1995 through in or about September 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
and others known and unknown to the grand jury, unlawfully, willfully, and knowingly, directly
and indirectly, falsified and caused to be falsified books, records, and accounts which, in reasonable
detail, would accurately and fairly reflect the transactions and disposition of the assets of YBM, by,
among other things, providing incomplete, inconsistent, contradictory and bogus documentation to
identify and support YBM's purported customer and vendor base; creating false financial records,
bank statements, invoices, customer lists, shipping documentation and audit confirms; and,
destroying wire transfer and other documents.
In violation of Title 15, United States Code, Sections 78m(b)(5), 78ff(a), 17 C.F.R.,
Section 240.13b2-1, and Title 18, United States Code, Section 2.
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