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ALFA GROUP
1. Alfa Group Consortium (“Alfa Group”)
Alpha Group is an unincorporated association of various affiliated companies set forth below. The Alfa Group consists of Crown Finance Foundation; CTF Holdings Ltd; Alfa Finance Holdings, SA; Crown Luxembourg Holdings SA, OAO Alfa Bank; Alfa Capital Markets (USA), Inc; Crown Commodities Ltd; Crown Trade and Finance Limited; Crown Resources, AG; Crown Resources (USA), Inc.; OOO Alfa-Eco ; and various other related companies whose identities are yet to be determined.
The Predicate Acts
Alpha Group through its affiliated companies and its officers and directors, including American John Irving, German Khan, Alexey Kuzmichev, Dimitry Plouznikov, Vladimir Plouznikov, and American Elliot Spitz, and through its control of TNK and other companies, committed specific predicate acts of racketeering in furtherance of the Illegal Scheme. These included:
· - Mail and Wire Fraud: Alpha Group, by and through its officers and directors, was managed, directed, and controlled and managed, directed, and controlled various other companies, such as TNK, through the use of mail and wires, including telephone calls made from the United States to Russia and other places, to bribe Russian government officials in order to effect the Illegal Scheme;
· - Wire Fraud: Alpha Group, by and through its officers and directors, managed, directed, and controlled the “Slush Fund Companies,” such as Eastmount, LT and Sandwell, which wired funds through banks in the United States to bribe Russian government officials as part of the Illegal Scheme;
· - Money Laundering: Alpha Group, by and through its officers and directors, was managed, directed, and controlled and managed, directed, and controlled the Slush Fund Companies which engaged in money laundering of the proceeds of the sale of petroleum from Chernogorneft, NNG, Kondpetroleum, and Yugraneft in furtherance of specified unlawful activity (i.e. bribery, extortion, mail and wire fraud, illegal transactions in monetary instruments, and Travel Act violations);
· - Illegal Transactions in Monetary Instruments: Alpha Group, by and through its officers and directors, was managed, directed, and controlled and managed, directed, and controlled of the wiring of proceeds constituting “criminally derived property” from the sale of oil of NNG, Kondpetroleum, Chernogorneft, and Yugraneft through banks in the United States;
· - Travel Act Violations: Alpha Group, by and through its officers and directors, traveled from the United States to Russia and back in aid of the racketeering of the Illegal Scheme.
· - Bribery: Upon information and belief Alpha Group, by and through its officers and directors, facilitated, controlled, directed and intentionally aided the bribery of Russian government officials in order to effect the Illegal Scheme in violation of N.Y.C.L.S. Penal §20 and §180.03;
Violation of 1961(a)
Alpha Group, through a pattern of racketeering, received income as a result of the Corrupt 1997 TNK Privatization and Corrupt 1999 TNK Privatization, the Corrupt NNG Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud which was effected through bribery, mail and wire fraud, economic extortion, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act. Such income included shares in TNK obtained through the Corrupt 1997 TNK Privatization and the 1999 Corrupt TNK Privatization, assets of NNG, Kondpetroleum, and Chernogorneft obtained through the Corrupt NNG Takeover and Bankruptcy and the Corrupt Kondpetroleum and Chernogorneft Bankruptcies, and funds obtained through each of these schemes. Such income also included shares in Yugraneft which were obtained through the Corrupt Chernogorneft Bankruptcy.
A part of such income or its proceeds, and specifically including the shares of Yugraneft, were used, directly or indirectly, to acquire an interest in Yugraneft and to operate Yugraneft through the Illegal Takeover.
Violation of 1961(b)
Alpha Group, through a pattern of racketeering which included bribery, extortion, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act acquired and maintained, directly or indirectly, an interest and control of Yugraneft.
Violation of 1961(c)
Alpha Group, conducted and participated in the conduct of the Access/Alfa/Astons Enterprise (association in fact), the Crown Enterprise, the TNK Enterprise, the Slush Fund Enterprise, the NNG, the Kondpetroleum Enterprise, the Chernogorneft Enterprise and the Yugraneft Enterprise through a pattern of racketeering activity including bribery, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act in regard to the Corrupt 1997 TNK Privatization, the Corrupt 1999 TNK Privatization, the Corrupt NNG Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud and the Illegal Takeover of Yugraneft.
Violation of 1961(d)
Alpha Group conspired with other defendants to undertake and consummate the Illegal Scheme.
1. Crown Finance Foundation (“CFF”)
CFF is a “foundation” (similar to a business trust) organized under the laws of Liechtenstein, a country known for its bank secrecy laws. Upon information and belief, the beneficial owners and controlling persons of CFF are Russian oligarch Mikhail Fridman (“Fridman”), Alexey Kuzmichev (“Kuzmichev”), and German Khan (“Khan”).
CFF controls CTF Holdings which controls holding companies such as Alfa Finance Holdings S.A., and Crown Luxembourg Holdings, S.A. which in turn control various operating subsidiaries such as TNK.
The Predicate Acts
CFF, through Khan and Kuzmichev, committed specific predicate acts of racketeering in furtherance of the Illegal Scheme. These included:
· - Mail and Wire Fraud: CFF, through Khan and Kuzmichev, was managed, directed, and controlled and managed, directed, and controlled its subsidiaries, such as TNK, through the use of mail and wires, including telephone calls made from the United States to Russia and other places, to bribe Russian government officials in order to effect the Illegal Scheme;
· - Wire Fraud: CFF, through Khan and Kuzmichev, managed, directed, and controlled the “Slush Fund Companies,” such as Eastmount, LT and Sandwell, which wired funds through banks in the United States to bribe Russian government officials as part of the Illegal Scheme;
· - Money Laundering: CFF, through Khan and Kuzmichev, was managed, directed, and controlled and managed, directed, and controlled the Slush Fund Companies which engaged in money laundering of the proceeds of the sale of petroleum from Chernogorneft, NNG, Kondpetroleum, and Yugraneft in furtherance of specified unlawful activity (i.e. bribery, extortion, mail and wire fraud, illegal transactions in monetary instruments, and Travel Act violations);
· - Illegal Transactions in Monetary Instruments: CFF, through Khan and Kuzmichev, was managed, directed, and controlled and managed, directed, and controlled of the wiring of proceeds constituting “criminally derived property” from the sale of oil of NNG, Kondpetroleum, Chernogorneft, and Yugraneft through banks in the United States;
· - Travel Act Violations: CFF, through Khan and Kuzmichev, traveled from the United States to Russia and back in aid of the racketeering of the Illegal Scheme.
· - Bribery: Upon information and belief, CFF, through Khan and Kuzmichev, facilitated, controlled, directed and intentionally aided the bribery of Russian government officials in order to effect the Illegal Scheme in violation of N.Y.C.L.S. Penal §20 and §180.03;
Violation of 1961(a)
CFF, through a pattern of racketeering, received income as a result of the Corrupt 1997 TNK Privatization and Corrupt 1999 TNK Privatization, the Corrupt NNG Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud which was effected through bribery, mail and wire fraud, economic extortion, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act. Such income included shares in TNK obtained through the Corrupt 1997 TNK Privatization and the 1999 Corrupt TNK Privatization, assets of NNG, Kondpetroleum, and Chernogorneft obtained through the Corrupt NNG Takeover and Bankruptcy, Corrupt Kondpetroleum, and Chernogorneft Bankruptcies, and funds obtained through each of these schemes. Such income also included shares in Yugraneft which were obtained through the Corrupt Chernogorneft Bankruptcy
A part of such income or its proceeds, and specifically including the shares of Yugraneft, were used, directly or indirectly, to acquire an interest in Yugraneft and to operate Yugraneft through the Illegal Takeover.
Violation of 1961(b)
CFF, through a pattern of racketeering which included bribery, extortion, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act acquired and maintained, directly or indirectly, an interest and control of Yugraneft.
Violation of 1961(c)
CFF, conducted and participated in the conduct of the Access/Alfa/Astons Enterprise (association in fact), the Crown Enterprise, the TNK Enterprise, the Slush Fund Enterprise, the NNG, the Kondpetroleum Enterprise, the Chernogorneft Enterprise and the Yugraneft Enterprise through a pattern of racketeering activity including bribery, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act in regard to the Corrupt 1997 TNK Privatization, the Corrupt 1999 TNK Privatization, the Corrupt NNG Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud and the Illegal Takeover of Yugraneft.
Violation of 1961(d)
CFF, through Kuzmichev and Khan, conspired with other defendants to undertake and consummate the Illegal Scheme.
2. CTF Holdings Ltd (“CTF Holdings”)
CTF Holdings, a company organized under the laws of Gibraltar, is owned and controlled by CFF, and controls various holding companies such as Alfa Finance Holdings S.A., and Crown Luxembourg Holdings, S.A. which in turn control various operating subsidiaries such as TNK . Upon information and belief, the beneficial owners and controlling persons of CTF Holdings are Fridman, Kuzmichev, and Khan. David Gould is a director of CTF Holdings and a citizen of the United States.
The Predicate Acts
CTF Holdings, through Kuzmichev and Khan, committed specific predicate acts of racketeering in furtherance of the Illegal Scheme. These included:
· - Mail and Wire Fraud: CTF Holdings, through Kuzmichev and Khan, was managed, directed, and controlled and managed, directed, and controlled its subsidiaries, such as TNK, through the use of mail and wires, including telephone calls made from the United States to Russia and other places, to bribe Russian government officials in order to effect the Illegal Scheme;
· - Wire Fraud: CTF Holdings, through Kuzmichev and Khan, managed, directed, and controlled the “Slush Fund Companies,” such as Eastmount, LT and Sandwell, which wired funds through banks in the United States to bribe Russian government officials as part of the Illegal Scheme;
· - Money Laundering: CTF Holdings, through Kuzmichev and Khan, was managed, directed, and controlled and managed, directed, and controlled the Slush Fund Companies which engaged in money laundering of the proceeds of the sale of petroleum from Chernogorneft, NNG, Kondpetroleum, and Yugraneft in furtherance of specified unlawful activity (i.e. bribery, extortion, mail and wire fraud, illegal transactions in monetary instruments, and Travel Act violations);
· - Illegal Transactions in Monetary Instruments: CTF Holdings, through Kuzmichev and Khan, was managed, directed, and controlled and managed, directed, and controlled of the wiring of proceeds constituting “criminally derived property” from the sale of oil of NNG, Kondpetroleum, Chernogorneft, and Yugraneft through banks in the United States;
· - Travel Act Violations: CTF Holdings, through Kuzmichev and Khan, traveled from the United States to Russia and back in aid of the racketeering of the Illegal Scheme.
· - Bribery: Upon information and belief, CTF Holdings, through Kuzmichev and Khan, facilitated, controlled, directed and intentionally aided the bribery of Russian government officials in order to effect the Illegal Scheme in violation of N.Y.C.L.S. Penal §20 and §180.03;
Violation of 1961(a)
CTF Holdings, through a pattern of racketeering, received income as a result of the Corrupt 1997 TNK Privatization and Corrupt 1999 TNK Privatization, the Corrupt NNG Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud which was effected through bribery, mail and wire fraud, economic extortion, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act. Such income included shares in TNK obtained through the Corrupt 1997 TNK Privatization and the 1999 Corrupt TNK Privatization, assets of NNG, Kondpetroleum, and Chernogorneft obtained through the Corrupt NNG Takeover and Bankruptcy, Corrupt Kondpetroleum, and Chernogorneft Bankruptcies, and funds obtained through each of these schemes. Such income also included shares in Yugraneft which were obtained through the Corrupt Chernogorneft Bankruptcy.
A part of such income or its proceeds, and specifically including the shares of Yugraneft, were used, directly or indirectly, to acquire an interest in Yugraneft and to operate Yugraneft through the Illegal Takeover.
Violation of 1961(b)
CTF Holdings, through a pattern of racketeering which included bribery, extortion, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act acquired and maintained, directly or indirectly, an interest and control of Yugraneft.
Violation of 1961(c)
CTF Holdings, through Kuzmichev and Khan, conducted and participated in the conduct of the Access/Alfa/Astons Enterprise (association in fact) the Crown Enterprise, the TNK Enterprise, the Slush Fund Enterprise, and the Crown Enterprise, the NNG, the Kondpetroleum Enterprise, the Chernogorneft Enterprise and the Yugraneft Enterprise through a pattern of racketeering activity including bribery, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act in regard to the Corrupt 1997 TNK Privatization, the Corrupt 1999 TNK Privatization, the Corrupt NNG Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud and the Illegal Takeover of Yugraneft.
Violation of 1961(d)
CTF Holdings, through Kuzmichev and Khan, conspired with other defendants to undertake and consummate the Illegal Scheme.
1. Alfa Finance Holdings, SA (“Alfa Finance”)
Alfa Finance, a company organized under the laws of Luxembourg, is owned and controlled by CTF Holdings. Upon information and belief, its beneficial owners and controlling persons are Fridman, Kuzmichev, and Khan. David Gould, Alexander Knaster and Alexander Tolchinsky are directors of Alfa Finance and citizens of the United States.
Alfa Finance is a holding company that owns the banking, financial, and industrial divisions of the Alfa Group including TNK.
The Predicate Acts
· - Mail and Wire Fraud: Alfa Finance, through Kuzmichev and Kahn, was managed, directed, and controlled and managed, directed, and controlled its subsidiaries, such as TNK, through the use of mail and wires, including telephone calls made from the United States to Russia and other places, to bribe Russian government officials in order to effect the Illegal Scheme;
· - Wire Fraud: Alfa Finance, through Kuzmichev and Kahn, managed, directed, and controlled the “Slush Fund Companies,” such as Eastmount, LT and Sandwell, which wired funds through banks in the United States to bribe Russian government officials as part of the Illegal Scheme;
· - Money Laundering: Alfa Finance, through Kuzmichev and Kahn, was managed, directed, and controlled and managed, directed, and controlled the sale of petroleum from Chernogorneft, NNG, Kondpetroleum, and Yugraneft in furtherance of specified unlawful activity (i.e. bribery, extortion, mail and wire fraud, illegal transactions in monetary instruments, and Travel Act violations);
· - Illegal Transactions in Monetary Instruments: Alfa Finance, through Kuzmichev and Kahn, was managed, directed, and controlled and managed, directed, and controlled of the wiring of proceeds constituting “criminally derived property” from the sale of oil of NNG, Kondpetroleum, Chernogorneft, and Yugraneft through banks in the United States;
· - Travel Act Violations: Alfa Finance, through Kuzmichev and Kahn, traveled from the United States to Russia and back in aid of the racketeering of the Illegal Scheme.
· - Bribery: Upon information and belief, Alfa Finance, through Kuzmichev and Kahn, facilitated, controlled, directed and intentionally aided the bribery of Russian government officials in order to effect the Illegal Scheme in violation of N.Y.C.L.S. Penal §20 and §180.03;
Violation of 1961(a)
Alpha Finance, through a pattern of racketeering received income as a result of the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud which was effected through bribery, mail and wire fraud, economic extortion, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act. Such income included shares in TNK obtained through the Corrupt 1997 TNK Privatization and the 1999 Corrupt TNK Privatization, assets of NNG, Kondpetroleum, and Chernogorneft obtained the Corrupt NNG Takeover and Bankruptcy, Corrupt Kondpetroleum and Chernogorneft Bankruptcies, and funds obtained through each of these schemes. Such income also included shares in Yugraneft which were obtained through the Corrupt Chernogorneft Bankruptcy
A part of such income or its proceeds, including specifically the shares of Yugraneft, were used, directly or indirectly, to acquire an interest in Yugraneft and to operate Yugraneft through the Illegal Takeover.
Violation of 1961(b)
Alpha Finance, through a pattern of racketeering which included bribery, extortion, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act acquired and maintained, directly or indirectly, an interest and control of Yugraneft.
Violation of 1961(c)
Alpha Finance, through Kuzmichev and Kahn, conducted and participated in the conduct of the Access/Alfa/Astons Enterprise (association in fact), the TNK Enterprise, the Slush Fund Enterprise, the NNG, the Kondepetroleum Enterprise, the Chernogorneft Enterprise and the Yugraneft Enterprise through a pattern of racketeering activity including bribery, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act in regard to the Corrupt 1997 TNK Privatization, the Corrupt 1999 TNK Privatization, the Corrupt NNG Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud and the Illegal Takeover of Yugraneft.
Violation of 1961(d)
Alpha Finance, through Kuzmichev and Kahn, conspired with other defendants to undertake and consummate the Illegal Scheme.
2. Crown Luxembourg Holdings, S.A. (“Crown Luxembourg”)
Crown Luxembourg is owned and controlled, directly or indirectly by CTF Holdings. Upon information and belief, the beneficial owners and controlling persons of Crown Luxembourg are Fridman, Khan, and Kuzmichev. Crown Luxembourg is the holding company that owns the trading division of the Alpha Group such as Crown Trade and Finance Limited and Crown Resources AG.
The Predicate Acts
Crown Luxembourg, through Kuzmichev and Khan, committed specific predicate acts of racketeering in furtherance of the Illegal Scheme. These included:
· - Mail and Wire Fraud: Crown Luxembourg, through Kuzmichev and Kahn was managed, directed, and controlled and managed, directed and controlled its subsidiaries, such as TNK, through the use of mail and wires, including telephone calls made from the United States to Russia and other places, to bribe Russian government officials in order to effect the Illegal Scheme;
· - Wire Fraud: Crown Luxembourg, through Kuzmichev and Khan, managed, directed, and controlled the “Slush Fund Companies,” such as Eastmount, LT and Sandwell, which wired funds through banks in the United States to bribe Russian government officials as part of the Illegal Scheme;
· - Money Laundering: Crown Luxembourg, through Kuzmichev and Khan, was managed, directed, and controlled and managed, directed, and controlled the Slush Fund Companies which engaged in money laundering of the proceeds of the sale of petroleum from Chernogorneft, NNG, Kondpetroleum, and Yugraneft in furtherance of specified unlawful activity (i.e. bribery, extortion, mail and wire fraud, illegal transactions in monetary instruments, and Travel Act violations);
· - Illegal Transactions in Monetary Instruments: Crown Luxembourg, through Kuzmichev and Khan, was managed, directed, and controlled and managed, directed, and controlled of the wiring of proceeds constituting “criminally derived property” from the sale of oil of NNG, Kondpetroleum, Chernogorneft, and Yugraneft through banks in the United States;
· - Travel Act Violations: Crown Luxembourg, through Khan and Kuzmichev, traveled from the United States to Russia in aid of the racketeering of the Illegal Scheme.
· - Bribery: Upon information and belief, Crown Luxembourg, through Khan and Kuzmichev, facilitated, controlled, directed and intentionally aided the bribery of Russian government officials in order to effect the Illegal Scheme in violation of N.Y.C.L.S. Penal §20 and §180.03;
Violation of 1961(a)
Crown Luxembourg, through a pattern of racketeering received income as a result of the Chernogorneft Bankruptcy, the Massive Tax Fraud which was effected through bribery, mail and wire fraud, economic extortion, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act. Such income included the proceeds of the sale of oil of NNG, Kondpetroleum, and Chernogorneft obtained through the Corrupt NNG Takeover and Bankruptcy and the Corrupt Kondpetroleum, and Chernogorneft Bankruptcies.
Upon information and belief, a part of such income or its proceeds were used, directly or indirectly, to acquire an interest in Yugraneft and to operate Yugraneft through the Illegal Takeover.
Violation of 1961(b)
Crown Luxembourg, through a pattern of racketeering which included bribery, extortion, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act acquired and maintained, directly or indirectly, an interest and control of Yugraneft.
Violation of 1961(c)
Crown Luxembourg, through Kuzmichev and Khan, conducted and participated in the conduct of the Access/Alfa/Astons Enterprise (association in fact), the Crown Enterprise, and the Slush Fund Enterprise through a pattern of racketeering activity including bribery, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act in regard to the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud and the Illegal Takeover of Yugraneft.
Violation of 1961(d)
Crown Luxembourg, through Kuzmichev and Khan, conspired with other defendants to undertake and consummate the Illegal Scheme.
3. Elliot Spitz (“Spitz”)
Spitz is a citizen of the United States who managed and operated the Crown Group which trades oil and other commodities and consists of Crown Commodities, Ltd., Crown Trade and Finance Ltd., Crown Resources, A.G., and Crown Resources (U.S.A.) Inc., a Delaware corporation.
The Predicate Acts
Spitz committed specific predicate acts of racketeering in furtherance of the Illegal Scheme. These included:
· - Mail and Wire Fraud: Spitz managed, directed, and controlled Crown Group and its subsidiaries through the use of mail and wires, including telephone calls made from the United States to Russia and other places, to bribe Russian government officials in order to effect the Illegal Scheme;
· - Wire Fraud: Spitz directed, and controlled the “Slush Fund Companies,” such as Eastmount, LT and Sandwell, which wired funds through banks in the United States to bribe Russian government officials as part of the Illegal Scheme;
· - Money Laundering: Spitz managed, directed, and controlled the Slush Fund Companies which engaged in money laundering of the proceeds of the sale of petroleum from Chernogorneft, NNG, Kondpetroleum, and Yugraneft in furtherance of specified unlawful activity (i.e. bribery, extortion, mail and wire fraud, illegal transactions in monetary instruments, and Travel Act violations);
· - Illegal Transactions in Monetary Instruments: Spitz managed, directed, and controlled the wiring of proceeds constituting “criminally derived property” from the sale of oil of NNG, Kondpetroleum, Chernogorneft, and Yugraneft through banks in the United States;
· - Travel Act Violations: Spitz traveled from the United States to England in aid of the racketeering of the Illegal Scheme.
· - Bribery: Upon information and belief, Spitz facilitated, controlled, directed and intentionally aided the bribery of Russian government officials in order to effect the Illegal Scheme in violation of N.Y.C.L.S. Penal §20 and §180.03;
Violation of 1961(c)
Spitz, conducted and participated in the conduct of the Access/Alfa/Astons Enterprise (association in fact) the Crown Enterprise and the Slush Fund Enterprise through a pattern of racketeering activity including bribery, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act in regard to the Corrupt 1997 TNK Privatization, the Corrupt 1999 TNK Privatization, the Corrupt NNG Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Massive Tax Fraud and the Illegal Takeover
Violation of 1961(d)
Spitz conspired with other defendants, and with others, to undertake and consummate the Illegal Scheme.
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