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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT COURT OF DELAWARE ------------------------------------------------Davis International, LLC et al. Plaintiffs, -againstNew Start Group Corp, et al. Defendants. ------------------------------------------------DECLARATION OF ROBERT A. LEVINSON I, Robert A. Levinson, declare pursuant to the provisions of 28 U.S.C. §1746, as follows: INTRODUCTION 1. In this declaration, I set forth my knowledge of Vyacheslav Kirillovich Ivankov, also known as Yaponchik ("Ivankov"), a prominent figure in Russian organized crime. 2. Ivankov is a professional criminal and organized crime boss running his own criminal organization engaged in extortion, murders, drug smuggling, and racketeering. 3. Ivankov was charged in Russia with killing of two Turkish nationals in a Moscow restaurant in January, 1992. 4. In July 1996, a jury in New York found Ivankov guilty on charges of extorting $3.5 million from Russian émigrés who owned an investment company in Manhattan. He was subsequently sentenced for nine years and eight months. 5. Ivankov was involved in the threats on the lives of law enforcement agents and witnesses even when he was under trial in the United States. One of the Russian law No. 44-1482-GMS

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enforcement officers, Major Uporov became so concerned about his and his family safety that he moved to Switzerland. 6. Ivankov's criminal organization is connected with the organization formerly headed by late Anton Malevskiy also known as "Antoha," who protected interests of Mikahil Chernoi, a defendant in this action. The representatives of the two organizations had at least one meeting in Atlantic City, New Jersey. 7. Ivankov was released from a federal correctional institution in July 2004 and deported back to Russia where he is presently in confinement awaiting trial. 8. Despite being confined, he has the ability to communicate with the outside world and instruct his lieutenants to make good on any threats he makes. In fact, some of the meetings of top Russian criminals take place in prisons where they are able to enter through bribery of the prison officials. 9. I believe that a person threatened by Ivankov must take such threats very seriously and take all necessary precautions including avoiding traveling to Russia. QUALIFICATIONS 10. I am the principal of my own investigative consulting firm, R.A. Levinson & Associates, Inc., and formerly served as the Managing Director in charge of the Miami offices of two international investigative consulting firms, Decision Strategies and SafirRosetti, LLC. 11. In each of these capacities, I directed worldwide investigations involving litigation support, the collection of business intelligence, due-diligence, product piracy, and threats to legitimate businesses.

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12. For at total of twenty-eight years, I was employed by the U.S. Department of Justice, serving for five and a half years (1970-1976) as a Special Agent with the Drug Enforcement Administration (DEA), in its New York and Denver field offices and also at DEA Headquarters in Washington, D.C.. 13. Subsequently, in February 1976, I transferred to the Federal Bureau of Investigation (FBI) and served that agency as a Special Agent in Los Angeles, New York and Miami until my retirement on March 31, 1998. 14. While with the government, I specialized in the investigation of international organized crime, international fraud, and money laundering activities. 15. I served as a representative of the U.S. on a number of international organized crime task forces attacking such problems as the Colombian drug cartels and the criminal groups operating in the former Soviet Union. 16. During my government service, I taught as a guest lecturer at the FBI Academy in Quantico, Virginia, the Royal Canadian Mounted Police (RCMP) Academy in Ottawa, Canada, the Foreign Service Institute in Arlington, Virginia and the International Law Enforcement Academy (ILEA) in Budapest, Hungary. 17. I appeared on numerous television programs concerning international organized crime and money laundering, including the Public Broadcasting Company's Frontline, the Canadian Broadcasting Company, the History Channel, Arts & Entertainment (A&E), British Broadcasting Company (BBC), and French television. 18. I am a Phi Beta Kappa graduate of the City College of New York. 19. The information which I provide herein comes as a product of my service as one of the FBI's principal specialists in the field of Russian/Eurasian organized crime

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during the period 1992 through 1998, and from investigations I conducted subsequent to my retirement from government service.

DISCUSSION Background 20. After the break up of the Soviet Union in the early 1990's, a number of Russian professional criminals, called "thieves-in-law" or "vory-v-zakone," together with other racketeers known as criminal authorities or "avtoritety," began organizing their small groups into larger criminal organizations. "Thieves-in-law" have been historically an important part of the Russian underworld and have their own strict "code of conduct." They can be identified by certain tattoo markings which have been extensively documented by investigators of the Russian Ministry of Interior. 21. Among the largest of these newly-formed organized crime gangs were groups called the "Solntsevskaya" or "Solntsevo" Organization, headed by Sergey Anatolyevich Mikhailov, also known as "Mihas," (with over one thousand members and associates), the "Izmailovskaya" or "Izmailovo' Organization, headed by Sergey Axenov ("Axenov"), also known as "Aksyon," and his partner, the late Anton Malevskiy also known as "Antoha," (also with over one thousand members and associates) as well as the Ivankov Organization, headed by a "vor-v-zakone" named Vyacheslav Kirillovich Ivankov also known as "Yaponchik" and "Yaponets." 22. Each of these organizations was further composed of a leadership structure and members who are organized into smaller groups, called "brigades" or "combat

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brigades" composed of sometimes as few as five or as many as fifty men each. These groups are headed by a "brigade leader" or "brigadier" whose allegiance is to the larger organization and who sees to it that organizational discipline is followed, and, oftentimes, that a percentage of the proceeds from the criminal activities of each member is put into a mutual assistance fund, called an "obshak." 23. There is a highly trusted person from each organization who is responsible for the maintenance and security of the "obshak." The "obshak" is utilized to 1) pay for attorneys' fees for any of the leaders or members who are arrested, 2) pay stipends to the family members of those members of the group who are jailed, and 3) pay for the services of assassins who may be needed to kill witnesses involved in the trials of members. Ivankov's Criminal Activities in Russia 24. Beginning in 1994, and utilizing a variety of investigative techniques, including the development of a network of confidential informants, Special Agents of the FBI, including myself, began conducting investigation into the activities of Ivankov. Furthermore, during 1995, while teaching investigative techniques in Europe, I had personal contact with investigators of the Russian Interior Ministry's Organized Crime Control Division who had conducted their own investigations of Ivankov and his organization. 25. What was learned through these sources and contacts with other investigators was that Ivankov was a longtime "thief-in-law," well respected in the Russian criminal underworld, and he was a member of its ruling body, the so-called "thieves council."

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26. Our investigation further determined as documented in published reports, that Ivankov has been convicted of criminal activities in Russia on three separate occasions. (See Exhibit 1.) Insofar as two of these are concerned, Ivankov was reportedly sentenced to a five year term of imprisonment sometime during the 1970's as a result of his involvement in a criminal gang headed by a boss named "Mongol." He was also reportedly convicted of involvement in violent robberies, another violation of the Russian criminal code, in 1981 and received a fourteen year sentence in a maximum security prison. This sentence was reduced and he was released in November 1991, after reportedly having given a bribe to a member of the Russian Supreme Court. 27. We also determined that Ivankov's organization in Russia was composed of

at least two (2) so-called "combat brigades" which were headed by two individuals we identified as Aleksey Petrov, also known as "Petrik," and Aleksandr Inshakov, also known as "Inshak." 28. In Russia, Ivankov's organization was involved in the extortion of legitimate businessmen, and collecting regular payments to "protect" enterprises such as large financial institutions and television advertising companies. This "protection" is part of a system known as the providing of "krisha," (literally, in Russian, a "roof") to insure that the person or enterprise is not threatened physically or economically by that particular criminal organization or other groups. 29. Ivankov's organization was closely allied with the Solntsevskaya Organization, identified earlier in this affidavit as headed by Sergey Anatolyevich Mikhailov also known as "Mihas," and much of this alliance had to do with the importation and distribution in Russia of multi-kilogram quantities of illegal drugs,

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including heroin. The individuals in the Solntsevskaya Organization with whom Ivankov's group worked included three other "thieves-in-law" identified as Dzhemal Konstantinovich Khachidze, Levan Ardzinba, and Beslan Djonova also known as "Beisik." 30. In addition, Ivankov's organization was allied with the Izmailovo Organization formerly headed by the late Anton Malevsky, also known as "Antoha." During the mid-1990's, I conducted an investigation into the penetration of the Russian television advertising industry, primarily in the wake of the March 1995 assassination of Ostankino Television executive Vladislav Listyev. 31. I and other agents of the FBI determined at that time that two separate Russian organized crime groups, the Solntsevskaya (headed by Ivankov) and Izmailovskaya (headed jointly by the late Malevskiy and his partner, Sergey Axenov also known as "Aksyon"), were literally controlling the Moscow television advertising revenue system and receiving percentages of the proceeds. The two individuals who were serving as the links between the television industry and the organized crime groups were Boris Zosimov and Sergey Lissovskiy. 32. Through Malevskiy, Ivankov was also connected with Mikhail Chernoy ("Chernoy"), a defendant in this action. Chernoy was traditionally "protected" by two entities. Outside of the Russian Federation, his activities were protected by the Solntsevskaya Organization, and in particular, Sergey Anatolyevich Mikhailov also known as "Mihas," and Mikhailov's second in command, Viktor Sergeyevich Averin, also known as "Avera." Within the Russian Federation, his activities (and those of his

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brother, Lev Chernoy also known as "Lova," were the province of the Malevskiy's Izmailovskaya Organization. 33. Representatives of Ivankov's and Malevskiy's organization also had meetings in the United States. As reported by the Ivankov's principal lieutenant, Leonid Abelis ("Abelis"), also known as "Shatera," who, upon being "turned" as a witness for the Government in the Ivankov case, stated that sometime prior to Ivankov's arrest in June 1995, Sergey Axenov, Malevskiy's partner traveled to the United States on a visit and had a meeting with Abelis in Atlantic City, New Jersey to discuss cooperation between two groups.

Ivankov's Criminal Activities in the United States 34. Information available to the FBI during the mid-1990's indicated that upon arrival into the United States from Russia in the mid-1990's, Ivankov began setting up a branch of his organization and began operating in both the United States and Canada. His principal lieutenant in the United States was an individual identified as Leonid Abelis ("Abelis") also known as "Shatera". His principal lieutenant in Canada was his brotherin-law, Vyacheslav Sliva, also known as "Slava," who was subsequently deported to Russia by Canadian authorities. 35. Ivankov's organization's income was derived from a number of sources: his group was implicated by sources to have been involved in the "gasoline tax scam" whereby so-called "daisy-chains" of petroleum handling companies were established with the specific intention of defrauding governmental tax authorities using non-existent or ghost companies to pay the gasoline taxes due.

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36. A primary source of the group's funds was the collection of "krisha" or protection money from wealthy Russian and Eurasian businessmen operating between North America and the former Soviet republics. In addition, the Ivankov organization organized the collection of, in effect, a "street tax" from Russian-born and Eastern European criminals who were operating their illegal enterprises in North America. Ivankov organization members fanned out across the United States and Canada identifying and then approaching these criminals saying that each now had to contribute to an "obshak" (mutual benefit fund ­ see ¶ 21 above) being collected and organized by the Ivankov group. 37. In addition, Ivankov and other members of his organization settled business disputes for Russian and Eastern European businessmen operating between North America and the former Soviet Union, receiving in return a percentage of the amount in dispute, usually hundreds of thousands of dollars. Through his authority as a "thief-inlaw" and the head of a criminal organization, Ivankov was able to exercise a kind of informal power in the émigré business community tantamount to decisions made by formal, official courts of law. Those who went against the decisions made by Ivankov and his associates were usually met with violence, including beatings and/or murder. 38. One individual who challenged the power of Ivankov in the United States was a criminal group leader identified as Monya Elson. In the mid-1990's, sources were identifying Elson as competing with Ivankov for the leadership of the Russian criminal community in North America and as a result of his challenge to Ivankov's position, a number of attempts were made on Elson's life in New York and Los Angeles. Elson was subsequently incarcerated on federal charges and abandoned these efforts.

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39. On June 8, 1995, Special Agents of the FBI arrested Ivankov and several members of his organization, including his principal lieutenant, Leonid Abelis, in New York on charges of extorting $ 3,500,000 from two Russian émigré businessmen, Alexander Volkov and Vladimir Voloshin, who owned and operated an investment company located on Wall Street in Manhattan. Shortly after Ivankov's arrest, photographs were taken by FBI Special Agents to document numerous tattoos which were on his body, all of which were typical of those worn by so-called "thieves-in-law." 40. In July 1996, Ivankov was convicted by a jury after a trial held at the United States District Court, Eastern District of New York in Brooklyn, New York. In January 1997, Ivankov was sentenced to a term of incarceration of nine years and eight months. He was released from a federal correctional institution on July 14, 2004 and deported back to Russia. Ivankov's Involvement in Murders 41. It is my understanding from published reports that on July 15, 2004, immediately after his deportation from the United States on July 14, 2004, Ivankov was formally charged by the Moscow Prosecutor's Office with the murder of two Turkish nationals in a Moscow restaurant called Fidan on February 29, 1992. (See Exhibits 1-5.) 42. The Russian news service ITAR-TASS reported on July 14, 2004 that "mass media indicated in this connection that `Yaponchik' had come to the restaurant in the company of another crime boss, Vyacheslav Sliva. As a brawl with three foreigners began, he (Ivankov) fired shots at them from a gun, killing two of the three men." (See Exhibit 5.)

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43. It should be further noted that the original arrest complaint filed by the FBI on June 8, 1995 said that during the course of the Ivankov's group's 1995 extortion of the two Russian émigrés, Aleksandr Volkov and Vladimir Voloshin, principals of Summit International in New York City, Ivankov was part of a conspiracy to murder extortion victim Vladimir Voloshin's father. 44. The elder Voloshin was attacked by several individuals on a Moscow subway train platform and later died from the injuries sustained in the assault. It was alleged that this attack was, in fact, part of the effort to convince Volkov and Voloshin to give up the $ 3.5 million being demanded by Ivankov and his associates.

Ivankov and His Associates' Reported Involvement in Threats on the Lives of Law Enforcement Officers and Witnesses 45. During mid 1996, while the trial of Ivankov was taking place in Brooklyn, information was received from a confidential source that individuals who had arrived from Russia were seeking to learn the location of the two FBI case agents on the Ivankov investigation so that they could be murdered. 46. After an investigation was conducted to identify those reportedly involved in this reported plot, a Russian national who admitted being both associated with the socalled "thieves council" in Moscow (see above) and acquainted with Ivankov was arrested by Special Agents of the FBI in Miami. This individual was taken into custody after it was determined that he was in violation of the Federal Firearms Act, having participated in a "straw purchase" of a weapon from a Miami area gun store. This individual denied any knowledge of or participation in a plot to murder the FBI Special

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Agents, however, and he was subsequently convicted and incarcerated for his role in the firearms act violation. He served a term of several months of incarceration for this crime and was then deported from the United States. 47. In the fall of 1996, one of Ivankov's criminal partners, Solntsevskaya Organization leader Sergey Mikhailov also known as "Mihas," was taken into custody by officers of the Surete of Geneva, Switzerland on charges of participation in an organized crime group and money laundering. 48. An officer of the Russian Ministry of Interior's Organized Crime Control Division, Major Nikolai Uporov, was contacted by the Surete of Geneva in connection with the investigation of Mikhailov. Both Major Uporov and I subsequently testified in the December 1998 trial of Ivankov's associate, Mikhailov. 49. During the course of my contacts with Major Uporov in 1997, prior to the trial, and subsequently, I learned that he had been the recipient of numerous death threats and that on at least two occasions, attempts had been made by criminal organization members to kidnap his daughter in Moscow. Major Uporov subsequently became so concerned about his own safety and that of his family that he moved to Switzerland and granted residency there. 50. In mid-1996, after the trial of Ivankov was in progress, it was learned from previously reliable sources that associates of Ivankov in the so-called "council of thieves" in Moscow, including Vladimir Voronin, also known as "Vorona," one of the leaders of an allied group, the Lyuberetskaya ("Lyubertsy") Organization, reportedly told others that they and other members of the council were so outraged by the defection of

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Ivankov's lieutenant in the United States, Leonid Abelis, that they were taking steps to have him killed. 51. On April 23, 1997, a Moscow publication called "Komsomolskaya Pravda," published an interview that its "special correspondent," Oleg Karmaza, conducted with Ivankov while he was incarcerated after his conviction in New York on federal extortion charges. (See Exhibit 7.) This interview was entitled "Vyacheslav Ivankov: I Know Who Killed Vladislav Listyev ­ Komsomolskaya Pravda Correspondent Oleg Karmaza Interview the Famous "Jap" Serving a 10-Year Sentence in a New York Prison." 52. During the course of that interview, Ivankov is quoted as saying as follows: I know what I am saying. Go ahead and write it: I am borrowing their methods. The methods of all those (expletive ­ O.K.) from the FBI, MVD and FSB. They took my life away from me; they are not letting me live normally, as a human being, with a family; they have ruined my old age ­ let them. I will fight them with their own vile methods. This will be honest. A man's way. I have a list. I know who committed these crimes both from the side of the Russian special services and from the FBI side. I know who handed my archive over to Russia. I know who hunted down my people in Russia, who gave the orders and carried them out. I know all these people. And I warn them that they will answer for their crimes. 53. Ivankov is being held currently at the Matrosskaya Tischina prison in

Moscow, and from my experience, criminals held at that facility, as well as other institutions of the Russian prison system, have been able to continue to direct the activities of their organized crime groups while incarcerated. 54. In fact, I was informed by a previously reliable source that on a number of

occasions in the past, meetings of the so-called "council of thieves" (See above) have been literally held inside of Russian prisons, with organized crime figures permitted to

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EXHIBIT 1 SOURCE: DATE: ITAR-TASS in English 1228 GMT, 29 Apr 05

[FOREIGN BROADCAST INFORMATION SERVICE (FBIS) Transcribed Text] By Nadezhda Gaisenok MOSCOW, April 29 (Itar-Tass) - The Moscow City Court on Friday refused to drop the case against criminal boss Vyacheslav Ivankov, nicknamed "Yaponchik" (little Japanese). Yaponchik's lawyer Alexander Gofshtein said the defense had requested to give up the charges because of the expiration of the 10-year period of limitation when the person could be held criminally responsible. The lawyer also said he then filed a new petition asking the court to send the case back to prosecutors "for eliminating the shortcomings." The judge is now deliberating. Vyacheslav Ivankov was deported from the United States to Russia and remanded in custody on July 14, 2004. The next day investigators from the Moscow Prosecutor's Offices formally charged him with the double killing of Turkish citizens in 1992. Ivankov had been charged with the murders in absentia back in 2000, when he was serving a nine-year prison term in the United States for extortion. At that time, Russian prosecutors informed the U.S. Justice Ministry that after his release from prison and deportation to Russia he would be taken into custody. Although the arrest warrant was issued four years ago, it remained effective, prosecutors said. Ivankov, 64, has three criminal convictions. In the 1970s, was sentenced to five years in prison in the case of the gang led by criminal boss Mongol. In 1981, he was sentenced to 14 years in a maximum security prison. However, Yaponchik was released in November 1991, after the Supreme Court mitigated the penalty. On June 8, 1995, he was arrested by the FBI in New York for extorting 3.5 million dollars from the owners of the Summit International company, Alexander Volkov and Vladimir Voloshin, who had received money from the notorious Chara bank. In 1997, Brooklyn's federal court sentenced Yaponchik to 9 years 7 months in prison. After serving out the sentence, Yaponchik was deported to Russia. He was placed under arrest upon his arrival at the Sheremetyevo-1 airport.

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EXHIBIT 2 SOURCE: DATE: Kommersant in Russian 19 Nov 04

[Report by Aleksandr Zheglov, Yelena Glumskova, in Bishkek, 19 Nov: "The Case of Yaponchik: Vyacheslav Ivankov Identified in Absentia: Murder Witnesses Found in Kyrgyzia" -- taken from HTML version of source provided by ISP] [Foreign Broadcast Information Service (FBIS) Translated Text] Yesterday Nurlan Dzheenaliyev, head of the criminal investigations oversight directorate in the General Prosecutor's Office of Kyrgyzia, stated that two important witnesses had been questioned in Kyrgyzia in the case of Vyacheslav Ivankov (Yaponchik) and had allegedly accused him of committing a double murder in 1992 in Moscow. Mr. Ivankov's defense considers these statements "improper and untimely." In Kyrgyzia, investigators in the Russian prosecutor's office have questioned two witnesses in the case of Vyacheslav Ivankov. This was announced yesterday, at a briefing in Bishkek, by Nurlan Dzheenaliyev, head of the criminal investigations oversight directorate in the General Prosecutor's Office of Kyrgyzia. He said that the witnesses had been taken to the General Prosecutor's Office at the request of the Russian side a few days ago. The interrogation was devoted to obtaining testimony on the possible participation by Vyacheslav Ivankov in the shooting of three citizens of Turkey in Moscow in 1992, as a result of which two died on the spot and a third was gravely injured. According to Mr. Dzheenaliyev, the witnesses' testimony "directly accused Ivankov of committing this serious crime." True, Nurlan Dzheenaliyev refused to speak in more detail about who these witnesses were and what specific testimony they gave. "We have fulfilled the request of the Russian side and do not care to discuss the course of this investigation," he said. Mr. Dzheenaliyev merely clarified that the citizens of Kyrgyzia found themselves at the scene of the crime "by chance." According to Kommersant's information, we are talking about two call girls who were accompanying the Turks in the restaurant on the day of the shooting. Immediately after the incident they returned home to Kyrgyzia. Russian investigators and their Kyrgyzstani colleagues together conducted the procedure of identifying Vyacheslav Ivankov from photographs. Yuriy Rakitin, Mr. Ivankov's attorney, considers Nurlan Dzheenaliyev's statement "improper for a prosecution employee and untimely, to put it mildly." In the defense's opinion, identifying the suspect from photographs, without the presence of his attorneys, when there is the real possibility of conducting these investigative actions with him there, "is illegal and improper." "I saw those photographs, and even his own children wouldn't have recognized Ivankov from them," said an indignant Yuriy Rakitin. Yesterday the Moscow Prosecutor's Office hastened to distance itself from the statement of their colleagues in Bishkek. In a

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conversation with Kommersant, Sergey Misyura, investigator for the Moscow Prosecutor's Office in the Vyacheslav Ivankov case, called the press conference a "provocation by the Kyrgyzstanis." "There's never been anything like it," said Mr. Misyura, referring to the interrogation of the witnesses in Kyrgyzia.

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EXHIBIT 3

SOURCE: DATE:

Kommersant in Russian 05 Aug 04

[Article by Aleksandr Zheglov: "The Jap Is Demanding Rehabilitation" -taken from HTML version of source provided by ISP] [Foreign Broadcast Information Service (FBIS) Translated Text] The Jap is demanding rehabilitation: he does not want to become a monster. Yesterday Yuriy Rakitin, defense attorney for "thief in the law" Vyacheslav Ivankov (the Jap), announced that his client does not intend to agree to the closing of his criminal file. The only thing that suits the Jap is full rehabilitation. As Kommersant has already reported, on 23 July Yuriy Rakitin filed a petition with Moscow prosecutor Anatoliy Zuyev asking that the criminal investigation of his defendant be closed because the period of prescription for the crime that Mr. Ivankov is charged with has expired. We will recall that he is accused of a double homicide that he supposedly committed on 29 February 1992 in the Fidan restaurant. "As defense attorney I am required to use every opportunity to defend my client," attorney Rakitin told Kommersant. "There has been no response to the petition yet, but Vyacheslav Kirillovich has already stated that he does not want to close his case based on prescription. He is not guilty and will demand full rehabilitation, with all the consequences that flow from that." Mr. Rakitin also stated: "My defendant and his relatives intend to bring suit against all the journalists who have turned him into a monster." Vyacheslav Ivankov really does consider himself defamed by the press, and on this subject he even made a program statement of his attitude toward the press from Matrosskaya Tishina prison (see note [not included]). The essential point is that the mass media "disfigured" his life, portraying him as "some kind of monster and idol of the criminal world." But that is not all the journalists are guilty of: Mr. Ivankov cannot forgive contemporary journalists for the "existence of the criminal communist regime in our country for almost 100 years" because "all these years it was you who nurtured and praised this regime." In his opinion, what should be written about is the "torture in prisons, the constant violations of the law by associates of these institutions, and the destitution." As for the accusation of the 1992 homicide, of course, Mr. Ivankov had nothing to do with it. The prosecutor's office assessed Vyacheslav Ivankov's statement about refusing to close his case because the period of prescription has expired as a bad PR move. According to associates there, "Ivankov understands very well that his petition will be denied, and he is

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trying to squeeze something out of this situation." The investigation thinks that right after committing the murder Vyacheslav Ivankov went into hiding abroad, and therefore, "in conformity with Article 48 of the RSFSR Criminal Code that was in effect at that time, the period of prescription in relation to him was suspended." In any case, Vyacheslav Ivankov is preparing for a lengthy investigation of his criminal case. A whole group of defense attorneys is being formed for this. According to Kommersant's information, this week attorneys Grigoriy Perelman and Sergey Kotelevskiy will join Yuriy Rakitin, who has already entered the case.

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EXHIBIT 4 SOURCE: DATE: ITAR-TASS in Russian 1413 GMT, 15 Jul 04

[Foreign Broadcast Information Service (FBIS) Translated Text]

Moscow, 15 July: Investigators from the Moscow prosecutor's office today charged criminal boss Vyacheslav Ivankov, also known as Yaponchik, with murder, sources in the Moscow Prosecutor-General's Office told an ITAR-TASS correspondent today. "Interrogation, during which Ivankov was charged with double murder, is under way in the Matrosskaya Tishina remand centre," the Prosecutor-General's Office said. Ivankov, who spent nine years doing time in a New York jail for extortion, was deported to Moscow where he was charged with murdering two Turkish citizens in 1992. Moscow Deputy Prosecutor Vladimir Yudin told an ITAR-TASS correspondent earlier that investigators had managed to launch investigatory actions after Ivankov had had a meeting with his lawyer. "In accordance with the law, we must bring a charge against the arrested within 24 hours," the deputy prosecutor said.

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EXHIBIT 5 SOURCE: DATE: ITAR-TASS in English 1827 GMT 14 Jul 04

[Foreign Broadcast Information Service (FBIS) Transcribed Text]

MOSCOW, July 14 (Itar-Tass) - Russian organized crime boss and mastermind thief Vyacheslav Ivankov, broadly known under the Russian nickname of Yaponchik ("the Little Japanese") was taken to Moscow's Sheremetyevo airport by jet from the U.S. Monday and handed over to a special task force of the Russian Justice Ministry. His arrival in Russia after twelve years of stay in the U.S., including about ten years in jail, was followed by a brief legal procedure, in the course of which the Russian officials issued an order for his arrest. Right from the airport, Yaponchik was transported to Moscow's custody center No. 1 on Matrosskaya Tishina Street. He will stay there in a general ward, but contrary to some media reports, he will not be sharing a ward with the former CEO of the major Russian oil company Yukos, Mikhail Khodorkovsky. The sanction to arrest him, originally issued in 2000, remained effective on the date of his arrival in Russia, said sources at the Prosecutor's Office of Moscow City. "It is still effective, although it was issued under provisions of the previous Code of Criminal Practice and four years have passed since then," an interlocutor who asked to withhold his name told Itar-Tass. He indicated that prosecutors might issue official charges on a crime dating back to 1992 to Yaponchik as early as Thursday, July 15. In 2000, the Moscow City Prosecutor's Office charged the man with killing two Turkish nationals during a row in the Moscow restaurant Fidan in January 1992. Mass media indicated in this connection that Yaponchik had come to the restaurant in the company of another crime boss, Vyacheslav Sliva. As a brawl with three foreigners began, he fired shots at them from a gun, killing two of the three men. Yaponchik, now 64, was first tracked by the former Soviet interior agencies back in the mid-1970's. After the breaking of a mob of the crime boss nicknamed Mongol, whose disciple Yaponchik happened to be, the latter man was sentenced to five years in jail. After he was freed, he pooled together a criminal ring of former convicts. In 1981, he was jailed again, this time for 14 years, on charges of robbery and inflicting heavy bodily damage on a person. Yaponchik served the term in a high-security jail.

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The Supreme Court mitigated his sentence in 1991, and he was set free in November of the same year. Yaponchik left for Germany in March 1992 and crossed the Atlantic to settle in the U.S. The FBI arrested members of his ring and himself in New York June 8, 1995, on charges of extorting 3.5 million U.S. dollars from two former Russians, Alexander Volkov and Vladimir Voloshin, who owned an investment company on Manhattan. The two men were said to have received 2.7 million U.S. dollars from the owner of a Moscow-based financial pyramid Chara Bank. The Brooklyn federal court sentenced Yaponchik to nine years and seven months in jail in January 1997. The previously mentioned crime boss Sliva was also extradited to Russia. The Canadian immigration court decided to deport him back in 1997 on the premise that he had concealed his crime record while entering the country on a guest visa. Unlike Yaponchik, Sliva was not arrested upon arrival in Russia - he got away with a close watch by the law enforcement agencies.

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EXHIBIT 6 SOURCE: DATE; Ogonek May 97 No 18 pp 14-20 in Russian 01 May 97

[Article by Andrey Konstantinov, of the Shans Publishing House Investigations Service, St. Petersburg, under the "Topic of the Issue" rubric: "`In the Law' and Outside the Law. From His Cell in Manhattan, Ivankov Continues To Direct His `Empire'"] [Foreign Broadcast Information Service (FBIS) Translated Text] Vyacheslav Kirillovich Ivankov (aka Yaponchik, aka Slava Yaponets, aka the Assyrian Son-in-Law, aka Grandfather). According to the Internal Affairs Ministry [MVD] and the Federal Bureau of Investigation, he is one of the five most influential of the Russian "crime bosses." He is suspected of arms and drug smuggling and numerous incidents of extortion and murder. Law enforcement agencies of Russia and the United States assert that under his control, criminal groups are operating on the territory of Russia, Ukraine, Belarus, France, Germany, Austria, Canada, and the United States. A large number of the charges, however, have not succeeded in being proved. Last summer a jury in Brooklyn, New York, found him guilty of having created a criminal group and of having extorted $3.5 million from two Russian citizens, and he was later sentenced to nine and a half years. According to the testimonials of people who knew Ivankov in New York, Yaponchik was always remarkably polite and obliging, loved historical literature, practically never drank, and from time to time smoked Virginia Super Lights. Now he is awaiting the results of the appeal filed by his lawyers in New York's MCC (Metropolitan Correctional Center) prison, in almost the very center of the city, in Lower Manhattan. For a person who has spent more than 10 years in Soviet prisons and camps, the conditions of custody in the MCC must be reminiscent of a resort. It is not even a prison, but an investigative detention facility, in which 830 people are awaiting the results of the examination of their cases: Two-man cells, which are closed down from 2300 until 0600, five showers and toilets per block (100 people). Meals three times a day, and the portions can be as large as one wants to take. During the day inmates may move about freely on the floor, and play whatever they like, from cards to Monopoly, order books at the prison library, which numbers 2,000 volumes, and subscribe to any newspapers. On one block there are four televisions and the same number of telephones, which may be used 17 hours a day. If one wishes to do so, one may work in the prison studio, but the majority wish to acquaint themselves with their own cases. But one thing could cancel out all of the advantages of the MCC. In America, regardless of the term of incarceration, there are no conjugal visits. In Russian prisons, for exemplary behavior, it is possible once

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every half-year to get the chance to spend three days with one's wife in a separate little room on camp property. With an almost domestic stove and bed. In the MCC, inmates are allowed three visits a week. But only in a common room for visitors, where 30 men sit shoulder to shoulder on plastic chairs. And no packages from home. Yaponchik still maintains that he is innocent, and the case was completely fabricated by the American and Russian special services. While in his homeland, they continue to discuss his case, not greatly trusting in the reliability of the American prison locks and bolts. The United States v. Vyacheslav Ivankov The testimony given by FBI agents at Yaponchik's trial was refuted more than once by Ivankov's lawyers; witnesses for the prosecution got mixed up in their names and dates, at the same time confessing to their own crimes. For the jury, as usual representing not the most well-educated strata of American society, they even put up a special slate, on which they wrote Russian names and nicknames every day in Latin letters. Especially for them, the prosecutor gave them an entire lecture on the fact that one of Ivankov's crime names--Grandfather--in actual fact means...well, approximately the same as Godfather in the Italian mafia. It seemed that the case that had been prepared with such hard work was crumbling before their eyes, and Yaponchik's lawyer, Barry Slotnik, on the day that the verdict was rendered had even ordered a festive banquet, to celebrate the defendants' walking free. The banquet did not take place. The jurors unanimously decided that Ivankov was guilty. The indictment prepared by the FBI outweighed all of the arguments of the defense, and, despite many patent incongruities and unproved facts, it played the decisive role in Yaponchik's fate, confirming once again an old truth: It is futile to fight with the state. If it wants to put you in prison, you may be sure that it will put you there. The editorial board will not comment upon the testimony from secret sources, leaving wholly to the conscience of the FBI the information of its agents. From the testimony of special FBI agent Lester R. MacNulty: [Begin box] GENERAL INFORMATION ON THE DEFENDANT. "...Vyacheslav Kirillovich Ivankov (aka Yaponchik) belongs to an elite group of criminals known in the Soviet Union as "crime bosses." He heads an international criminal organization associated with the drug trade, extortion..." [End Editorial Note] Ivankov created a criminal organization in Russia in approximately 1980. Using forged or stolen police documents, the members of Ivankov's grouping conducted "searches" in the homes of well-off people and stole money and other valuables. For these crimes, Ivankov was sentenced to 14 years' incarceration in prison. According to information received by the Russian MVD, having given a bribe to a member of the Supreme Court of Russia, in 1991 Ivankov was released, having served only 10 years...

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After his release from prison, Ivankov began work organizing a criminal group in the United States. In January 1993, the MVD informed the FBI that Ivankov had entered the country in order to coordinate Russian organized crime in that country. The MVD also handed over to the American side a list of telephone numbers that Ivankov could call during his stay in the United States, after which a call identification device was installed on the telephone lines. Analysis of the telephone conversations revealed that Ivankov had used the above-mentioned numbers for talks with established members of Russian criminal groupings. From the time of his arrival in the United States, FBI agents more than once established Ivankov's meetings with other famous members of Russian organized crime. Ivankov registered at least one company in New York (Slavic Incorporated), which served to launder money. He also participated in several incidents of extortion... Ivankov's organization operates in several city of Europe, Canada, and the United States, giving preference to New York, London, Toronto, Vienna, Budapest, and Moscow... Ivankov's organization includes two main groups of "commandos," headed by Aleksey Petrov ("Petrik") and Aleksandr Inshakov ("Inshak")... Inshakov's main assistant is Viktor Sergeyev, a former officer of the KGB. They commit murders at Ivankov's order, including five or six murders of Russian organized crime leaders who had got in Ivankov's way. According to a report by "Secret Source No. 1," Ivankov pays Inshakov's group about $100,000 a month. In turn, members of the Solntsevo criminal grouping pay a portion of their "earnings" out to Ivankov... Among other companies used by Ivankov in his criminal business, one may name Atkom (Vienna), the undertaker's firm Ritual, and Arbat International in Moscow. Ivankov used Arbat to send large amounts of money from Moscow to Budapest, for companies controlled by Seva Mogilevch, one of his closest aides. According to a report of "Secret Source No. 1," in recent months Ivankov's organization set up close ties with a criminal group headed by Anzor Kikalishvili and Iosif Kobzon. Kikalishvili and Kobzon illegally receive money from the joint venture Russo- American, located in New York. They were also associated with one of the leaders of Russian organized crime, Otari Kvantrishvili, killed by a sniper in Moscow in April 1994. Kobzon, Kikalishvili, and Kvantrishvili, giving bribes to a Russian customs official, received a special permit, exempting the joint venture Russo-American from payment of import duties on alcohol and tobacco products. In the guise of payment for security services, the joint venture pays Kobzon and Kikalishvili for customs services and for the "protection" that they give. (Another "secret source," "SS 2," in a conversation on 16 March 1995, indicated that Iosif Kobzon also heads operations on the import of bootlegged vodka, affixed with the labels of elite brands, into the United States.) ..."Secret Source No. 1" also reported a deal on the delivery of armaments and military equipment carried out by the KobzonKikalishvili group. The weapons, including machine guns and

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antiaircraft systems, were delivered from Germany to one of the Arab countries. The cost of the deal amounted to $18-20 million. According to "Secret Source No. 1's" information, another participant in the deal was Alimzhan Tokhtakhunov ("Tayvanchik"), who worked with Kikalishvili and Kobzon in their company 21st Century Association, which, like the joint venture Russo-American, supplies tobacco and alcohol to Russia without payment of customs duties... The Last Extortion Attempt Against the Personnel of the Summit International Firm In March 1995, "Secret Source No. 1" informed FBI agents that Ivankov was trying to get money from the investment company Summit International in New York, headed by Russian citizens Aleksandr Volkov and Vladimir Voloshin... "Secret Source No. 1" maintains that the prehistory of the matter is as follows: In the spring of 1994, the head of the Russian bank Chara transferred $2.7 million to Summit International for investment in various securities. In August 1994, when the investor began to have financial problems, he informed Volkov that if he received a call from a man who gave a code word, then Summit International must return all the money. Soon Volkov received a call, and the man, having given the password, demanded that the money be returned at the end of the year... At the end of 1994, the head of Chara died unexpectedly, and Volkov began getting calls from Rustam Sadykov and Maksim Korostyshevskiy, demanding that he return the money... In February 1995, Sadykov and Korostyshevskiy, at Inshakov's recommendation, came to Ivankov... According to "Secret Source No. 1's" report, Ivankov's representatives telephoned Volkov and Voloshin and set up a meeting in the office of Summit International on Wall Street on 23 February. At the appointed time, on seeing Ivankov himself coming up to the office along with Maksim and Rustav, Volkov and Voloshin got scared and left New York... After the meeting failed to take place, the unofficial mediator came to them and informed them that now the matter would be handled by Yaponchik personally, that now they owed him $5 million, and that now a lot of problems were cropping up for them. ...In Florida, Volkov turned to the FBI for help... Ivankov's Participation in Drug Trafficking Operations According to "Secret Source No. 1's" information, Ivankov's organization transports and distributes narcotics... In July 1994, Ivankov began to have differences of opinion with Sergey Ivanovich Timofeyev ("Silvestr"), who headed the Orekhovo- Borisovskiy grouping and controlled a significant portion of the drug trade in Moscow. The conflict arose after a deal that did not go through, when Timofeyev accused Ivankov's son Edik of appropriating $300,000. Timofeyev was killed when his car was blown up in September 1994 in Moscow... In January 1995, Ivankov informed Viktor Averin and Sergey Mikhaylov, the heads of the Solntsevo grouping, that the territory and merchants that had earlier been controlled by Timofeyev would be passing to them.

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Intercept of a telephone conversation. [Begin box] On 9 May 1995, at 1530, Ivankov called Sergey Mikhaylov in Moscow. They talked for more than 50 minutes, discussing, among other things, recent murders in Moscow. "Mikhaylov: I am calling from a place where I can talk... Three days ago, our friend, who was... "Ivankov: Yes, yes, I understand. "Mikhaylov: He was asked to come out of his apartment in the evening, and he called me... "Half an hour after that conversation, his wife called... "Ivankov: Yes. "Mikhaylov: They went out onto the street, and three men came toward them and began... "Ivankov: To shoot. "Mikhaylov: To shoot. They had one guy with them, and he was killed on the spot. The second is in serious condition, and our man is also in critical condition. He lay for three days in the resuscitation unit, and only today began to speak. He knows the people who did the shooting. And he thinks that they have gone against the thieves' law. Do you understand?" At the end of the conversation, Ivankov told Mikhaylov that he would take the situation in hand... [End Editorial Note] ...At the present time, Ivankov and the Solntsevo organization are engaged together in the transport and distribution of narcotics in Russia. In January 1995, Sergey Mikhaylov told his people that he had found a new source of deliveries of large batches of cocaine into Russia, but that neither Ivankov nor his people must know anything about this... The Enigma of Yaponchik At the end of January 1997, an American court announced to Vyacheslav Ivankov, the famous crime boss with the "handle" Yaponchik, the verdict of "Guilty"--the "Russian mafioso" got 115 months in prison. The case "The United States v. Vyacheslav Kirillovich Ivankov" had ended. However, the mysteries surrounding the personality of Yaponchik himself remain--despite a multitude of articles about him in newspapers and magazines, despite a book devoted to the Ivankov trial, despite the numerous television programs...How had the "boss" who was called the absolute leader of organized crime been able to gain his freedom early in Russia and, with inconceivable speed, to get over to the United States? It is amusing that nowhere has it been clearly told how the figure of Yaponchik was, in essence, a stumbling block in a real "war of methodologies" between two special services in the USSR that developed at the end of the 1980s and the beginning of the 1990s.

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What happened, anyway, that Yaponchik, sentenced for audacious robberies with assault in 1982 to 14 years, went free after 10? In order to try to answer this question, we will not only have to plunge into Ivankov's past, but also to try to understand what in fact a "crime boss" is--simply a cliche that sets one's teeth on edge, or something a little more than that, after all? Our Russian specialists who study the phenomenon believe that the necessity of a criminal kingpin's attaining of the status of "crime boss" bears, to a great extent, an ideological character. Obligated to live according to unwritten criminal laws, taking upon themselves the duty of "human rights activist" of the arrested in investigative detention facilities, prisons, and corrective labor camps, and helping the families of convicts on the outside (at the expense of the "kitty"), the crime bosses know in advance that they become an obvious target for the law enforcement agencies. However, the status of a crime boss, with all that, automatically gives its possessor a guarantee of inviolability, of personal security and prosperity, both in the investigative detention facility, prison, the camp, and on the outside. At least, that was how it was earlier. And for that same personal immunity and security, the crime bosses have been prepared to give a very great deal. Over many years of attempts to study the thieves' world, detectives and workers in the operations units at correctional labor institutions never have succeeded in getting the "thieves' code" through undercover methods or in seizing it during the course of investigative operations. Only in the works of certain criminologists are individual precepts of the "thieves' law" cited, "10-15 precepts." Most likely, the criminal world, in the person of its ideologists, the crime bosses, intentionally do not write down their rules of conduct, thereby giving themselves the ability to transform them in their own interests, and not living strictly according to an unwritten law invented by their grandfathers. It was the KGB's personnel who first began to take an interest in the possibilities of undercover infiltration into the criminal world. The start was made in the middle of the 1980s, when workers of the State Security Committee embarked upon sanctioned contacts with crime bosses. Not a single "crime boss" prison (Vladimir, Tulun, the "White Swan," and many others) went without their attention. "Committee men" have had confidential conversations with most of the crime bosses; meanwhile, it remains a mystery what on earth was specifically promised to the generals of the criminal world. However, it is known that KGB personnel attempted to take out of the GULAG's archives all documents compromising the crime bosses--written statements repudiating the thieves' traditions, written statements on collaboration, and so on. It is obvious that the committee took the easiest path--they did not have to spend the energy to expose kingpins on the outside or to select agents for their investigation. In 1991 in the USSR's criminal circles, relations became extremely aggravated between the Slavic and the Georgian (called "lavrushniki") crime bosses; these aggravations increasingly often went as far as open violent clashes. At the same time, the fusing of common and economic crime was under way at a rapid pace, there was a luxuriant flowering of corruption, and the term "contract murders" entered the working lexicon. It was at just this time that leaders appeared in the country, who built their criminal families in the likeness and image of foreign

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mafia structures. One may consider Otari Kvantrishvili, one of Yaponchik's partners in crime, a vivid representative of such a type of leader. Kvantrishvili succeeded at one time in legalizing criminally acquired capital, and he, enjoying the support of the majority of the criminal kingpins of both the old and the new formation, forging ties among high-ranking bureaucrats, was quickly transformed into the new criminal ideologist of the entire Moscow region. He, first of the criminal kingpins, took part in energetic political activity (we will note that this in no way had ever squared with the thieves' traditions). In April 1994, when coming out of the Krasnopresnenskaya baths, he was shot by hired killers with a small-caliber sporting rifle. This murder has remained unsolved to this day. However, certain informed workers in the law enforcement agencies permit themselves the conjecture that this elimination was the work of the special services. In this specific instance, it was not so much even the accuracy of the shot that attracted attention (anyone can find a sniper) as much as getting the shot to its mark--and here it would have been very difficult to do without serious organization: There is a theory that Kvantrishvili, having quickly gained authority and influence, had gradually begun to get out from under the control of his "handlers"... Let us return, however, to Yaponchik; it was precisely at the end of the 1980s and the beginning of the 1990s that the question of his release became extremely urgent for those who were trying to control organized crime from within. Yaponchik was coronated a crime boss almost immediately after receiving his sentence in 1982 in the Tulun prison. Ten years as a crime boss in places of incarceration did not pass for him without a trace: By the end of the 1980s, he had become a true ideologue of the Russian thieves' movement. He could become that crime boss who could realistically oppose the Georgians in the central region. Over the entire 10 years of his prison term, Ivankov, through lawyers and his connections in the law enforcement agencies, was constantly appealing to various courts, complaining about his "unlawful conviction." For a long time, however, all of these appeals went unanswered. But at the very end of the 1980s, everything suddenly changed abruptly: It was precisely then that personnel of the USSR KGB and Internal Affairs Ministry became Yaponchik's regular visitors in the Tulun prison. What Ivankov chatted with them about is not known. However, the very fact of private conversations of a crime boss with his investigators does not fit within any framework of the unwritten thieves' laws. (The now late Vitya-Kalina, for example, in 1991 responded to a summons to appear at the Sixth Directorate of the USSR Internal Affairs Ministry; however, he did not engage in any conversations with its personnel without a third party. In the Vladimir Central Prison, another crime boss, Aleksandr Zakhar, crime name, Zakhar, likewise did not speak with operatives one on one.) From the archival materials. [Begin box] SPECIAL REPORT. TO THE CHIEF... SECRET. PERSONAL. ...Intelligence has been received from a trustworthy source: Yaponchik got a visit from a lawyer from Moscow; they went into the question of his early release from prison. Given a positive resolution of the question, Ivankov intends to go to the United States. The goal of his departure is not known. Based on the account of one of Yaponchik's

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cellmates, "X," it has become known that he found among Ivankov's personal effects a statement written in printed letters; the purpose of its writing is not known to the source... [End Editorial Note] It should be noted that, in the course of analysis conducted by specialists with the use of GULAG archival materials, it has transpired that about 70 percent of the crime bosses who have been convicted and have served sentences in correctional labor camps and prisons at various times have had contact in one form or another with operatives, being representatives, informants, or sources. At the same time, such crime bosses went for contact only with the head of the camp (the "master") or with the head of the operations unit (the "godfather"). The written statements given by the crime bosses were necessary in order to keep the criminal kingpins in check. If they surfaced in the criminal world, a sentence of death would inevitably be pronounced upon the author of the written statement. The texts of such statements, as a rule, were similar to this one, left by one of the most authoritative bosses: [Begin box] TO THE HEAD OF ADMINISTRATION P/Ya A.M224 TO COLONEL... FROM THE INMATE... SIGNED STATEMENT I, a convicted thief by the crime name "..." renownse the title of crime boss and the propogasion of thieves' ideas. I plege to help... I request that you do not spread word about my conversations both with you and... I myself will keep our secrets and as much as possible will suppress criminal manifestations. I ask you to intersede in sending me to the hospital for treatment. [misspellings retained from original] 24/04/19... [End Editorial Note] When, at the end of the 1980s and the beginning of the 1990s, the strange piece of information began circulating about the attempts to release Yaponchik early, it was explained to detectives from the Internal Affairs Ministry during the course of consultations at the GUIN [Main Administration for the Execution of Punishments] of the USSR Internal Affairs Ministry that early release of such a category of person was at variance with current legislation and was never applied in practice. The Yaponchik story, however, abruptly left the framework of the usual practice. From May 1989, not a single violation of the prison regime was attributed to him. Moreover, the convict Ivankov tried openly not to participate in the processes of the prison thieves' life. From the minutes of a session of the administrative commission of 18 December 1990:

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[Begin Box] "...he (Yaponchik) has stepped onto the road of rehabilitation, and it is advisable to take humanitarian action with respect to him..." [End Editorial Note]

There soon followed an appeal by Ivankov's wife to USSR People's Deputy Svyatoslav Fedorov, with a request to render assistance in her husband's pardon. Subsequent events developed according to a script written in advance: a deputy inquiry to the Presidium of the USSR Supreme Soviet and Chairman of the Russian Federation Supreme Soviet Boris Nikolayevich Yeltsin, inquiries to the institution UK- 272-ST2 (the Tulun Prison), and, naturally, a positive result. [Begin Box] FROM THE ARCHIVAL MATERIALS: "...A confidential conversation has taken place with an official of the division on questions of pardon, who explained that deputy inquiries petitioning for pardon of convicts are complied with immediately and with supervision (consequently, in Yaponchik's case, the most fail-safe variant was selected--A.K.), while judicial supervisory verification on the legality of the conviction is sent only to the Supreme Courts of the Russian Federation or of the USSR, with respect to which, as a rule, appeals are filed. [End Editorial Note] A.E. Merkushev, then deputy chairman of the Supreme Court of the Russian Federation, got involved in the case, filing an appeal with the presidium of the Moscow City Court, with the aim of reopening Yaponchik's case in the exercise of supervisory power. The Moscow City Court left the appeal unredressed. Then Merkushev brought the appeal for a second time, but this time with the collegium for criminal affairs of the Supreme Court of the Russian Federation, that is, with his own subordinates. This time, the boss's appeal did not go unredressed, and the 14 years were replaced for Ivankov with 10, that is, for the very same amount of time that he had already served by then. After the Supreme Court's decision took effect, a so-called "red telegram," on the necessity for Ivankov's immediate release, went out to Tulun. It is curious that Yaponchik's wife arrived even earlier than the telegram, and, pounding with her fist on the desk of the head of the prison, demanded her husband's immediate release. However, there was a vexing glitch in the well-worked-out scenario; the fact is that the inmate Ivankov had had the imprudence to ill- treat a prison newspaper and magazine delivery man, causing him minor bodily injury, for which he received four and a half months' deprivation of liberty. This term was to be served concurrently with the 14-year term, but the commutation affected only the first sentence, and so Yaponchik had to serve out the four and a half months after all. During this time, a number of high-ranking Internal Affairs Ministry officersundertook the most active of steps aimed at reversing the judgment on Yaponchik's release. Officers of the Sixth Directorate of the Internal Affairs Ministry presented the minister of internal affairs and the procurator general with a memo on the scenario that had been set in motion and on the elements of corruption that had appeared during the release proceedings. However, this document was held up until the moment that Ivankov was set at liberty. It is known that the minister

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read the memo carefully, but he did not do anything to reverse the process. After his release, Yaponchik found himself under intense police scrutiny. Workers of the Sixth Directorate compiled and transmitted via Interpol channels a special intelligence report for the leadership of the US Federal Bureau of Investigation about the fact that Yaponchik had the intention of moving to the United States, "with the aim of being an emissary of the Russian criminal world to the United States, and the formation there of a mafia and the organization of contract murders." To what extent this information corresponded with reality, it is hard to say--let us leave it to the conscience of the workers of "Number Six." It is possible that they simply wanted to scare the Americans silly, so that they would not allow Ivankov entrance into the United States. Soon after the abovementioned information reached its destination, a certain American journalist from The New York Times arrived in Russia (Ivankov at that moment was already in the United States). This journalist went directly to the officer who was investigating Yaponchik, supposedly with the aim of writing an article about him. However, during their meetings, the correspondent asked questions not so much on Yaponchik's activity