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(1) List the predicate acts and specific statutes which were violated:
Due to the nature of the Illegal Scheme, Plaintiff does not have complete knowledge of all predicate acts committed by Defendants, absent discovery. Plaintiff reserves the right to amend this statement after discovery.
- Extortion and Attempted Extortion in violation 18 U.S.C. §1951;
- The Corrupt Kondpetroleum Bankruptcy was used to extort economic benefits from Sidanco’s shareholders, including BP-Amoco and Kantupan.
- The Corrupt Chernogorneft Bankruptcy was used to extort economic benefits from Sidanco’s shareholders, including BP-Amoco and Kantupan, and from Yugraneft.
- The Corrupt NNZ Bankruptcy was used to extort economic benefits from Yugraneft.
- Khan threatened Rotzang in November, 1999.
- Khan threatened Kondrashina at the August, 2000 meeting in order to extort concessions from Yugraneft.
- Khan threatened Kondrashina at the January, 2001 meeting in order to extort concessions from Yugraneft.
- Khan threatened Kondrashina at the June, 2001 meeting in order to extort concessions from Yugraneft.
- TNK took over Yugraneft in June and July, 2001 through physical force and the threat of physical harm.
- TNK threatened Radov on August 1, 2001.
- Nam threatened Kondrashina in August, 2001.
- TNK threatened Thimoskin in August, 2001.
- Belevtsov threatened Thimoskin in August, 2001.
- TNK obtained control over Yugraneft through extortion as reflected by the threat of the armed thugs.
- Mail and Wire Fraud in violation of 18 U.S.C. §§1341 and 1343:
Wiring funds through banks in the United States in order to bribe Russian government officials involved in the Corrupt 1997 TNK Privatization, the Corrupt 1999 TNK Privatization, the Corrupt NNG Proceedings, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, and the Illegal Takeover of Yugraneft;
Telephone, telefax, and mail communications between persons and entities located in the United States, such as Access, Renova, Blavatnik, Vekselberg, and Crown Resources (USA) Inc. on the one hand, and persons located outside of the United States on the other hand in order to effect the Illegal Scheme, including the Corrupt 1997 TNK Privatization, the Corrupt 1999 TNK Privatization, the Corrupt Nizhnevartovsk Nefte Gaz Takeover and Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Nizhnevartovsk Nefte Gaz Bankruptcy, the Corrupt Chernogorneft Bankruptcy, and the Illegal Takeover of Yugraneft through fraudulent representations and the threat of physical force.
Wiring millions of dollars through banks in the United States in order to purchase a 40% interest in TNK through the rigged auction in 1997 in the Corrupt 1997 TNK Privatization.
Wiring millions of dollars through banks in the United States in order to purchase the remaining interest of TNK through the rigged auction in 1999 in the Corrupt 1999 TNK Privatization.
Wiring millions of dollars through banks in the United States obtained through the sale of oil of Kondpetroleum through the Corrupt Kondpetroleum Bankruptcy in 1998 and 1999.
Wiring millions of dollars through banks in the United States in order to purchase the assets of Kondpetroleum through the Corrupt Kondpetroleum Bankruptcy in 1999.
Wiring millions of dollars through banks in the United States obtained through the sale of oil of Chernogorneft through the Corrupt Chernogorneft Bankruptcy in 1998 and 1999.
Wiring approximately $15 million through banks in the United States in order to repay the Ex-Im Bank loan in 1999 as part of the successful effort to takeover Chernogorneft thorough the Corrupt Chernogorneft Bankruptcy.
Wiring millions of dollars through banks in the United States in order to purchase the assets of Chernogorneft through the Corrupt Chernogorneft bankruptcy in 1999.
Wiring millions of dollars through banks in the United States in order to make payments from the Crown Group to the Slush Fund Companies as part of the Massive Tax Fraud and in order to create a slush fund to bribe Russian government officials.
Wiring millions of dollars through banks in the United States in order to make payments from the Slush Fund Companies to Futura, as part of the Massive Tax Fraud.
Wiring millions of dollars through banks in the United States from the sale of Yugraneft oil after the Illegal Takeover.
Wiring millions of dollars through banks in the United States from the illegal conversion of dollar denominated bank deposits and debentures of Yugraneft after the Illegal Takeover.
Specific wires of monies to the Slush Fund Companies through banks in the United States took place on or about the following dates and involved the below amount of funds:
| DATE | FROM | TO | AMOUNT in US$ |
| January 14, 1999 | Crown Trade and Finance Ltd. | Freebow Investment Ltd. | 83,600.00 |
| February 15, 1999 | Crown Trade and Finance Ltd. | Freebow Investment Ltd. | 45,000.00 |
| February 15, 1999 | Crown Trade and Finance Ltd. | Scorpio Resources | 55,000.00 |
| March 24, 1999 | Crown Trade and Finance Ltd. | Arufa Investment and Trade S.A. | 3,000,000.00 |
| June 14, 1999 | Crown Trade and Finance Ltd. | Riverside Cay Ltd. | 2,160,123.00 |
| July 16, 1999 | Crown Trade and Finance Ltd. | Riverside Cay Ltd. | 547,206.00 |
| July 23, 1999 | Crown Trade and Finance Ltd. | Riverside Cay Ltd. | 27,000.00 |
| August 19, 1999 | Crown Trade and Finance Ltd. | Riverside Cay Ltd. | 509,258.00 |
| December 16, 1999 | Crown Trade and Finance Ltd. | Redwood Trading Inc. | 6,000,000.00 |
| February 14, 2000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 6,711,918.56 |
| June 30, 2000 | Crown Trade and Finance Ltd. | LT Enterprise | 3,319,176.44 |
| July 4, 2000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 3,320,000.00 |
| July 7, 2000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 3,321,354.00 |
| July 1, 2000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 4,606,010.53 |
| July 2, 2000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 4,439,547.92 |
| August 30, 2000 | Crown Trade and Finance Ltd. | LT Enterprise Limited | 5,745,394.11 |
| September 4, 2000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 3,923,907.15 |
| September 26, 2000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 3,646,846.84 |
| September 29, 2000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 3,961,700.00 |
| October 2, 2000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 4,000,017.45 |
| October 24, 20000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 3,290,760.21 |
| October 25, 2000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 3,780,001.67 |
| October 26, 2000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 3,706,700.00 |
| November 13, 2000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 2,570,156.29 |
| December 18, 2000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 3,156.89 |
| December 15, 2000 | Crown Trade and Finance Ltd. | LT Enterprise
Limited | 877,982.71 |
- Money Laundering in violation of 18 U.S.C. §1957:
- As part of the Illegal Scheme, the proceeds of the sale of oil from Kondpetroleum, Chernogorneft, NNG and TNK were laundered through the Crown Group through the payment of false invoices to the Slush Fund Companies in dollar denominated wires through banks in the United States as part of the Massive Tax Fraud scheme and in order to create a slush fund to bribe Russian government officials.
- After the Illegal Takeover, the proceeds of the sale of oil from Yugraneft were laundered through the sale of Yugraneft’s oil in the domestic market through TNK and the international market through the Crown Group in dollar denominated wire transfers through banks in the United States so that Defendants could appropriate the assets of Yugraneft.
- Upon information and belief, some of the profits of these proceeds were laundered through the Slush Fund Companies as part of the Massive Tax Fraud scheme and in order to create a slush fund to bribe Russian government officials.
- The predicate acts of money laundering of the Illegal Scheme were in furtherance of the following actual or attempted acts of specified unlawful activity: bribery, extortion, mail and wire fraud, illegal transactions in monetary instruments, and Travel Act violations, as alleged herein.
- Specific wires of laundered funds through banks in the United States took place as set forth above.
- Illegal Transactions in Monetary Instruments in violation of 18 U.S.C. §1956:
- Proceeds obtained from the sale of oil of NNG, Kondpetroleum, and Chernogorneft, pursuant to the Illegal Scheme constitute “criminally derived property” in excess of $10,000 and were wired through banks in the United States.
- Proceeds obtained from the sale of oil obtained from Yugraneft pursuant to the Illegal Scheme constitute “criminally derived property” in excess of $10,000 and were wired through banks in the United States.
- Proceeds obtained from the conversion of Yugraneft’s dollar denominated bank deposits and debentures pursuant to the Illegal Scheme constitute “criminally derived property” in excess of $10,000 and were wired through banks in the United States.
- Some of these proceeds were laundered through the Slush Fund Companies as part of the Massive Tax Fraud scheme and in order to create a slush fund to bribe Russian government officials.
- The predicate acts of illegal transactions in monetary instruments of the Illegal Scheme were in furtherance of the following actual or attempted acts of specified unlawful activity: bribery, extortion, mail and wire fraud, money laundering, and interstate and foreign travel, as alleged herein.
- Specific wires of laundered funds through banks in the United States took place as set forth above.
- Interstate and Foreign Travel in violation of 18 U.S.C. §1952:
- In order to effect the Illegal Scheme, including the Corrupt 1997 TNK Privatization, the Corrupt 1999 TNK Privatization, the Corrupt Nizhnevartovsk Nefte Gaz Bankruptcy, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, and the Illegal Takeover of Yugraneft, various Defendants and their agents traveled to and from the United States to Russia, including Blavatnik, Vekselberg, Kukes, Bakaleynik, Khan, and Spitz, from 1997 through the filing of the instant action.
- The predicate acts of interstate and foreign travel in aid of racketeering of Illegal Scheme were in furtherance of the following actual or attempted acts of unlawful activity: bribery, extortion, money laundering, illegal transactions in monetary instruments, and mail and wire fraud, as alleged herein.
- Bribery as part of the scheme and artifice to defraud in violation of N.Y.C.L.S. Penal §20 and §180.03 based on the conduct of Blavatnik, Vekselberg and others in New York in organizing and implementing the bribery scheme and the wiring of funds through banks in New York in order to effect the bribing of Russian government officials:
- Upon information and belief, Russian government officials were bribed in order to obtain their cooperation in the Corrupt 1997 TNK Privatization, the Corrupt 1999 TNK Privatization, the Corrupt Kondpetroleum Bankruptcy, the Corrupt Chernogorneft Bankruptcy, the Corrupt Nizhnevartovsk Nefte Gaz Bankruptcy and Reorganization, and the Illegal Takeover of Yugraneft.
- Khan attempted to bribe Kondrashina at the August, 2000 meeting.
- Khan attempted to bribe Kondrashina at the June, 2001 meeting.
- Nam attempted to bribe Kondrashina at the August, 2001 meeting.
- TNK attempted to bribe Timoskin at the August, 2001 meeting.
- Belevtsov attempted to bribe Timoskin at the August, 2001 meeting.
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