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Justice Department's indictment of Semion Mogilevich

Justice Department's indictment of Semion Mogilevich

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THE GRAND JURY FURTHER CHARGES:<br />

COUNT THIRTY-FIVE<br />

(Money Laundering Conspiracy)<br />

1. Paragraphs 1 through 46 <strong>of</strong> the Introduction to this Superseding Indictment are<br />

incorporated by reference herein.<br />

2. From in or about May 1994, through in or about September 1998, in<br />

the Eastern District <strong>of</strong> Pennsylvania and elsewhere, defendants<br />

SEMION MOGILEVICH,<br />

a/k/a "Simeon Mogilevitch"<br />

a/k/a "Semjon Mogilevcs"<br />

a/k/a "Shimon Makhelwitsch"<br />

a/k/a "Seva"<br />

IGOR FISHERMAN,<br />

JACOB BOGATIN,<br />

a/k/a "Yakov"<br />

did unlawfully and knowingly conspire and agree together and with other persons known and<br />

unknown to the grand jury, to knowingly transport, transmit and transfer, and attempt to transport,<br />

transmit and transfer, monetary instruments and funds from places in the United States to and<br />

through places outside the United States, and to places in the United States from and through<br />

places outside the United States:<br />

(a) with the intent to promote the carrying on <strong>of</strong> specified unlawful activity, that<br />

is, mail fraud (Title 18, United States Code, Section 1341); wire fraud (Title<br />

18, United States Code, Section 1343); and securities fraud (Title 15,<br />

United States Code, Section 78j(b), 17 C.F.R., Section 240.10b-5), in<br />

violation <strong>of</strong> Title 18, United States Code, Sections 1956(a)(2)(A) and 2; and<br />

(b) knowing that the monetary instruments and funds involved in the<br />

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