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Justice Department's indictment of Semion Mogilevich

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THE GRAND JURY FURTHER CHARGES:<br />

NOTICE OF FORFEITURE<br />

(Racketeering Forfeiture - 18 U.S.C. § 1963)<br />

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

and Count One are incorporated by reference here.<br />

2. From in or about 1993, continuously thereafter, up to and including in or<br />

about September 1998, in the Eastern District <strong>of</strong> Pennsylvania and elsewhere, the 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 />

ANATOLY TSOURA<br />

violated Title 18, United States Code, Section 1962(d) as alleged in Count One. Upon conviction<br />

on Count One, each defendant shall forfeit to the United States any interest the defendant has<br />

acquired or maintained in violation <strong>of</strong> Title 18, United States Code, Section 1962; and any interest<br />

in, security <strong>of</strong>, claims against, and property and contractual rights affording a source <strong>of</strong> influence<br />

over, the Enterprise, which the defendant established, operated, controlled, conducted, and<br />

participated in the conduct <strong>of</strong>, in violation <strong>of</strong> Section 1962; and any property constituting and<br />

derived from proceeds, which the defendant obtained, directly or indirectly, from racketeering<br />

activity in violation <strong>of</strong> Section 1962, including but not limited to, at least the approximate sum <strong>of</strong><br />

$32.7 million in proceeds derived from the violation <strong>of</strong> Title 18, United States Code, Section<br />

1962(d) as alleged in Count One, and all interests and proceeds traceable thereto.<br />

3. The above-named defendants, and each <strong>of</strong> them, shall be jointly and severally liable<br />

83

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