Case Document 9 Filed 01/06/17 Page 1 of 62

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK

PPF MANAGEMENT LLC

Plaintiff,

V3

OJSC SBERBANK OF RUSSIA
SBERBANK CAPITAL
SBERBANK CIB USA, INC.

NEO CENTRE
PROMSVYAZBANK FAQ

I SC NATIONAL AGGREGATES COMPANY
KLEVER ASSET MANAGEMENT
KLEVER INTERNET INVESTMENT
ALETARRO LTD.

NISORAM HOLDING LTD.
URASAY LTD.

MOSTRA CONSULTING LTD.
SUINTEX LTD.

GERMAN GREF

OLEG GREF

ASHOT KHACHYATUREANTS
YURIY ZHUKOV

GREGORY SHIRIN

KIRILL NOGOTKOV

ALEXEY BAZARNOV

ZOYA GALEEVA

SERGEY KUBLITSKIY,

Defendants.

COMPLAINT

DEMAND FOR JURY TRIAL

COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

I. NATURE OF ACTION

1. This Complaint arises out of a textbook case of Russian corporate raiding against
Sergey Poymanov and Irina Porgornaya (?Majority Shareholders?) and their company Open

Joint Stock Company one of the largest granite producers

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in Europe. The Defendants wanted both to eliminate P-Granit as a major competitor on the
Russian granite market and to seize its assets.

2. Majority Shareholders assigned their claims against Defendants to Plaintiff PPF
Management LLC in order to preserve and pursue them in a system adherent to the Rule of Law.
Majority Shareholders? main bank and largest competitor conspired to take advantage of a
downturn in the market by interjecting themselves into Mr. Poymanov?s refinancing
negotiations. While pretending to offer realistic restructuring options, they purposefully
maneuvered Mr. Poyinanov into a position where he was essentially trapped. Defendants then
triggered a series of phony civil divestitures proceedings and criminal cases which ultimately
resulted in the main competitor taking over P-Granit.

3. Defendant Zhukov masterminded and oversaw the conspiracy executed by
Defendants and others companies and individuals under his direct and indirect control. In order
to steal a company of P-Granit?s magnitude, Defendant Zhukov needed the participation and
protection of Defendant German Gref, the chief executive of?cer of the largest bank in Russia,
Defendant OJSC Sberbank of Russia (?Sberbank Russia?). Although Defendant German Gref
was a former Minister of Economy and Trade and one of the few Russian politicians with a
moderate reputation in both the East and West, he used his reputation and in?uence in the
government to shield Defendants? actions from the investigations and reviews of the Federal
Anti-Monopoly Service (FAS) and regional and federal law enforcement. Mr. Poymanov
challenged every step taken by Defendants in the local courts, initiating more than 50 legal
actions. A key component to Russian corporate raiding is, however, undue influence in the

captured Russian courts. Thus, each claim was, predictably, rejected.

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4. Defendants furthered the illegal takeover of P-Granit by using multiple offshore
companies and straw men to disguise the true participants and bene?ciaries of the conspiracy.
Defendants implemented a complex scheme in order to hide not only from the majority
shareholders of P?Granit, but also from the Department of Economy and Finance of the
Government of the Russian Federation under the Prime Minister (current President, V.V. Putin),
that P-Granit?s shares and assets were being transferred illegally to Defendant Zhuhov?s
company. Defendants were so ef?cient that, for example, they identi?ed the assignee of shares
as the winner of an auction days before they had even conducted the auction. The cover-up and
crimes were of suf?cient enormity and sensitivity that Defendants Gref and Zhukov were
compelled to mislead President Putin?s adviser, Mr. Belousov, who was asked speci?cally to
investigate the situation with the P-Granit/Sberbank Russia debt.

5. P?Granit shares were transferred using four different procedures: shares were
foreclosed pursuant to an arbitration award; (ii) shares were auctioned; shares were assigned,
and; (iv) the last were dissolved in a phony bankruptcy proceeding. The assigned shares were
paid for with loaned money from Defendant Sberbank Russia. All P?Granit shares ended up in
Zhukov?s company.

6. Defendants also used U.S. banks in order to further the conspiracy, subsequently
investing some of the apparent proceeds of the crime in the United States.

7. This type of illicit scheme is a common modus operandi in Russia. It is carried
out through well?known techniques and is now internationally known as ?Reiderstvo.? These
techniques include fraud, bribery, forgery, corruption, intimidation, manufactured bankruptcy
and, ultimately, expropriation of the targeted company. Reiderstvo often involves private and

public sector white collar criminals conspiring with state organizations, including law

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enforcement agencies, as well as high level sitting politicians and their family members. See Dr.
Louise Shelley and Judy Deane, The Rise of Reiderstvo: Implications for Russia and the West
(2016). In the end, the prevailing level of corruption in Russia makes it easier for Defendant
Zhukov and his co-conspirators to steal P?Granit than compete with or pay a fair price for it.

8. While nicknamed as a Russian phenomenon, Reiderstvo commonly includes
activities outside of Russia: e. the use of shell companies in various jurisdictions to hide the
bene?cial owners, the use of foreign correspondent banks to move funds in more ef?cient
foreign currency?such as Euros and dollarswand investment of the proceeds.

9. As demonstrated in detail below, Defendants? actions ?t the pattern from the very
launch of the attack; from the manipulations of local law enforcement, to the laundering of assets
through offshore companies, to the use of US. dollars, U.S. correSpondent banks and U.S.
investments.

10. A compromised, corrupt Russian judiciary facilitates the Reiderstvo phenomenon
and is, thus, part of the problem. By design, it leaves victims of Reiderstvo no meaningful forum
in which to seek damages for the expropriation of their assets. In this case, all of Majority
Shareholders? claims for restitution and/or compensation have been denied, and its attempt to
seek justice in Limassol court in Cyprus is under threat of being curtailed by the receivers from
the P?Granit invest and Mr. Poyrnanov?s personal bankruptcy. The receivers are members of an
association of receivers whose members have a well-established history of engaging in
Reiderstvo. It is this same receivers association?SRO ?Dela? ?t.hat manipulated the Russian
bankruptcy system in the infamous ease of Sergei Magnitsky and the ongoing attacks against

William Browder and Hermitage Capital.

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ll. Plaintiff, as the assignee of Mr. Poymanov and Mrs. Podgornaya?s claims, now
seeks redress from a competent and independent judicial authority. Speci?cally, this is an action
for fraud and misrepresentation, conspiracy to commit fraud, breach of ?duciary duty, negligent
supervision, abuse of process and unjust enrichment under common law seeking to recover, inter
alia, damages for losses suffered as a result of the conspiracy described below.

II. PARTIES

12. Plaintiff PPF Management LLC is a corporation registered under Delaware law
with headquarters in Wilmington, Delaware. The purpose of the PPF Management LLC is to
preserve and pursue the claims of this lawsuit in a system adherent to the Rule of Law. Plaintiff
holds an assignment of the Majority Shareholders? claims for the actions against P?Granit.

13. Sergey Poymanov is a citizen of the Russian Federation and former majority
shareholder of P-Granit. P?Granit is and was at all material times a Russian company engaged in
granite mining and production. Established in 1976 on the base of the Shkurlatovsk granite
depositwthe largest in Europew?P-Granit has long been an industry leader. The company?s
assets have included full-scale quarries and equipment for the mining of raw materials and
facilities for the production of reinforced concrete framings and other products. In 2008, Mr.
Poyrnanov was the majority shareholder of P-Granit Group with a combined 90.5% shares
owned directly and indirectly through Vitera and PNH/Zinika. lrina Podgornaya is a citizen of
the Russian Federation and a former minority shareholder of P-Granit. In 2008, she owned
2.32% of P?Grranit. She is Mr. Poymanov?s former wife, the couple having divorced in 2011.
They share joint custody of three minor children, and a fourth child over 18 is in school and still
dependent on his parents. Mr. Poyrnanov?s father owned 4.57%, and Mr. Poymanov?s brother
owned 1.61% of P-Granit. They both assigned their rights to Ms. Podgornaya. Other minority

shareholders owned the remainder of approximately 1.04% of P-Granit.

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I. Defendants
a. Russian Comerate Defendants

l4. Defendant Sberbank Russia, a/k/a Savings Bank of the Russian Federation is a
Russian commercial bank and ?nancial services company headquartered in Moscow, Russian
Federation. Since 2011, Sberbank Russia has been trading Level 11 ADRS on the New York
Stock Exchange. Defendant Sberbank Russia is also trading its bonds on the London Stock
Exchange. Defendant Sberbank Russia interfered deliberately with Majority Shareholders?
attempt to restructure their debt. Defendant Sberbank Russia assigned P-Granit?s debt to
Defendant Sberbank Capital, which in turn implemented?together with Defendant Zhukov and
other co-conspirators?the illegal scheme to take over ownership of P-Granit shares, dismantle
the company by distributing its assets to Defendant NAC and, ultimately, liquidate P?Granit.

15. Defendant Sberbank Capital LLC is a Russian company and wholly?owned
subsidiary of Defendant Sberbank Russia that, according to its website, manages assets, provides
?nancial consultancy, and makes direct investments, including the creation of new and
acquisition of existing businesses. Defendant Sberbank Capital was a key participant in the
conspiracy that undertook direct actions meant speci?cally to strip Majority Shareholders of their
assets and created the conditions for other co?Defendants to likewise take such actions.

'16. Defendant JSC National Aggregates Company (NAG) is one of the largest
crashed stones (including granite) company in Russia and it is owned by Defendant Zhukov.
Until 2010, P?Granit was the main competitor of Defendant. NAC. Defendant implemented
the conspiracy developed by Zhukov and emerged as the new owner of P-Granit?s assets.

17. Defendant NEO Centre LLC is a Russian appraisal company established in 1997.
Defendant Oleg Gref owns 19.9% of the company. Defendant NEO Center appraised the shares

of P?Granit at a value grossly below market value, which created the conditions for the

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implementation of the conspiracy to transfer P-Granit shares to Defendants Zhukov and NAC.
Defendant NEO Center also appraised the shares of Defendant NAC in 2009?2010 supposedly
for the purpose of negotiating a loan with Defendant Promsvyaz?oank. Although assets
constituted a fraction of P-Granit?s real value, NEO Centre appraised NAC at a value of RUR
7,607,172,909 (seven billion six hundred and seven million one hundred seventy two thousand
nine hundred and nine), equivalent to USD 257,908,736 (two hundred fifty seven million one
hundred nine thousand seven hundred thirty six) that is 2.48 times higher for the supposed
purposes of receiving the loan from PSZB compared to the NAC de?ated valuation of P-Granit
shares which were valued by NEO Centre at 3,145,969,598.00 mbles, equivalent to USD
103,654,622.00 on the date of valuation.

18. Defendant Promsvyazbank PAO is a Russian-based commercial bank.
Defendants Aletarro, Nisoram, Suintex, and Urasay opened bank accounts at branch
of?ce in Limassol, Cyprus that were used to funnel the proceeds of the crime and make
payments to Defendants Sberbank Russia and. Sberbank Capital. Atlantic LLC also had accounts
with PSZB in Moscow. PSZB uses the following banks for payments in US. dollars: Deutsche
Bank Trust Company Americas, New York, NY, JP Morgan Chase Bank, New York;
American Express Bank, and; The Bank of New York. PSZB also participated. in the conspiracy
by misrepresenting to P-Granit the intent to restructure Sberbank Russia?s debt, and; (ii)
improperly disclosing P~Granit?s con?dential information to further the conspiracy to steal the

company while masking the role of Zhukov.

b. Defendant Offshore Companies

19. Defendant Klever Group Limited (?Klever?) is a Cyprus corporation specializing

in private equity investments and owned by Defendant Zhukov. Klever has a representative

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of?ce in Moscow, and the company uses the brand name ?Klever Asset Management.? Klever
owns Defendant Klever Internet Investment. Defendant Shirin is the Director of Defendant
Kiever. Co-conspirator Mayorova is the CFO of Klever.

20. Defendant Klever Internet Investment is, upon information and belief, a,
British Virgin Islands special-purpose vehicle established by Klever in order to diversify
exposure in Internet technology markets. Defendant KII kept all its investment in Russia until
2014, when?using the proceeds of P-Granit?s raidmit participated in the investment to
purchase a minority interest in CityAds Media Inc., which operates in the US. through its of?ce
in Alexandria, VA. Further, in 2015, K11 made an additional the 
Series round of funding?in Humanity.cern Inc, a company incorporated in California and
headquartered in San Francisco. Defendant Shirin is a Director of K11.

21. Defendant Aletarro is a company incorporated in Cyprus. Aletarro?s director is
eo-conspirator Georgios Charalamous. Defendant Sberbank Capital assigned 11.37% of Vitera?s
shares in P-Granit to Defendant Aletarro. Upon information and belief, Defendant Aletarro is
owned by Defendant Zhukov. Aletarro?s corporate secretary was, during the relevant time,
Totalserve Management, a services company based in Cyprus with registered of?ces at 17 Gr.
Xenopoulou Street, Limassol 3106, Cyprus that subsequently became C. ARGYROU 
ASSOCIATES SECRETARIAL LTD. In 2014, Defendant Sberbank Russia granted C.
ARGYROU ASSOCIATES SECRETARIAL LTD 8. contract for providing services with
regard to debt collection. Defendant Aletarro entered into service agreements with co-
conspirator PI for the implementation of this illegal scheme.

22. Defendant Nisoram Holding is a company incorporated in Cyprus at the same

address as Defendant Alettaro. At the time of the Reiderstvo in question, Nisoram also used

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Totalserve Management as company secretary. Defendant Sberbank Capital assigned 25% of
Vitera?s shares in P-Granit to Defendant Nisoram. Defendant Nisoram then entered into service
agreements with co?conspirator PI for the implementation of the illegal scheme. The bene?cial
owner of Nisoram is unknown.

23. Defendant Urasay is a company incorporated in the British Virgin islands.
Defendant Urasay, like Alteraro and Nisoram, hired Totalserve Management as company
secretary. Co?conspirator Trade LLC, which acquired 24.67% of Mr. Poymanov?s shares in 
Granit at the auction where the other bidder was Defendant Sberbank Capital, transferred those
shares to Defendant Urasay. Defendant Urasay then entered into service agreements with co-
conspirator PI for the implementation of the illegal scheme. Upon information and belief,
Defendant Zhukov is the bene?cial owner of Urasay.

24. Defendant Mostra Consulting is a company incorporated in the British Virgin
Islands that owns 100% of the shares in Atlantic LLC. Totalserve Trust is also the registered
agent of Mostra. Under Defendant Atlantic?s loan agreement with Defendant Sberbank Russia to
?nance its obligations to Sberbank Capital under the Assignment Agreement, Atlanticmbeing
the new owner of P?Granit shares?could be sold by its sole shareholder/co-conspirator Natalia
Mayorova to Mostra Consulting. Upon information and belief, the end beneficial owner of
Defendant Mostra is Defendant Zhukov.

25. Defendant Suintex is a company incorporated in the BVI in 2012 by Defendant
Klever for the purposes of implementing the conspiracy and laundering money out of Russia. In
2013, the new shareholders of P?Granit?Defendants Aletarro, Nisoram, Urasay, and Atlantic
LLC?voted to sell the rights of claim to Defendant Suintex at a fraction of their value. Upon

information and belief, the end bene?cial owner of Suintex is Defendant Zhukov.

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c. Russian Individual Defendants

26. Defendant German Gref is a citizen of the Russian Federation and the CEO and
Chairman of the Executive Board of the Sberbank of Russia. Defendant German Gref is also a
close associate of Defendants Khachyatureants and Zhukov. Defendant German Gref met with
Zhukov during and in furtherance of the conspiracy by, inter alia, engaging in: a pre?detennined
restructuring process through phony negotiation of the restructuring; a manipulation of the
appraisal of P-Granit shares; baseless criminal proceedings, and; shielding Zhukov?s
participation in the endeavor.

27. Defendant Oleg Gref is a citizen of the Russian Federation and the Vice President
of Defendant NEO Centre, a Russian appraisal company. Defendant Oleg Gref is a close
associate of Defendant Zhukov and worked on appraisals for his company, Defendant NAC.
Defendant Oleg Gref engaged in multiple communications with Zhukov during and in
furtherance of the conspiracy by, inter alia: supervising the bogus and arti?cially-deflated
appraisal ofP-Granit; improperly disclosing PuGranit?s con?dential information, and; laundering
the P?Granit shares. Defendant Oleg Gref owns 199% of Neo Center.

28. Defendant Ashot Khachyatureants is a citizen of the Russian Federation and the
CEO of Sherbank Capital. Defendant Khachyatureants worked for Defendant German Gref at
the Ministry of Finance and is now part of his inner circle. Defendant Khachyatureants is also a
close associate of Defendant Zhukov. Defendant Khachyatureants participated in and furthered
the conspiracy by, inter alia, engaging in: a predetermined restructuring process through phony
negotiations; a manipulation of the appraisal of P?Granit shares, and; the shielding of Zhukov?s
participation.

29. Defendant Yuriy Zhukov is a citizen of the Russian Federation, the founder of

PIK Group, a publicly?traded company on the London Stock Exchange, and the owner of
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Defendant NAC. Defendant Zhukov is also a close associate of the Defendants Gref and
Khachyatureants and, according to media reports, was proposed to be the CEO of a new
Sberbank Russia subsidiary, overseeing real estate assets. Defendant Zhukov drove the
conspiracy by, inter alia: interfering with and corrupting P-Granit?s restructuring process;
manipulating the criminai justice and bankruptcy court proceedings against Poymanov and P-
Granit, and; concealing his acquisition of P?Granit.

30. Defendant Kirill Nogotkov is a Russian citizen and the receiver appointed to
oversee the estate of P-Granit Invest in 2013. Defendant Nogotkov is a member of Delo, the
selfwregulated association of independent receivers. Defendant Nogotkov has been an active
participant in the conspiracy to raid P?Granit. He has followed Defendants Zhukov and Shirin
and co-conspirator Kuznetsov?s instructions. In furtherance of the Reiderstvo, Defendant
Nogotkov has improperly: a) disclosed P?Granit Invest con?dential and proprietary information
to co-conspirator Kuznetsov; tiled baseless criminal charges against Mr. Poymanov; c)
initiated civil proceedings in Cyprus court, and; d) adopted and approved bankruptcy plans for 
Granit Invest that were intended to bene?t the conspiracy rather than the entity or its creditors.
Delo is same the receivers? association whose members are involved in Mr. Poymanov?s
personal bankruptcy and in the ongoing attacks against William Browder and Hermitage Capital.
The latter attack is part of the infamous case of Sergei Magnitsky, which was the basis for both
the Russia and Moldova Jackson?'Vanik Repeal and the Sergei Magnitsky Rule of Law
Accountability Act of 2012, PL. 112-208 (December 14, 2012), referred to as the ?Magnitsky

Act," as well as for the issuance of sanctions by the US. government.

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31. Defendant Alexey Bazarnov is a Russian citizen and the receiver appointed to
oversee the personal bankruptcy of Mr. Poymanov. Bazarnov, like Defendant Nogotkov, is a
member chelo, the selfnregulated association of independent receivers.

32. Defendant Zoya Galeeva is a Russian citizen and employee of Defendant Project
Industry. Defendant Galeeva coordinated and implemented the Reiderstvo actions against P-
Granit and the majority shareholders. Defendant Galeeva also has a close personal relationship
with Kuznetsov, Shirin, and Kublitskiy and acted in close coordination with them.

33. Defendant Sergey Kublitskiy is a Russian citizen and former law enforcement
agent who is now reputed to be a member of organized crime. Alexander Litvinenko, the former
of?cer who died in London of plutonium poisoning, reported that Defendant
Kublitskiy was responsible for the killing of the mayor of Nefteyugansk (a crime Russian
prosecutors now attribute to ex?political prisoner Mikhail Khodorkovsky).

d. U.S. Defendants

34. Defendant Gregory Shirin is a U.S. citizen currently residing in Moscow.
Defendant Shirin is the Director of both Defendants Klever Asset Management and Kll.
Defendant Shirin is also a close associate of Defendant Zhukov who participated in the majority
of the meetings between Defendants Zhukov, NAC, and Mr. Poymanov in 2010, prior to
Defendant Sberbank Russia?s refusal to restructure P?Granit?s debt. Defendant Shirin
participated in and furthered the conspiracy by, inter alia, engaging in: a predetermined
restructuring process through phony negotiations; a manipulation of the appraisal of P?Granit
shares, and; the shielding Zhukov?s participation. Defendant Shirin was, at the time of the
described events, and is currently a member of the Board of NAC.

35. Defendant Sberbank CIB USA, Inc. is a company organized in 1997

under the laws of the State of Delaware with its principal place of business and headquarters

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located in New York, New York. Defendant SCIB is a registered broker-dealer pursuant to
Section 15(b) of the Securities and Exchange Act of 1934. The company is also registered as an
Introducing Broker with the Commodity Futures Trading Commission and is a member of the
National Futures Association. is a wholly-owned subsidiary of Troika Dialog Group
Limited, which is an indirect subsidiary of Defendant Sberbank Russia. Upon information and
belief, Defendants used Defendant SCIB to launder the instrumentalities and proceeds of the

wrongs described below through US. banks.

2. Co-conspirators

36. Alteom Chayka is a Russian citizen, the son of the Attorney General of Russia,
Yuriy Chayka, and the owner of which is currently the largest producer of granit in
Russia. Chayka has stated publicly his intent to acquire major companies in the crushed stone
industry, including P?Granit, the industry leader in Russia. Chayka furthered the conspiracy by
using his family in?uence to manipulate both criminal justice and bankruptcy court proceedings
against Mr. Poymanov, with the ultimate goal of overtaking some of P?Granit?s assets.

37. Vladimir Lelukh is the general counsel of Defendant Sherbank Capital. Lelukh
provided Chayka with con?dential information concerning P?Granit and coordinated with
Defendant Zhukov to render impossible the restructuring of PuGranit?s debt. Lelukh sits on the
board of director of Chayka?s company, First Non~0res Company.

38. CJ SC (closed joint stock company) Project Industry is a Russian company
specializing in asset and debt recovery, business recovery, and mergers and acquisitions.
Defendant Sberbank Russia is a client of PI. Kuznetsov, an officer of PI and co-conspirator
under the direction of Defendants Zhukov and Shirin, implemented the conspiracy. Acting
informally until 2011, PI entered into servicing agreements with Defendants? offshore companies

Aletarro, Nisoram, and Urasay to provide legal services including, but not limited to: organizing

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a general meeting of P-Granit?s shareholders; electing four nominees to the Company?s Board of
directors from the customer?s nominees, and; ultimately liquidating P?Granit. As employees of
Defendant PI, Galeeva and Potolitsyn were straw men, organizers and actual coordinators and
directors for multiple companies, including offshore companies involved in the scheme.

39. Atlantic LLC is a Russian company incorporated in November 2011 by co?
conspirator Mayorova, who is an of?cer of Defendant Klever under Defendant Zhukov?s control.
In December 2011, Defendant Sberbank Capital entered into an assignment agreement with co-
conspirator Atlantic for its rights under the P-Granit Loan Agreement and the various security
pledges. Atlantic received a loan for this purpose from Defendant Sberbank of Russia, which
was approved by Defendant German Gref. The loan was based upon a resolution of Defendant
Sberbank Russia?s credit committee on December 21, 2012 that relied on events that had not yet
taken place?e.g., auctions that were organized later with winners yet unknown?thus allowing
co-conspirator Mayorova to transfer the shares in Atlantic to Mostra and pledge P-Granit shares
that had not yet been acquired. After the original assignment, Atlantic re?assigned this debt to
the new debtor, Defendant NAC, with the transfer of what was left of P-Granit assets, after
which, having served its purpose as the straw company of the conspiracy, Atlantic was
liquidated.

40. Andrey Kuznetsov is a Russian citizen and employee of co?conspirator Project
Industry. Co-conspirator Kuznetsov coordinated and implemented the Reiderstvo actions against
both P-Granit and Majority Shareholders. Kuznetsov was the contact person for Defendants
Zhukov and Shirin, and acted as the main coordinator of all activities.

4i. Andrey Potolitsyn is a Russian citizen and an employee of Project Industry. Co-

conspirator Potolitsyn coordinated and implemented the Reiderstvo actions against P-Granit and

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Majority Shareholders. Co?conspirator Potolitsyn is under Defendant Galeeva?s control and,
together with Kuznetsov, acted in the interests of Defendant Zhukov. In August of 2012, cc?
conspirator Potolitsyn became the General Director of Atlantic, acquired by Mostra, and
throughout the conspiracy acted together with the Defendant Sberbank, Capital managers and
other co?eonspirators.

JURISDICTION AND VENUE

42. This Court has jurisdiction pursuant to 28 U.S.C. 1332(a) on the grounds that
the amount at issue exceeds $75,000, that Plaintiff is a citizen of the State of Delaware, and that
two of the Defendants are citizens of the States of New York and California, respectively.

43. Jurisdiction over Defendant Sberbank Russia is proper in this court on the
grounds that Defendant trades Level II ADRS on the New York Stock Exchange, conducts
business within the United States directly and through its subsidiary Defendant SCIB, and has
purposefully availed itself of this Court?s jurisdiction in previous litigation.

44. Jurisdiction over Defendants Klever Asset Management and Klever Internet
Investments is proper on the grounds that Defendants participated in both a $9,000,000 capital
raise for Humanitycom lnc., a California corporation, and in the investment to purchase a
minority interest in CityAds Media Inc, which operates in the U.S. through its of?ce in
Alexandria, VA.

45. Jurisdiction over Defendants PSZB, Aletarro, Nisorani, Urasay, Atlantic, Mostra
Consulting, and Suintex is proper on the grounds that Defendants furthered the conspiracy at
issue by conducting transactions in US. dollars using U.S. banks.

46. Jurisdiction over Defendants Sberbank Capital, NEO Center LLC,
Khachyatureants, Zhukov, Shirin, Nogotkov, Bazarnov, Galeeva and Kublitskiy is proper on the

grounds that they are all co?conspirators who committed acts in furtherance of a conspiracy

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which they knew included. acts in the United States, such as investing in US. businesses and
using US. banks for the transfer of the money and/or US. dollar payments for the assets of P-
Granit.

47. Venue is proper in this Court fer all Defendants pursuant to 28 U.S.C. 
l39l(c)(3), which authorizes an action against an alien in any district. Venue is additionally
proper in this court for all Defendants pursuant to 28 U.S.C. 1391(b)(2) because substantial
actions in furtherance of conspiracy giving rise to Plaintiffs claims, including the use of US.
banks and businesses for the transfer of US. dollar payments for the assets of P~Granit, occurred
in this District. Venue is proper in this court for Defendant Sberbank CIS US pursuant to 28
U.S.C. l391(b)(1) and as the judicial district of its principal place of business. Venue
also is proper in this court for Defendants Sberbank Russia, Sberbank CIS USA, lnc., and
German Gref, pursuant to 28 U.S.C. 13910)), and 

IV. STATEMENT OF FACTS ALLEGATIONS RELATING TO ALL COUNTS

I. BUSINESS

48. Before the events described below, Mr. Poymanov was the owner of P-Granitm?a
successful business with a substantial quarrying operation, extensive real property and various
production facilities. P?Granit was the largest employer in Pavlovsk, Russia, and a major
taxpayer and corporate contributor to the local economy. P-Granit also produced non-military
explosives and was considered a strategic company under a special Anti-MonOpoly and
Economic regime which prevents the sale of any interest in the company to a foreignwowned
corporation without prior disclosure of the bene?cial owner(s) and approval by a special
Government committee on foreign investments into strategic companies.

49. In 2008, Mr. Poymanov owned approximately 90% of P?Granit directly or

through other companies. The share structure was: Mr. Poymanov 24.67%; (ii) P-Granit

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Invest 29.46% through PNH (a Cyprus company owned by Mr. Poymanov); Vitera LLC
36.37% (Vitera was owned 50%/50% by Mr. Poymanov and PNH), and; (iv) individual minority
shareholders 9.4% (Ms. Podgornaya and Mr. Poyrnanov?s father and brother).

2. P-GRANIT LOAN

50. In early 2008, Mr. Poymanov decided to have P~Invest acquire 100% of PNH and
consolidate his interest in P-Granit. Accordingly, on August 8, 2008, he entered into a credit
facility agreement with the Central Black-Earth Region Bank a branch of
Defendant Sberbank Russia (the ?Loan Agreement?) for RUB 5,100,000,000 
The Credit and Risk Committee of CBERB reviewed the company?s ?nancial records and
reports and did not report any negative information about the company or Mr. Poymanov,
personally. CBERB concluded that P?Granit was in sound ?nancial standing and made the loan.
The repayment schedule provided for instalments, the last instalment being due on July
31, 2015.

51. The Loan Agreement provided for a series of pledges: 1) business and real
property valued at ll. billion 990 million rubles; 2) 99% of shares in the authorized capital of P-
Granit and other assets, including Mr. Poymanov?s personal assets, and also personal guarantees
by Mr. Poymanov which subsequently lead to seizure of his other assets not directly related to P-
Granit. Although it was represented that Mr. Poymanov?s personal guarantee was requested as a
mere ?formality?, it was later used against him to declare him bankrupt. The pledged P?Granit
shares included those Mr. Poyrnanov and acquired with the CBERB loan.

52. As part of the loan CBERB required that P?Granit enter into various agreements
providing for extrajudicial foreclosure of the pledged shares. These agreements gave the creditor
the right to make a claim under the various pledge agreements without recourse to a court, either

by: taking ownership of the pledged shares with the price of the pledged security being
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determined in good faith by an independent appraiser; or (ii) selling the pledged security either
through an auction held in compliance with the applicable Russian law or by direct sale to a third
party by lawful means and on terms which ensure payment of the true vaiue of the assets.

53. P~Granit Invest paid a total of 730 million rubles of the principal and billiOn
rubles in interest during the time the loan was recorded on the books as a term loan asset. The
Credit Control Departments of Sberbank Russia and CBERB, respectively, audited the loan and
concluded that initially there were no irregularities.

3. RAIDERSTVO THE THEFT 0F MAJORITY 
INTEREST IN BUSINESS

54. Russian?style illegal raiding is a well-developed four~stage process:
(1) preparation - constitutes the selection of a target, assessment of the related risks and bene?ts,
and collection of information about a business, its owners, and their activities; (2) negotiation -
constitutes the raiders? contacts with the targeted business owners, ?nance, black PR campaigns,
lawsuits, blackmail or intimidation tactics; (3) execution constituting, after a legal owner
refuses to capitulate to the raiders, the use of forgery and fraud, malicious prosecution,
regulatory harassment, misuse of the banking system, violence and black and (4) legalization
once a takeover is completed and raiders initiate the laundering of their illegally acquired
property and funds. Defendants have followed all four steps to strip Majority Shareholders of
their P-Granit shares and, and concomitantly, P-Granit?s assets. As a result of the actions taken
in furtherance of the conspiracy, described below, P-Granit is now effectively part of Defendant
NAC which is owned and controlled by Defendant Zhukov.

55. The conspiracy was to a) sell all the secured assets of P~Granit, at below
distressed values; b) transfer them offshore; c) avoid detection of any connection to Defendant

Zhukov; d) transfer each parcel back to Defendant NAC through these offshore entities; and e)

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collect them together and repatriate them into one company under the auspices of the Defendant
NAC for the bene?t of Defendant Zhukov.

56. To launch the conspiracy, Defendant Sberbank Russia negotiated in bad faith, as
the restructuring of the debt was never intended to offer Majority Shareholders reasonable
conditions for restructuring. During this phase, co-conspirator Lelukh was funneling PuGranit
information to co?conspirator Chayka and Defendants Zhukov as they were planning and starting
the implementation of the illegal takeover.

57. Further, Defendants manipulated the valuations of P-Granit by having them
prepared by the company believed to be owned by Defendant Oleg Gref. Gref was the Vice?
President of Neo Center of which he owns 19.9 since February 20, 2013. The value attributed by
Sberbank Capital based on the Neo-Centre Report. was in stark contrast to the value attributed by
Sberbank at the time of the original loan. For example, Sberban?k division with whom Mr.
Poymanov organized the Loan Agreement valued the PNH/Zinica shares at approximately the
loan amount of 5,100,000,000 rubles. Yet, Neo Center Valued the entire P-Crranit at
3,145,969,598 rubles. This amount was less than the outstanding debt, and less than 13+ billion
rubles the value of P-Ganit in 2008 2010. The Vitera shares were taken away at valuation of
1,144,189,143 rubles, when the real value was 4.5 billion rubles. Subsequent reports valued it at
lower than this amount. None of the appraisers made any requests to P-Granit for information on
its activities, including any ?nancial or operational parameters.

58. Defendant Sberbank Capital initiated the transfers of shares to companies out of
Russia, and into Cyprus. Within just one day of receiving the Vitera shares,?Sberbank Capital
transferred the shares into Nisorarn and Aletarro, both of which are owned, controlled by or

otherwise connected to Defendant Zhukov, the owner of Defendant NAC.

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59.

Despite the fact that the shares were transferred using three different procedures,

they were all transferred ultimately to the Defendant NAC. The following acts were committed

in furtherance to the conSpiracy:

1.

Defendants communicated during the conspiracy in order to develop tactics and
share details on the progress of the conspiracy among themselves.

Defendants incorporated Aletarro, Urasay and Atlantic speci?cally for the
purpose of the conspiracy. Defendant Nisoram was an off?the?shelf company.
Defendants auctioned Mr. Poymanov?s shares at below market value to LLC
Trade which re-directed the shares to Urasay, another company linked to
Defendant Zhukov.

Defendants Sberbank Russia and German Gref included the name of the winner
of an auction in one of the assignment agreements before the auction was held,
and allowed in the same Credit Committee decision the sale of Atlantic to an
offshore company in order to conceal Zhukov was behind the scheme.
Defendants obtained a low valuation by a company known as PAC and used it as
a basis to justify the extra?judicial foreclosure of the PNH/Zinica shares at a
price substantially below market value.

Defendant Sberbank Russia ?nanced Defendant Atlantic for the purpose of
illegal acquisition of the P-Granit shares and took pledges over the shares of
Nisoram, Aletarro and Urasay in P~Granit.

Defendants opened fabricated criminal cases against Mr. Poymanov and

attempted to block his efforts to seek relief in Cyprus. The Defendants

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collaborated with the individuals associated with infamous raider Kluyev
included in the Magnitsky list.

8. Defendants took advantage of captured courts and bankruptcy court procedures
and personnel.

9. Defendants used US intermediary banks to make payments during the
implementation of the conspiracy.

60. Defendants invested alleged proceeds of the conspiracy in the 

B. Phase one - PREPAMTION

61. In late 2008 and the ?rst half of 2009, the global economy in general caused
unfavorable market conditions in Russia and specifically resulted in a considerable decline in the
demand for, and the price of, P?Granit?s products. Therefore, in July 2009, P?Granit approached
CBERB to restructure the loan, seeking a 2-year extension of the loan and a principal payment
deferral.

62. In August 2009, Mr. Poymanov and CBERB discussed restructuring the loan, and
CBERB proposed draft terms that Mr. Poymanov found acceptable. CBERB concluded that
under the new terms of the loan, P-Granit would be in a position to timely and fully settle all of
the obligations under its Loan Agreement with the bank.

63. Although CBERB issued preliminary approval for the restructuring of the loan,
the Sberbank Russia Loan and Investment Committee of Defendant had to review and approve
the opinion regarding the feasibility of the restructuring. . Thus, on November 18,
2009, the Sberbank Russia Loan and Investment Committee endorsed the proposed restructuring
parameters, but added an extreme provision: the transfer of 51% of P-Granit?s shares to

Defendant Sberbank Capital?s books within 3 months, with the right to repurchase them upon

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repayment of the loan (hereinafter ?Zhukov/Sherbank ?deal?). In addition, Defendant Sberbank
Russia demanded that control of the Board of Directors of P-Granit be transferred to Defendant
Sberbank Russia?s subsidiary Defendant Sberbank Capital.

64. Defendant Sberbank Russia gave Mr. Poymanov a very short time to assess its
additional demands. The failure to accept these requirements would void the offer to restructure,
and the original loan immediately would become due and payable.

65. The aforementioned restructuring presumed major changes to the loan agreement:
the terrn was extended through July 31, 2017 with payments deferred through March 27,
2010, and (2) an interest rate of 14.75% per annum, with interest payment. If Mr.
Poyrnanov did not consent to Sberbank?s additional demands the restructuring would consist of a
repayment deferment only through February 27, 2010.

66. Between August 2009 and January 2010, CBERB staff, including the CBERB
Chairman, Mr. A.K. Soloviev, who also served as the Deputy Chairman of the Board of
Directors [of Sberbank Russia], conducted repeated negotiations with SP. Poymanov regarding
the implementation of Defendant Sherbank Russia?s proposal. Later, after the debt was assigned
to Sberbank Capital, negotiations were held with the participation of Defendant Sberbank
Capital.

67. In essence, Defendant Sberbank Russia demanded a deal that created a situation
whereby Mr. Poymanov, essentially, was handing over control of his company to the bank. The
transfer of 51% of the shares and change of management meant that Mr. Poymanov would give
up all control of the business, and there were zero guarantees that the changed management
would attempt to arrange for repayment of the loan rather than make sure the company stayed in

default and was taken over. The condition of the transfer of 51% for the nominal amount of 

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million rubles and the buyout for 350 million rubles following successful repayment of a
signi?cant part of the loan more than 10 million at the then rate was also outrageously
excessive. Mr. Poymanov refused to accept the offer. He knew of Sberbank Capital?s prior
record of acquiring 51% of a company that was in distress for the purported purpose of
restructuring, but ultimately bankrupting the company and selling its assets. For example,
Mosmart, the Russian mega-company owning multiple malls, defaulted on a Sberbank Russia
loan in 2009 and as part of the restructuring Sberbank Capital insisted in acquiring 51% of its
shares. Nonetheless, despite obvious ?nancial restructuring opportunities, Sberbank Capital
initiated bankruptcy proceedings against the company and sold its assets.

68. Instead, Mr. Poymanov tried to save P-Granit from a Mosmart fate and offered to
transfer 25% plus 1 share of P-Granit to Defendant Sberbank Capital. Defendant Sberbank
Russia refused this counter offer and retaliated by demanding that CBERB transfer the debt from
its books to the books of Defendant Sberbank Capital and declare P~Granit indefault. At
subsequent negotiations at Sberbank Capital, of which there are voice recordings and transcripts,
it was con?rmed that the goal of Defendant Sberbank Capital was ?to change the owners? of P-
Granit.

69. Defendant Sberbank Russia was well aware that P-Granit could not meet the
shortened deadline, and on March 19, 2010, it issued a formal demand for immediate repayment
of the entire outstanding amount under the Loan Agreement RUB 4,457,364,65200
(equivalent to USD 

70. Contemporaneously, between August 2009 and February 20l0, Defendant

Zhukov, collected con?dential and proprietary information about P-Granit?s business in

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preparation for the illegal takeover. Several of the sources of the information were subject to a
duty to keep the information con?dential.

Speci?cally, further in 2010 Defendant Galeeva, together with co?conspirators
Kuznetsov and l?otolitsyn, illegally obtained con?dential information on both P-Granit and
Majority Shareholders, by bribing local government of?cials. Speci?cally, Galeeva secured
con?dential information regarding the ?nancial and business activities of P?Granit from the
Deputy Head of Control and Audit Department of the Voronezh Region Government.

C. Phase two - NEGOTIATION

72. Between November 2009 and February 2010, while Mr. Poymanov was
negotiating in good faith to restructure P-Granit?s debt, Defendants German Gref and
Khachyatureants conspired with Defendant Zhukov to devise and demand conditions that
compelled Mr. Poymanov to seek alternative possibilities for the restructuring of the debt.
Eventually, Mr. Poymanov had no viable alternative but to accept the Zhukov/Sberbank ?deal?
in order to salvage a long~shot opportunity of keeping a small portion of his business and not to
be declared bankrupt. 

73. In the beginning of 2010, Mr. Poymanov met Defendant Zhukov during the
meetings on the creation of an Association of the Russian stone and granite producers that
Defendant Zhukov feigned an interest in forming. Defendant Shirin represented Defendant NAC
at the meetings.

74. During one of these meetings, Defendant Zhukov approached Mr. Poymanov and
said that he is aware of Poymanov?s dif?culties regarding restructuring Sberbank?s loan.
Defendant Zhukov made the unsolicited aggressive proposal that Mr. Poymanov should merge
P-Granit with his company, Defendant NAC. Defendant Zhukov?s promised to ?x all the

challenges faced by P?Granit, speci?cally including that he guaranteed that he could persuade
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Defendant Sberbank Russia to restructure its debt on favorable terms. Defendant Zhukov
boasted that he was on friendly relations with Defendant's Gref and Khachyatureants.

75. In February 2010, a couple of days prior the expiration of the one month
extension granted by Defendant Sberbank Russia, Defendant. Zhukov presented Mr. Poymanov
with a an ?offer? to form a ?NewCo.? The terms included the establishment of a new business
entity with an ownership interest distribution of 70 to Defendants NAC and 30 to P~Granit.
Defendant Zhukov told Mr. Poymanov that the new company would apply for a loan to
Defendant PSZB to fully repay P-Granit?s Sberbank loan.

76. In February 2010, Defendant Shirin and other NAC employees had multiple
meetings with Mr. Poymanov to discuss a merger.

77. In summer of 2010 Zhukov offered to Poymanov to use PSZB to restructure the
debt, for which purposes introduced him to Mr. Ananyev. In December 2010, Mr. Ananyev
offered Mr. Poymanov to apply separately for a loan to repay Defendant Sberbank Russia?s loan.
The Director of Defendant PSZB, Dmitry Ananiev, continued the bank?s availability to provide
the re?nancing needed to extinguish the Sberbank debt.

78. P-Granit, based solely on the premise that it was negotiating a re-?nancing solely
on its own behalf, provided all the documents, including con?dential and proprietary data,
requested by Defendant PSZB to review the issue of re-??nancing. In violation of Russian
banking secrecy law and breaching the ?duciary duty to P?Granit, Defendant PSZB conspired
with and Defendants Khachyatureants, Zhukov, Shirin and co-conspirator Lelukh and Chayka
disclosed all 'P?Granit con?dential and proprietary information.

79. in early March 2011, shortly before the PSZB Credit Committee was to meet on

the P~Granit loan, Mr. Ananyev called Mr. Poymanov on his cell phone and told him that,

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despite the necessary economics and ?nancial information for a positive decision, PSZB would
not be moving forward with P?Granit. Mr. Ananyev stated that he was instructed by Defendant
Khachyatareants to deny P?Granit the loan. Mr. Ananyev said that the stakes were too high for
his bank to be on bad terms with Defendants Sberbank Russia and Sberbank Capital, plus he
could not afford to jeopardize his relationship with Defendants Gref and Khachyatureants. Mr.
Anayev said that if. Mr. Poymanov convinces Defendant Khachyatnreants not to object,
Defendant PSZB would come back and issue the re?nancing loan.

80. As it became known later, during the time Mr. Poymanov was negotiating with
Defendant PSZB and co?conspirator Ananyev, Defendants Aletarro (in March 2011), Nisoram
(in September 2010) and Urasay (in July 2011) were opening bank accounts with Defendant
Cyprus branch to receive funds in US dollars from offshore companies associated with
Defendants Zhukov and Klever Group, such as Maritrade Investment Limited, Monbee Trading
Limited and to transfer money to Defendant Sber?oank Capital as alleged consideration for the P-
Granit shares assignment.

81. Throughout the conspiracy, Defendant Zhukov was informing Defendant German
Gref on the progress of his securing ownership of P~Granit For example, on May 25, 2013,
Defendant Zhukov in a phone conversation with Defendant Shirin told him that he had discussed
P~Granit related issues with Defendant Gref earlier in the day.

82. During the meetings with Mr. Poyrnanov in August 2010, Defendant Zhukov
threatened Mr. Poymanov that, if he declined the merger offer, the P??Granit group would face
major difficulties in its relationship with Defendants Sberbank Russia and Sberbank Capital. Mr.

Poymanov rejected Defendant Zhukov?s ?offer.? Immediately thereafter, Defendants oo-

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conspirators took a series of actions aimed at essentially stealing P?Granit?s shares for the bene?t
of Defendant Zhukov and the co-defendants.

D. EXECUTION OF THE SCHEME

1.. Transfer of P-Granit Debt to Defendant Sberbank Capital Criminal
Investigation against Mr. Povmanov

83. While P-Granit thought it was independently negotiating with Defendant
Sberbank Russia to restructure its loan and with Defendant PSZB to apply for and receive a new
loan to repay Sberbank Russia, Defendant co-conspirators already were readying to steal P-
Granit if Mr. Poymanov did not accept Defendants Zhukov and sweetheart deal.
Between March 2010 and June 2013, Defendants planned and implemented a series of
assignments under the Loan Agreement to multiple companies that owned by or for the bene?t
of Defendants Zhukov and other unknown bene?ciaries.

84. On May 20, 2010 Defendant Sherbank Russia assigned all its interests under the
Loan Agreement to Defendant Sberbank Capital LLC by entering into an Assignment Agreement
of Rights with Sberbank Capital (?Assignment Agreement?).

85. Immediately thereafter, P-Granit realized that Defendants had manipulated the
situation as to all of them so as to shield themselves from the Courts and the public disclosure of
Zhukov?s interests by invoking the out?of?court settlement clause they had forced P-
Granit/Poymanov to accept in the Loan Agreement. P?Granit/Poymanov ?led a claim with the
local court in Voronezh to nullify the clause. That claim, along with the other 60 claims ?led by
P-Granit between May 2010 and August 2016 in courts of different jurisdictions, predictably was
rejected by the Russian Courts. The court proceedings were tainted with multiple procedural
rights violations, for example: failing to provide Mr. Poymanov?s counsel suf?cient time to

study the court ?ling; (ii) appointing an appraiser who had a con?ict of interests and who had

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been accredited professionally by Defendants German Gref; failing to admit into evidence
properly authenticated documents favourable to Mr. Poyrnanov?s position; and (iv) approving
auctions conducted without proper notice to Mr. Poymanov. Defendant Chayka was involved in
court proceedings against P-Granit through Elizaveta Berezina and her law ?rm ?Zvezda
Resource? that acted as the outside counsel of Defendant Sberbank Capital in the litigations with
Mr. Poymanov over the shares and assets of P-Granit.

86. On July 6, 2010, Defendant Sberbank Capital ?led. a claim in the Arbitrazh Court
of Voronezh District for the recovery of RUB 4,649,293,410 under the pledge agreements. The
court granted Defendant Sberbank Capital?s claim on July 3, 201 l.

87. Thus, Defendant Sberbank Capital sought a court order against all P-Granit?s
property mortgaged as a guarantee for loan payment and valued as at 11 billion 990 million.
rubles and 99% of shares in the authorized capital of P?Granit. Pursuant to the Loan and
Assignment Agreements, Defendant Sberhank Capital could enforce the court order either by: 
taking ownership of the pledged shares with the price of the pledged security being determined
in good faith by an independent appraiser; or (ii) selling the pledged security either through an
auction held in compliance with the applicable Russian law or by direct sale to a third party by
lawful means and on terms which ensure payment of the true value of the assets.

88. Defendants conspired to falsify the fair market value of the assets by engaging
captured appraisers who joined the conspiracy and helped rig the auctions. Defendants Sberbank
Russia and German Gref included the name of the winner of an auction in one of the assignment
agreements before the auction was held.

89. Between July 2010 and fall 2010, P?Granit unsuccessfully ?led counterclaims to

nullify the assignment agreement between Sberbank and Sberbank Capital. While using all

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available legal actions in local courts, Mr. Poymanov brought Defendants? conspiracy into the
public limelight. He published open letters addressed to Defendant German Gref, and then wrote
letters to the then Prime Minister of Russia, new President V.V. Putin.

90. In response to his persistence and resilience, Defendant Chayka had used his
family connection, as the son of the attorney General of the Russian Federation, to commence
and continue criminal investigation against Mr. Poymanov to pressure him to relinquish his
rights and claims regarding illegal takeover of PuGranit. Defendant Sberbank Capital in the
person of Defendant Khachyatureants ?led a criminal complaint with the law enforcement in
Voronczh claiming that Mr. Poylnanov was attempting to bankrupt P-Granit.

91. Later, in 2011 Defendant Sberbank Capital filed a bankruptcy petition itself to the
Voronezh oblast Arbitrazh court. Later in the spring of 2011, the investigative department of
Voronezh police indicted Mr. Poymanov on these charges. These criminal cases against Mr.
Poymanov have been closed. Further on, Defendant Sberbank Capital filed a bankruptcy petition
against P-Invest.

92. In 2014, the receiver of P-lnvest, Defendant Nogotkov ?led another criminal
complaint claiming that Mr. Poymanov, as a shareholder of one of his smaller companies, P-
Beton, attempted to cause damage to the company. The complaint was prepared by employees
of NAC. P-?Beton was 50% owned by P-Invest, and 50% by Mr. Poymanov.

93. The bankruptcy of P-Beton was initiated by another company of Mr. Poymanov?s
group, P-Zhilstroy. Its bankruptcy was initiated by P~Ncrud, the company which acquired assets
of P~Granit. The charges are baseless since Mr. Poymanov was not an of?cer or a director of the

company, a threshold requirement necessary for the crime. The used the

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bankruptcy procedures to destroy Mr. Poymanov?s businesses, undercutting his ability to fight
the Reiderstvo.

94. The supervisor in Moscow for the criminal investigation against Mr. Poymanov
was reporting to Mr. Glukhov, who is well known for his involvement in corrupt schemes and
Reiderstvo. He is included on various international sanctions lists and has dif?culty traveling
outside of Russia.

95. While Mr. Poymanov initially was defending the fabricated criminal charges
against him and litigated in local and regional courts, the Defendants were transferring money
from one offshore account to another in order to acquire-Granit?s shares and assets while hiding
Defendant Zhukov?s role in the scheme. For example, on September 25, 2010, Defendant
Nisoram, whose end beneficial owners are unknown received $30 million US dollars from
Marbello Holdings limited, which is owned by Defendant Zhukov. Nisorarn made payments to
Sberbank Capital for the shares in P-Granit. Similarly, on December 24, 2011 Urasay, which is
believed to be owned by Defendant Zhukov, received in its US Dollars account with the
Promsvyazbank Cyprus branch, a loan of US 18 million from Monbee Trading Ltd. the same
company which provided loans to Atlantic and which is mentioned in the Atlantic/Sberbank loan
agreement as a member company of the NAC group.

96. At the same time, in November 2010, co-conspirator Galeeva communicated via
co?conspirator Kuznetsov with other co?conspirators and sent P-Granit?s con?dential ?nancial
information received from public officials and other P?Granit proprietary information to other
co-conspirators. By email, she instructed them to construct a harassment and intimidation
campaign against Mr. Poymanov. In particular, Galeeva in the email instructions to the

infamous Defendant Kubiitskiy demanded that he coordinate the involvement of law

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enforcement agencies to put pressure on Mr. Poymanov. She speci?cally stated that order
to reach the objective, namely to gain control over the authorized capital and the operating
activities of P?Granit in addition to the list of corporate measures following need to
be arranged: wiretapping of SP. Poymanov; freld surveillance of the opponent with a view of
revealing the persons, assisting SP. Poymanov in terms of the con?ict; search of premises; preu
trial restrictions (arrest, custody, overseas travel ban).? Defendant Kublitskiy remained in
constant communication with Defendants Shirin, Zhukov and co-conspirator Kuznetsov and his
involvement has been instrumental in the current persecution against Mr. Poymanov. Also,
Defendant Kublitskiy is an associate of, and communicates often with, the infamous raider
Kluyev.

2. False Apnraip?and Auction of P-Granit?s Shares

97. To further implement their fraudulent scheme, and prior to the Court?s decision
issued on July 3, 2011 granting Defendant Sberbank Capital?s claims to enforce the pledge
agreements, Defendant co?conspirators secured arti?cially de?ated valuation reports wherein far
below market or distress values were attributed to P?Granit?s shares and assets. Defendants
relied upon this value in order to justify transfers of the shares at deflated prices to companies
connected to Defendants Zhukov and Oleg Grel?.

98. Although these valuation reports were used as supposed benchmarks for the sale
price of the shares, at the time of the appraisals, none of the appraisers made any requests to 
Granit for information on its activities, including any ?nancial or operational parameters.

99. Thus, on or about April 6, 2011, Defendant cowconspirators Sberbank Capital,
Khachyatureants, German Gref and Zhukov co?ordinated with Defendants Nee Centre and Oleg
Gref to obtain an arti?cially de?ated appraisal report for P~Granit?s shares and assets. Defendant

Oleg Gref, the son of Defendant German Gref, and a close associate with Defendant Zhukov,

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quickly performed his role, and, only two weeks later, issued the appraisal report of P-Granit
valuing its shares at a fraction of the real market value.
a. The Vitera Shares

100. On 8 April 2011, for the purpose of enforcing the Sberbank Russia debt,
Defendant Neo Center issued its appraisal for the P-Granit shares. It valued the shares at RUB
3,035,319,747. Defendant NEO Center estimated P-Granit at a value ?ve times lower compared
to the value determined for the purpose of the original CBERB loan. Between June 3 and June
14, 2011 Defendants Sberbank Capital, through co~conspirators Lelukh and Kuznetsov
communicated with notary Kharnaukhova causing the latter to purposefully and knowingly send
Vitera LLC a notice of the enforcement of the pledge against 'Vitera shares in P?Granit to an
incorrect address. The co?conspirators were well-aware of that Vitera LLC was not located at
the address 12 Ostapovskiy projezd, b. 3, Moscow, because on the enforcement application by
Defendant Sberhank Capital dated 31 May 2011 it states that ?Vitera LLC office is not located at
the legal address 12 Ostapovskiy projezd, b. 3, Moscow, there are no Vitera LLC representatives
at the stated address?. This was done despite the fact that Sberbank Capital was noti?ed in
writing about the actual correct address for Vitera. Khnaraukova?s sister, Lobakh also a notary,
later issued the ?nal enforcement notice of the pledge against Vitera shares after the lyear statute
of limitation for challenging the enforcement order had passed.

101. Having issued its final enforcement notice against Vitera ?shares, Defendants
Sberbank Capital, P1 and Zhukov contacted bailiff Burmistrov to initiate enforcement proceeding
against Vitera.

102. On June 22, 2011, Burmistrov, having avoided a challenge to the order, arranged

the withdrawal of Vitera shares of P?Granit, and their transfer to Defendant Sberbank

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Capital. Thus, on June 22, 2011 the Vitera shares at the de?ated value set forth in the Defendant
Neo Centre?s Report passed under the control of Defendant Sberbank Capital.

103-. On the same day, on June 22, 2011, Defendant Aletarro received in its account at
Defendant branch in Cyprus 3. $10 million US dollars loan from Zasteni Investment Ltd,
a BVI company owned by Defendant Zhukov. On the same day, Defendant Aletarro transferred
the $10 million US dollars in two payments of $3 million and $7 million to its bank account with
Bordier C113, Geneva Switzerland, a correspondent (intermediary bank) of UB S.

104. On 23 June 2011, Defendant Sberbank Capital transferred the Vitera shares
[36.37%. of P-Granit] to Defendants Nisoram 25%, and Aletarro 11.37%. Aletarro paid
Sberbank Capital $10 million US dollars from its account with Bordier CIE bank in
Switzerland. Because the transfer was in US dollars the Swiss banks had to use a US,
correspondent bank.

105. Defendants Sberbank Capital and Zhukov intentionally split the Vitera shares in
order to circumvent general anti-monopoly restrictions and. the restrictions imposed under
Russian law on the acquisition of shares in strategically important companies by foreign subjects.
P~Granit is a strategically important company and acquisition by a foreign entity of more than
51% shares would require the permission of a special committee under the Federal Government 
of the Russian Federation. One of these proceedings would have exposed Defendant Co-
conspirators Zhukov?s, Gref?s, Khachaturyants?s and the other couconspirators? roles in the
scheme.

106. Vitera challenged the administrative act/transfer of its shares to Defendants
Nisoram and Aletarro directly in the Arbitrazh courts in Russia. Predictably, the court rejected

their claims.

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.107. While the case was still pending, on 19 April 2012, and before Court issued its
appeal decision on the validity of the transfer of Vitera shares, a bankruptcy manager was
appointed over Vitera. Defendant Atlantic LLC was the only Vitera creditor at that stage and the
bankruptcy manager that was appointed was nominated by? Defendant Atlantic LLC. Thus, the
sole creditor controlled the entire process. The bankruptcy manager did not support the claim on
appeal and left it to the court to decide as it saw The 19th Arbitrazh Appellate Court
predictably allowed the appeal against Vitera, without objection by its receiver, in relation to
Defendant Nisoram on May 15, 2012 and in relation to Defendant Aletarro on July 20, 2012.
Contrary to the professional rules, the receiver acted in the interests of the co-conSpirators, rather
than defending the interest of Vitera.

108. Once the Vitera Bankruptcy Trustee withdrew support for Vitera?s claim for
recovery of the Vitera shares from Nisorarn and Aletarro, PNH issued petitions with the Central
District Federal Arbitrazh court and Supreme Arbitrazh court for their supervisory review of the
decisions of the 19th Arbitrazh Appellate court. However, it was held that PNH, as a third party,
did not have the right to appeal the decisions of the 19th Arbitrazh Appellate court in relation to
Vitera?s claim, despite the obvious fact that the judgments, effectively refusing to return the
shares to Vitera and keeping the enforcement of the pledge over 'V'itera shares at the de?ated
value determined by NEO Centre, affected PNH as the provider of pledge of its shares in P-
Granit. Effectively the Trustee and the Court insulated the distribution of Vitera shares from
independent review.

b. Mr. Povmaaov?s Shares

109. After the Vitera shares, Defendant Sberbank Capital moved to enforce the pledges
against Mr. Poyrnanov?s 24.67% shares in P-Granit. Thus, on July 8, 2011, for the purpose of

obtaining a bailiff order in the enforcement proceedings, the bailiffs in co?ordination with P1 co?

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conspirators retained Sokolov of appraiser Primula LLC to issue an arti?cially de?ated valuation
report for Mr. Poymanov?s shares. Sokolov is an acquaintance of Ms. Galeeva, and his wife is an
employee of Promsvyazbank.

110. The Primula LLC Report valued Mr. Poyrnanov?s shares at approximately RUB
496,174,826. This value was lower than that attributed to comparable shares appraised by
Defendant Neo Centre, which was RUB 733 million.

111. On December 30, 2011, the Task Quadro Securities LLC organized an auction of
Mr. Poymanov?s shares. The auction of Mr. Poymanov?s shares was designed and conducted in
a manner that minimized participation by potential bidders. A temporary decision of the
Supreme Court of Russia suspended the auction date. When the temporary decision was ?tted,
the auction was held on only one day?s notice. There were only two participants at the auction:
LLC Trade and Defendant Sberbank Capital. The winner of the action was declared LLC Trade
that paid RUB 516,174,826 for the share.

112. Later, believed to be in or around February 2012, LLC Trade transferred Mr.
Poymanov?s P-Granit shares to Defendant Urasay. On December 24, 2011 Urasay received in its
US Dollar account with the Promsvyazbank Cyprus branch a loan of US 18 million from
Monbee Trading Ltd. the same company which provided loans to Atlantic and which is
mentioned in the Atlantic Sberbank loan agreement as a company of the NAC group. On
January 25 and 31, 2012 Urasay transferred 12,953,367.87 US Dollars and 4,281,949.93 US
Dollars under the Contract of Purchase and Sale of Securities dated 23.01.2012. The amount
corresponds to the price of the shares purchased by 000 Trade at the auction. 000 Trade is
mentioned in the Sberbank credit committee decision approving the loan to Atlantic as the

winner?to?be of the auction. These movements clearly establish the additional ?nancial ?ows in

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US dollars by the NAC. Upon information and belief, Defendant Zhukov owns Defendant
Urasay.
c. The PNH/Zinika Shares

113. Disposing of PNH/Zinika shares took place after Defendant Sberbank of Russia
assigned its debt to Defendant Atlantic. Before that assignment, Sberbank Capital worked on the
enforcement of pledges on the shares in P-Granit in the interests of Zhukov and other co?
conspirators.

114. On November 9, 2011, co-conspirator Nataliya Maiorova, the Chief Accountant
(as co-defendant Shirin informed the criminal investigator in the course of interrogation) of
Defendant Klever Asset Management and acting under Defendant Zhukov?s control,
incorporated Defendant Atlantic LLC.

115. On 20 December 2011, Defendant Sberbank Capital entered into an assignment
agreement with Defendant Atlantic LLC transferring all of its rights under the Loan Agreement
and the various security pledges to Defendant Atlantic LLC for a consideration of 4,l40,550,564
(the ?Assignment Agreement?). Department of the Economy and Finance of the GoVernrnent of
the Russian Federation, in a letter dated 30 December 2011, described the party receiving
assignment from Defendant Sberbank Capital in its report to then Prime Minister, new President
of Russia Mr. Putin, signed by Mr. Belousov as c?structures owned by? Zhukov.?

116. The Assignment Agreement listed a series of pledge agreements also assigned by
Sberbank Capital to Atlantic LLC. Further, it provided that Defendant Atlantic LLC had to pay
within 20 business days of the date of the Assignment Agreement. The Assignment Agreement
links the failure to perform to the termination of the option agreement between Defendants

Sberbank Capital, Atlantic LLC, Aletarro and Nisorarn (the ?Option Agreement?).

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117. On December 21, 2011, one day after the Assignment and the Option Agreements
were signed, the Defendant Sberbank Russia?s Credit Committee (?Credit Committee?), chaired
by Defendant German Gref, approved the issuance of a loan to Defendant Atlantic LLC. The
amount of the loan was, surely not by coincidence, equivalent to the amount payable by Atlantic
to Sberbank Capital for the assignment of the debt less the amount which was subsequently paid
by the winner-to-be of the auction LLC Trade for the 24.67% block of shares owned by Mr.
Poymanoyr in P-Granit.

118. As a loan condition, the Credit Committee listed multiple events that had not
taken place yet, but happened within several weeks after the date of the Credit Committee
decision and the date when the loan agreement was signed. In particular, the agreement listed
Trade LLC as the winner of the auction for P~Granit shares organized by the State Agency for
Russian Property before the auction was conducted and approved the sale of the yet to be
acquired shares to Defendant Urasay.

119. Furthermore, the Credit Committee minutes of the meeting on the loan to
Defendant Atlantic described how the founder of Atlantic, co?eonspirator Mayorova would be
allowed to sell P?Granit debt to Defendant Mostra Consulting which is allegedly owned by
Defendant Zhukov. The minutes omitted that the Credit Committee was retroactively
authorizing the transaction and made no reference to failure to secure proper authorization in the
future.

120. On 27 January 2012, Defendant Atlantic entered into a loan agreement with
Defendant Sberbank of Russia to ?nance its obligations to Defendant Sberbank Capital under the

Assignment Agreement. (?Sberbank?s Loan Agreement to Atlantic?).

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121. Defendant Sberbank?s Loan Agreement to Defendant. Atlantic identi?es that
Defendant Sberbank of Russia would provide a credit line to Atlantic with a limit of RU
3,624,400,000 to ?nance the transaction to buy the debt under the various agreements including
the Loan Agreement. The credit line balance had to be completely repaid by 25 December 2018.

122. Further, the agreement provided that the credit would be issued on execution of
certain guarantees, including a guarantee by Defendant Atlantic in favor of Defendant NAC.

123. As security, Defendant Atlantic guaranteed to provide to Defendant Sberbank the
following pledges: a pledge of the ordinary shares in Defendant Aletarro; a pledge of the
ordinary shares in Defendant Urasay; a pledge of the ordinary shares in Defendant Nisoram; a
pledge of an 11.37% shares in P~Granit; a pledge of a 25% shares in P~Granit; a pledge of a 24%
shares in PwGranit; and a pledge of a 38.63% shares in P-Granit.

124. These pledges had to be signed within 30 days of the transfer of the shares in 
Granit to Defendant Atlantic or af?liates of the Defendant NAC controlled by Defendant
Zhukov.

125. Defendant Sberbank of Russia also required Defendant Atlantic to ensure that the
Defendant NAC maintained a particular ratio as speci?ed in the agreement and.
that the debts owed by three companies associated with Defendant Zhukov are not to be taken
into account when assessing the overall exposure of his companies to Defendant Sherbank of
Russia. The companies noted in the agreement are: ?Tankard Trading Investments Limited;
MOnbee Trading Limited; and IBG Development Group Inc.? The exemption amounts to a total
not exceeding $80,000,000 (eighty million US dollars).

126. Under Defendant Sberbank Russia?s Loan Agreement to Defendant Atlantic,

Defendant Sberbank Russia can demand an early repayment of the credit funds given to Atlantic

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and provides Defendant Sberbank of Russia?s irrevocable and unconditional consent to the sale
of shares in Atlantic to Mostra by the founder and General Director of Atlantic, Natalia
Mayorova by 1 March 2012.
127. The agreement also contemplates and records the eventual transfer of shares in 
'Granit to Defendant Atlantic and or af?liates of the Defendant NAC controlled by Defendant
Zhukov.

128. Thus, Defendant Sberbank Russia ?nanced Defendant Atlantic acquisition
of the shares and took pledges for the shares of Defendant Nisoram, ?Aletarro and
Urasay in P-Granit, at more favourable terms than it was willing to give PuGranit/Poymanov to
re-?nance the original debt. If the P?Granit restructuring negotiated by Mr. Poymanov had been
accepted, Sberbank Russia would have recovered, before July 31, 2017, the entire loan amount
plus 3.635 billion rubles interest just on the main loan, not counting interest on other smaller
loans. Under the Atlantic loan agreement, Sberbank Russia would recover the loan amount, but
only 2.047 billion rubles interest, 1.588 billion rubles less. On the date Sberbank Russia
signed the loan agreement with Atlantic, the ruble rate was 30.3600 rubles for 1 US dollar, 
the difference amounted to a lesser interest return of US 52.3 million.

129. On February 17, 2012, Mayorova entered into a sale agreement with Defendant
Mostra Consulting, under direct control of Defendant Zhukov, for the purchase of 100% of
participatory interest in the authorized capital of Defendant Atlantic.

130. On March 28, 2012, Defendant Aletarro and Sberbank Russia entered into a Share
pledge agreement for the pledge of shares owned by Aletarro in P-Granit to Sherbank, whereby
Defendant Zhukov is the direct beneficiary of Defendant Aletarro for the purpose of Defendant

Atlantic enforcement proceedings under the Sberbank Loan Agreement to Atlantic.

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131. On September 6, 2012, by resolution of the sole member of Defendant Atlantic -
Mostra Consulting - drafted by attorney Kozyr, under the direct control of Defendant Pl.
Defendant Atlantic changed its address to 21 Bolshoy Sukharevskiy pereulok, b. 2, Moscow,
127051. This is the same address as VEB Upravlenie Projektami, another of Defendant
Zhukov?s registered companies.

132. During this entire process, as mentioned above, the Majority Shareholders used
all available legal means to protect their interest, including ?ling criminal complaints for the
theft of the company. it is no surprise that the Russian authorities only pretended to investigate
the facts. Moreover, the investigation was delayed and ultimately thwarted when Russian law
enforcement attempted to secure a response to a Mutual Legal Assistance Request seeking the
identity of the bene?cial owners of the offshore Defendant companies named herein. Despite the
fact that the Russian court in due order authorized such request for legal assistance, the request
of the court was never even sent to the Of?ce of Attorney General of Russia, whose Department
of International Co-Operation is sending such requests to foreign authorities in the normal
procedure of international assistance on legal and judicial matters.

133. Nonetheless, as part of its investigation on the theft of Vitera shares, the Moscow
Tver Interdistrict Prosecutor sent of?cial letters to Defendant Nee Center regarding its appraisal
of Vitera shares.

134. On September 25, 2012, receiving this letter, Defendant Oleg Gref emailed
Defendant Zhukov (from email o.gref@neoconsult.ru) forwarding the aforementioned letters to
Yuri Zhukov (e?mail with the following accompanying letter: ?Hello Yura.
For your information: the Show goes on?. On 25 September 2012 at 12:40 Yuri Zhukov (from e?

mail yz@klever.com) responded to Gref Oleg (to e-rnail think the

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show will not be long, neither will it be interesting, but it?s worth being attended. Need a contact
person for my legal advisors to arrive at a certain decision?.

135. On 28 September 2012, Defendant Atlantic ordered a valuation report from
Financial Appraisal Consulting LLC for the purpose of enforcement proceedings
against PNH/Zinica shares (the Report?). According to the agreement Defendant Atlantic
had to fulfil the requirement of obtaining a supposed independent valuation under the assignment
and loan agreements on extrajudicial foreclosure of the pledged shares. The FAC Report valued
the PN'H/Zinica shares at RUB 760 million a value even lower than the value for the PNH/Zinica
shares given by Neo Centre, which was RUB 926 million. The appraisal specialist doing that
report was member of SMAO the same guild of appraisers to which the NEO Centre appraiser
was a member.

136. On 2 October 2012, Defendant Atlantic served notice on under the
agreement on extrajudicial foreclosure of the PNH/Zinica shares, which was assigned to it
pursuant to the Assignment Agreement. Defendant Atlantic notified PNH of its intention to take
over the PNH/Zinica shares at the value assigned to it by the PAC Report, i.e. RUB 760,000,000.

137. On October 26, 2012, Defendant Atlantic LLC acquired the PNH/Zinica shares
through an out-of-court foreclosure of these shares.

E. LEGALIZATION
Illegal bankruptcies

138. In April 2012, Defendants started implementing their plan to bankrupt P?Granit

and funnelling its assets to Defendant NAC.
139. Thus, in December 2012, Defendants Atlantic, NAC, Zhukov, Shirin, and PI

conspired to initiate the extrajudicial bankruptcy proceedings against P?Granit.

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140. Contrary to the receiver?s obligation to act independently and his ?duciary duty to
the company?s creditors, correspondence of December 2012 between Defendants Sberbank of
Russia, NAC, Zhukov, and Galeeva and co?conspirators PI, Kuznetsov, and Potolitsyn
demonstrates that they controlled the bankruptcy receivers, including Defendants Nogotkov and
Bazarnov. They were instructing Defendant Nogotkov, who were in turn was reporting back on
all actions taken during the proceedings. For example, in December 2012 
Kuznetsov and the receiver Zaytsev and receiver Defendant Nogotkov exchanged emails
sharing: 1) reconciliation statement between Vitera LLC, LLC and
2) Evrogranitinvest LLC progress report for November 2012;
3) Vitera LLC progress report for November 2012. Defendant Nogotkov sent to eo-conspirator
Kuznetsov (from his e-mail knogotkov@gmail.com to the e?rnail K.andrey@bk.ru) the
aforementioned reconciliation statements and progress reports with the following comments:
?Hello! Please ?nd attached the reports on two bankruptcies (same like we do it for Slava in
Samara) and ?nancial expenses report. Is it ok for you? If yes, will discuss everything in detail
on Friday. Kirill.? {The same receiver, Zaytsev, although appointed receiver to protect its
interests, did not oppose Aletarro and Nisorarn?s appeal of the initial court judgment ordering
them to return P?Granit shares to Vitera.

b. Transfer of P-Granit Assets to Defendants NAC and Zhukov

141. On January 29, 2013, Defendant NAC, emailed Defendant Sberbank Russia, a
comprehensive plan for the future steps to be taken by Defendants to accomplish the takeover of
P-Granit?s assets for the bene?t of Defendants NAC and Zhukov. The plan detailed the
following actions that ultimately were implemented by Defendants: (1) Defendant Atlantic
assigned the debt of Defendant Sberbank Russia to Defendant NAC as a payment for obligation

assumed and Defendant NAC acquired receivables as to P?Granit and 20.86 block of shares;

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(2) P-Granit established an associated company (.1 SC) and funneled almost all the assets into it;
(3) P-Granit and Defendant NAC made an amicable settlement agreement, whereby Defendant
NAC changed receivables as to P-Granit; and (4) Defendant NAC owns a new Defendants
Shirin, Zhukov and Khachyatureants signed off this plan.

142. Thus, on June 27, 2013, Defendant Atlantic applied to the Russian Federal Anti-
Monopoly Service (the for permission to acquire two entities 
(?P-Prom?) and (?P-Nerud?) created by new shareholders of PuGranit, to
which most of the assets of P?Granit were to be moved. On 23 July 2013, Defendant Atlantic
obtained such approval.

143. On July 17, 2013, Defendant Atlantic and P-Granit entered in to a comprehensive
settlement in the process of the P-Granit bankruptcy case in court, whereby the assets of P?Granit
were transferred to P-Prom and P-Nerud. The settlement was also approved by the Russian
Court on the basis that the other creditors of P?Granit (very minor) would be paid in full (?the
Settlement?).

144. On August 15, 2013, subsequent to Defendant Atlantic?s application, Defendant
NAC applied to the FAS for permission to acquire 100% shares in PnProm and P~Nerud and
implement the Settlement. On September 2, 2013, Defendant NAC obtained such approval for
PvPer and on September 5, 2013, it got similar permission for P?Nerud.

145. On September 23, 2013, Defendant Atlantic and couconspirator Vetrolin, a BVI
company, entered into a sale and purchase agreement of P~Nerud 100% shares for the amount of
2 billion rubles. The deposit for the transaction in the amount of almost 1 billion RUB was
transferred from Vetrolin?s bank account in the Defendant Promsvyazbank Cyprus branch in US

dollars.

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146. In accordance with the Settlement, on November 1, 2013 P?Granit paid Defendant
Atlantic two amounts totalling 1,009,665,613 rubles. Subsequently, on November 14, 2013, P-
Granit transferred to Defendant Atlantic its shares in P?Nerud and in P-Prorn, and unilaterally
cancelled the agreement with Vetrolin, allegedly due to a more favourable offer.

147. The agreement between Defendant Atlantic and Vetroiin had an arbitration clause
and the forum was the Arbitration court of non-pro?t organization fund ?Pravo and Ekonomika
Shortly after the alleged breach, co?conspirators Gorbunov and Kuznetsov, pursuant to
Zhukov?s instruction, ?led a claim in the Moscow City Arbitrazh Court to enforce the arbitration
clause and seek compensation from Defendant Atlantic. Right before canceling the agreement,
Defendant Atlantic was renamed into AlfaMarket LLC. This was done to prevent the public,
including the Majority Shareholders, from ?nding the pending case between Atlantic and
Vetrolin on the docket. Under Russian law, if the contract requires an ?earnest payment? by
buyers to secure the transactions, and the seller cancels the deal, then the seller has to return
double the ?earnest payment?. Earnest payments are routinely set between 1% and 5% of the
purchase price. In this case, the ?earnest payment? was 75% of the 2 billion rubles purchase
price. The reasonable explanation for this extraordinary ?earnest paymen is to launder the
funds. By getting a court order for the distribution of the ?earnest payment,? Defendants
legalized that out?ow of funds.

148. As a result of the Settlement between PuGranit and Defendant
Atlantic/AlfaMarket, in exchange for payments in cash and in shares of P-Nerud and P-
described above, PuGranit acquired the rights of Defendant Atlantic/AlfaMarket

under the Loan Agreement, which were valued at 3,326,210,254 RUR. This amount is the

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equivalent of US 92,578,498 at an exchange rate of 1 RUR 0.278 USD (as of March 19,
2014).

149. On November 29, 2013 P?Granit entered into an agreement with Suintex Ltd, a
company, Whereby P?Granit (the Assignor) assigned to Suintex Ltd. (the Assignee) the
creditor?s rights under the Loan Agreement for only 137,000,000 RUR, which is the equivalent
of US 4,301,953, as per the exchange rate on October 29, 2014, and today of US $2,194,830.
The agreement to sell the rights to bring the claim to Suintex was a transaction which
required approval by the P-Granit shareholders. Defendant Atlantic put forward the proposal to
sell the claim to Suintex for 137 million rubles at the shareholders? meeting.

150. On December 3, 2013, the new General Director of Defendant
Atlantic/AlfaMarket, co-conspirator Potolitsyn distributed to P?Granit?s new shareholders a draft
?Resolution of P-Granit General meeting of shareholders, to be held on 27 December 2013?.
The ?rst item on the agenda was approval of the major transaction, formulated as follows: ?To
approve the Company?s major transaction, namely Receivables assignment contract (cession)
between P-Granit and the company Suintex Ltd.?

151. On December 23, 2013, Defendant Atlantic/AlfaMarket, acting as the borrower
under the non?revolving loan facility agreement dated January 27, 2012 with Defendant
Sberbank of Russia and concluding a tri?party agreement between Atlantic, Sberbank and NAC,
assigned the 3 billion 636 million 257 thousand 963 rubbles debt to the new debtor Defendant
NAC. The consideration was the transfer to NAC of 100% of shares in P-Prom and P-Nerud, the
latter holding most of the assets of the former P-Granit. As a result, NAC formally held the

assets and the business of P~Granit, which was at the ?nal stage of being raided.

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152. At the shareholders meeting on December 27, 2013 shareholders Defendants
Aletarro, Nisorarn, Urasay and Atlantic/AlfaMarket voted in favor of the Suitnex proposal.
Thus, Suintex, together with the right to the debts, accepted the corresponding receivables on the
guarantees for the debt as to:

a. primary debtor and
b. guarantors and pledgers: LY. Podgornaya, O.P. Poymanov, RA.
Poymanov, S.P. Poyntancv, VISKOM LLC, Evrogranit LLC, Evrogranit?
Invest LLC, Vitera LLC, and LLC.
The latter arose from the agreement on the non?revolving loan facility dated August 4, 2008,
with supplementary agreements between Defendant Sberbank of Russia and 
and the security interest agreements. The decisions adopted at this shareholders meeting violated
the law as related parties voted on matters in which they had a seifdnterest.

153. Also during the December 27, 2013 shareholders meeting, Defendants Aletarro,
Nisoram, Urasay and Atlantic/AlfaMarket voted to liquidate P?Granit. Subsequently, in
furtherance of the conspiracy and to cover it up, on June 17, 2014, Defendant
Atlantic/AlfaMarket was dissolved. Thus, Defendants liquidated the corporate entities which
could be parties to court proceedings challenging the validity of the performed transactions and
restitution of assets.

154. Mr. Poyrnanov continued to ?ght for his company in actions pending in Russian
court. During this period, he was. threatened multiple times with physical violence by an
unknown person who demanded that he drop his claims. Although Mr. Poymanov ?led a
complaint with the local police, the criminal case was closed due to a supposed deaduend in the

investigation.

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155. In a further attempt to intimidate Mr. Poymanov, on July 15, 2014, the
Investigative Committee for 'Voronezhkaya Oblast initiated a new criminal case against him
based on the complaint of the P-Invest receiver. The receiver Defendant Nogotkov alleged that
Mr. Poymanov, as the shareholder of a 000 through P-Granit Invest
abused his authority and sold certain assets to a third party, avoiding payment to the existing
creditors and the tax authority. The case against Mr. Poymanov was baseless as a matter of
Russian law, because a derivative action only can be brought against an of?cer of the company,
while Mr. Poymanov was a shareholder. Contrary to the allegation, on December 14, 2008, Mr.
Poymanov personally loaned 3.4 million rubles to the company, the balance of which is
outstanding. He never took measures to recover this debt.

156. On August 13, 2015, the Defendants? accomplished the next step in the
conspiracy the takeover of P-Granit when the Voronezh Regional Arbitrazh Court
recognized the liquidation of P?Granit. P~Granit ceased to exist and was erased from the
National Registry of companies.

157. Thus, Defendants successfully transferred the assets of PuGranit from the
Majority Shareholders to the Defendants NAC Group and Zhukov. Defendant Atlantic LLC was
re?named and ultimately liquidated. P?Granit also has been liquidated.

158. The persona} bankruptcy of Mr. Poymanov that followed the bankruptcy and
liquidation of P?Granit is part of the conspiracy to raid his company and eliminate his ability to
enforce his rights. In furtherance of this segment of the conspiracy, Defendant Suintex acquired
P-Granit?s alleged claims for a nominal value and then initiated the bankruptcy proceedings

purportedly to enforce those claims.

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159. On October 2, 2015, Defendant Suintex ?led for Mr. Poymanov to be put into
personal bankruptcy. On February 8, 2016, the Moscow Oblast Arbitrazh Court approved the
restructuring of the debt and, at the request of Defendant Suintex, approved Defendant Bazarnov
as the receiver. Shortly after his appointment, Defendant Bazarnov requested the Court freeze
Mr. Poyrnanov?s bank accounts and real estate. Although acting as the receiver for Mr.
Poymanov?s bankruptcy estate, Defendant Bazarnov refused to seek the re?evaluation of the 
Granit shares and to contest the previous arti?cially de?ated transactions which led to Mr.
Poymanov?s bankruptcy.

160. On July 21, 2016 the Moscow Oblast Arbitrazh Court declared Mr. Poyrnanov
bankrupt and initiated the sale of his assets. On July 29, 2016, co?conspira?tor Arismet, an entity
controlled by Defendant Zhukov, joined Suintex as one Mr. Poymanov?s creditors. The personal
bankruptcy of Mr. Poymanov is part of the conspiracy to raid his company and eliminate his
ability to enforce his rights. In furtherance of this segment of the conspiracy, Defendant Suintex
acquired P~Granit?s alleged claims for a nominal value and then initiated the bankruptcy
proceedings purportedly to enforce those claims. Although the alleged claims against Mr.
Poymanov were valued at the de?ated price by Defendant Neo Centre at 
rubles, Arismet purchased them for 2.656.800,00 rubles. On November 11 2016, P-Nerud,
controlled by Defendants NAC and Zhukov joined Suintex and Arismet as creditors in Mr.
Poyrnanov?s personal bankruptcy.

161. Although the original debt of P?Granit to Defendant Sberbank Russia was 4.5
billion rubles, Defendants became owners of shares and/or received cash in excess of 7 billion
rubles despite the intentional low-ball appraisal of the shares and assets. Yet, in Mr. Poymanov?s

personal bankruptcy, Defendants are claiming an additional 4 billion rubles.

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4. LITIGATIONS IN CYPRUS

162. Right after Defendant Atlantic executed the Settlement agreement with PuGranit?s
new shareholders, on August 7, 2013, Mr. Poymanov ?led a request for preliminary injunction in
the Limassol District Court in Cyprus, requesting the Court enjoin them from disposing of P-
Granit shares and an order for the return of the shares to Mr. Poyrnanov or monetary
compensation and the disclosure of the bene?cial owners of the offshore companies (?Limassol
Litigation?).

163. Although the Court originally granted the preliminary injunction, the decision was
reversed on the appeal. The matter of the preliminary injunction is currently pending at the
Supreme Court. The District Court postponed the disclosure of the bene?cial owners until the
case is adjudicated on the merits, it is being further heard. The claims alleged in the Limassol
Litigation are conspiracy to defraud Mr. Poymanov and other shareholders of their shares in P-
Granit.

164. On September 12, 2016, the court appointed receiver in Mr. Poymanov?s personal
bankruptcy case, defendant Bazarnov, submitted a letter to Mr. Poyrnanov?s Cyprus counsel
revoking any power of attorney (including retainers) issued by Mr. Poymanov for the Limassol
Litigation and demanded that counsel ?stop with immediate effect any legal work and/or
proceedings and/or services rendered, as regards any property movable or immovable, in which
Mr. Poymanov is directly or indirectly involved or interested in and/or any representation on
behalf of Mr. Poymanov in court or elsewhere.? Mr. Poymanov challenged the authority of the
receiver in Russian Court and the hearing has been scheduled for late November. Obviously,
this latest move by the co?conspirators demonstrates that there is no available forum for the

Majority Shareholders to seek redress for the expropriation of their assets in P?Granit.

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165. Mr. Poymanov ?led a complaint against Defendant Bazarnov?s actions canceling
the powers of attorney, but the Court, again, denied Mr. Poyamnov?s request. On November 7,
.2016, alleged creditors Suintex and Arismet approved the hiring of the law ?rm, Panagos and
Panagos, to purportedly represent Mr. Poyrnanov in the court cases in Cyprus. The same alleged
creditors also decided that Icouconspirator Arismet would ?nance Panagos and Panagos. Thus,
the receiver is represented in court by counsel that is paid by Defendant Zhukov.

1.66. To exert additional pressure on Mr. Poyrnanov, Defendant
Nogotkov, brought additional proceedings in Cyprus in March 2013 against PNH, Mr
Poymanov, Belirn Enterprises Limited and Abacus (Cyprus) Limited. The case is currently
pending in the District Court of Nicosia, with action number 1901/2013 (the ?Nicosia
Proceedings?).

167. In the Nicosia Proceedings Defendant Nogotkov claims that Mr. Poymanov and
others conspired to cause damage to P?Invest by unlawfully diluting P-lnvest?s interest in 
In particular, Defendant Nogotkov alleges that because the shares in P-G-ranit owned by PNH
were pledged as security for the Loan Agreement, Mr. Poymanov and others fraudulently took
steps to dilute the interest ofP?Invest in PNH to protect themselves from the consequences of the
breach of the Loan Agreement. This is a completely unsound allegation, as this has not affected
the pledge of shares owned in P-Granit by PNH in favor of Sberbank, taken over by Atlantic.
The Nicosia District Court granted Defendant Nogotkov freezing orders ex park. For now the
case is pending and a hearing date has not been scheduled.

168. While the Nicosia Proceedings arise from the same story as the Limassol claim,

they relate to only part of it, in particular P-lnvest?s shares in PNH and the related pledge

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agreement. By contrast, the Limassol Litigation relates to the shares in one level

up from PNH.

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COUNT 1

Fraud
(Against Defendants Sberbank Russia and Sberbank Capital)

169. Paragraphs 1 through 168 are incorporated by referenced as if fully set forth
herein.

170. Defendants Sberbank Russia and Sberbank Capital intentionally and knowingly
failed to disclose to Majority Shareholders that their purported negotiation over restructuring of
the debt was for the bene?t of Defendant Zhukov. Defendants kept Zhukov as the ultimate
bene?ciary of the scheme a secret until the end and circulated and disclosed proprietary and
con?dential information of P-Granit.

171. Defendants made proposals to the Majority Shareholders regarding the
restructuring, told the Majority Shareholders that the negotiated terms would result in a plan
that would allow Majority Shareholders to keep P-Granit, while in fact Defendants intended
only to make an offer in terms that could not work and would allow for the seizure of shares and
non-judicial sale of assets, caused issuance of de?ated appraisals what justi?ed throwing P-
Granit into control by them, foreclosure and ultimately dissolution. Defendants intended for both
the Majority Shareholders and P-Granit to rely on the misrepresentations.

172. Majority Shareholders reasonably relied on Defendants? misrepresentations by
commission and omission. in detrimental reliance on Defendants? malicious, intentional and
willful misrepresentations of material facts and malicious, intentional and willful failure to
disclose material facts, Majority Shareholders did not seek alternative ?nancing to restructure

Sberbank debts.

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173. Moreover, Defendants? fraudulent interference with the appraisal process, the
bankruptcy proceedings, the auctioning of P-Granit assets and the judicial process made it
impossible for Majority Shareholders to stop the destructive actions Defendant undertook against
their shares in P~Granit.

174. As a direct and proximate result of Defendants? fraud, Majority Shareholders
were stripped of their assets and are entitled to an award of damages, including compensatory
and punitive damages, as well as other legal and equitable relief.

WHEREFORE, Plaintiff seeks judgment against Defendants, under Count 1 for the

following relief:

A. Compensatory damages of no less than $500,000,000.00;

Punitive damages of no less than $250,000,000.00;

C. Costs, attorney?s fees, and post?judgment interest; and



Such other and further relief as the Court deems proper.

COUNT [1
Conspiracy to Commit Fraud

(Against all Defendants)
175. Paragraphs 1 through 174 are incorporated by referenced as if fully set forth

herein.

176. Pursuant to an agreement and understanding, Defendants conspired to commit and
did commit the unlawful acts of illegal takeover campaign against the Majority Shareholders?
assets in P?Granit.

177. Defendants maliciously, intentionally and willfully misrepresented to the Majority

Shareholders that they intend to negotiate the restructuring of the original Sberbank debt when in

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Case Document 9 Filed 01/06/17 Page 54 of 62

facts they never intended to restructure the debt but intended to steal Majority Shareholders? 
Granit shares and P?Granit?s assets and transfer them to companies owned or controlled by
Defendant Zhukov. The purposes of this conspiracy and common schemes were to steal P-
Granit from the Majority Shareholders for the bene?t of Defendants.

178. In furtherance of the conspiracy Defendant German Gref directed Defendant
Sberbank Russia to interfere with any attempts by Majority Shareholders to restructure their debt
or to secure alternative financing to repay the loan and to ?le a criminal complaint against Mr.
Poymanov to entangle him in criminal proceedings while his company was being stolen.
Defendant German Gref retained his son Defendant Oleg Gref and his company Defendant 
Centre, to appraise P?Granit group?s shares. Defendant Oleg Gref and NBC Center appraised 
Granit without visiting the P?Granit. Defendant Oleg Gref regularly communicated with
Defendant Zhukov as to the action plan. The appraisal of P?Granit shares was low.

179. Thereafter, Defendants involved co-conspirators unnamed defendants such as

notaries and bailiffs who sold P?Granit shares to Defendants through the following layering:

a. the 36.37% of Vitera shares in P-Granit to two offshore companies
Defendants Nisoram and Aletarro whose end-beneficiary is allegedly
Defendant Zhukov;

b. 24.67% of Mr. Poyrnanov?s shares to Defendants Urasay and Trade LLC,
whose end?bene?ciary is allegedly Defendant Zhukov.

c. 29.64% of PNH/Zinica shares to Defendant Atlantic LLC whose end-
bene?ciary is allegedly Defendant Zhukov. Just a month prior Defendant
Atlantic acquisition of the shares and for this purpose, Defendant
Sberbank Capital provided a loan, while still negotiating potential
restructuring with P-Granit.

d. 1,85% and 8% shares of the people affiliated with Mr. Poymanov were
diluted during the manufactured bankruptcy.

180. On December, 20, 2011, Defendants Sberbank Russia and German Gref were so
prescient that they included Trade LLC as the winner of an auction in one of the assignment

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Case Document 9 Filed 01/06/17 Page 55 of 62

agreements before conducting the actual auction. In September 2012, Defendant Zhukov assured
Defendant Oleg Gref that the scheme would not take long and it would be worth the effort.

181. Defendants kept Defendant Zhukov as the ultimate bene?ciary of the scheme a
secret until the end and circulated and disclosed proprietary and con?dential information of 
Granit. 'l?he offshore companies that acquired the undervalued shares ultimately sold them back
to Defendant Zhukov and Defendant NAC. This way, Defendant Zhukov?s original plan of
taking over control over P-Granit had been accomplished.

182. Defendants Sberbank Russia and Sberbank Capital intentionally and knowingly
failed to disclose to Majority Shareholders that their purported negotiation over restructuring of
the debt was for the bene?t of Defendant Zhukov.

183. In furtherance of the conspiracy, Defendants, as described in paragraph 95:

l?d

Manipulated the filing of fabricated criminal charges against Mr.
Poymanov. Defendant Galeeva instructed Defendant Kublitsky regarding
the objective of the conspiracy . .to gain control over the authorized capital
and the operating activities of P-Granit? and the law enforcement actions
necessary to implement the plan, including wiretapping, ?eld surveillance,
searches, and pro?trial restrictions all applicable to Mr. Poymanov;

2. Communicated during conspiracy in order to developed tactics and share
details on the progress of the conspiracy among themselves;

3. Incorporated offshore companies for sole purpose of the conspiracy and used
off-the-shelf company;

4. Collaborated with criminal investigators including those known to work
with infamous raider Kluyev; 

5. Took advantage of captured courts and bankruptcy court procedures and
personnel;

6. Used US intermediary banks to make payments during the implementation
of the conspiracy; and

7. Invested alleged proceeds of the conspiracy in the US.

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184. The Majority Shareholders reasonably relied on Defendants? misrepresentations
by commission and omission. in detrimental reliance on Defendants? malicious, intentional and
willful misrepresentations of material facts and malicious, intentional and willful failure to
disclose material facts, Majority Shareholders did not seek alternative ?nancing to restructure
Sherbank debts. Moreover, Defendants? fraudulent interference with the appraisal process, the
bankruptcy proceedings, the auctioning of P?Granit assets and the judicial process made it
impossible for Majority Shareholders to stop the destructive?actions Defendants undertook
against their shares in PuGranit.

185. As a direct and proximate result of this conspiracy, the Majority Shareholders
were stripped of their assets and are entitled to an award of damages, including compensatory
and punitive damages, as well as other legal and equitable relief.

Plaintiff seeks judgment against Defendants, under Count II for the
following relief:

A. Compensatory damages of no less than $500,000,000.00;

B. Punitive damages of no less than $250,000,000.00;

C. Costs, attorney?s fees, and post~judgment interest; and

D. Such other and further relief as the Court deems proper.

COUNT 
Negligent Supervision
(Against Defendants German Gref and Sberbank Russia)

186. Paragraphs 1 through 185 are incorporated by referenced as if fully set forth

herein.

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187. Defendant German Gref, as the CEO of Defendant Sberbank Russia had a duty to
properly supervise Defendant Khaehyatureants, the CEO of Sberbank Russia?s subsidiary
Defendant Sberbank Capital and Defendant German Gref breached that duty. Defendant
Sberbank Russia had a duty to supervise Defendant German Gref and Defendant Sberbank
Russia breached that duty.

188. As a result of Defendants Gref and Sberbank Russia?s failure to properly exercise
this duty, Defendants conspired with Defendant Zhukov to develop and implement the scheme to
defraud Majority Shareholders of their shares in P-Granit, dismantle P~Granit?s assets and
transfer them into Defendant Zhukov?s company, Defendant NAC. Defendants German Gref
and Sberbank Russia knew or should have known Defendants? propensity for the illegal conduct
that caused Majority Shareholders? injury.

189. As a direct and proximate result of Defendants German Gref and Sberbank
Russia?s failure to supervise Defendants Khachyatureants and German. Gref, the Majority
Shareholders were stripped of their assets and are entitled to an award of damages, including
compensatory and punitive damages, as well as other legal and equitable relief.

WHEREFORE, Plaintiff seeks judgment against Defendants, under Count 111 for the
following relief:

A. Compensatory damages of no less than $500,000,000.00;

Punitive damages of no less than $250,000,000.00;

C. Costs, attorney?s fees, and postajudgment interest; and



Such other and further relief as the Court deems proper.

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Case Document 9 Filed 01/06/17 Page 58 of 62

COUNT IV
Breach of Fiduciary Duty
(Defendant Sberbank Russia)

190. Paragraphs 1 through 189 are incorporated by referenced as if fully set forth
herein.

191. Defendant Sberbank Russia owed a duty to Majority Shareholders to treat them
fairly in the restructuring process and to avoid self?dealing.

192. Defendant Sberbank Russia breached that duty by purposefully interfering with
Majority Shareholders? attempt to restructure their debt and assigning P?Granit?s debt to
Defendant Sberbank Capital that in turn implemented together with Defendant Zhukov and other
co?conspirators the illegal scheme to expropri'ate ownership of the P~Granit shares and dismantle
the company by distributing its assets at below market value to Defendant NAC, and ultimately
liquidating PuGranit.

193. Defendant Sberbank Russia disclosed proprietary and con?dential P-Granit
information.

194. As a direct and proximate result of Defendant Sberbank Russia?s breach of its
?duciary duty, the Majority Shareholders were stripped of their assets and are entitled to an
award of damages, including compensatory and punitive damages, as well as other legal and
equitable relief.

WHEREFORE, Plaintiff seeks judgment against Defendants, under Count IV for the

following relief:

A. Compensatory damages of no less than $500,000,000.00;

B. Punitive damages of no less than $250,000,000.00;

C. Costs, attorney?s fees, and post-judgment interest; and

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Case Document 9 Filed 01/06/17 Page 59 of 62

D. Such other and further relief as the Court deems proper.

COUNT 
Tortious Interference with Business Relations

(Defendants German Gref, Zhukov, and Khachyatureants)
195. Paragraphs 1 through 194 are incorporated by referenced as if fully set forth

herein.

196. The Majority Shareholders attempted to restructure P-Granit?s debt to Defendant
Sberbank Russia. As part of this process, Majority Shareholders disclosed P-Granit con?dential
and proprietary information, requested by Defendant PSZB to assess the potential re?finaneing.
Defendants German Gref, Zhukov and Khachyatureants were aware of Majority Shareholders?
negotiation with P828 Credit Committee, and interfered with the process. Defendants told the
CEO of Defendant PSZB to not move forward with the PuGranit re?nancing. Mr. Ananyev
stated that he was instructed by Defendant Khachyatureants to deny P?Granit the loan. He also
said that should Mr. Poymanov convince Defendant Khachyatureants not to object, Defendant
PSZB would issue the re?nancing loan.

197. Defendants conduct was malicious and wanton. As a direct and proximate result
of Defendants? conduct, the Majority Shareholders have been damaged and are entitled to relief.

WHEREFORE. Plaintiff seeks judgment against Defendants, under Count for the

following relief:

A. Compensatory damages of no less than $500,000,000.00;

B. Punitive damages of no less than $250,000,000.00;

C. Costs, attorney?s fees, and post-judgment interest; and

D. Such other and further relief as the Court deems proper.

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Case Document 9 Filed 01/06/17 Page 60 of 62

COUNT VI
Abuse of Process

(Against Defendants German Gref, Zhukov, Khachyatureants, Negotkov and Bazarnov)

198. Paragraphs 1 through 197 are incorporated by referenced as if fully set forth
herein.

199. Defendants Gref, Zhukov, Khachyatureants and Nogotkov filed criminal
complaints against Mr. Poymanov that resulted in criminal charges. Defendants maliciously and
intentionally misused the Russian criminal legal process and manufactured charges against Mr.
Poymanov. Defendants used their reputation. and power to control the criminal cases in order to
force Mr. Poymanov to cease his fight over the stolen P-Granit shares and assets. Defendants
Nogotkov and Bazarnov impeded Mr. Poymanov?s ability to defend himself outside Russia as he
cannot travel during the investigation.

200. Co-conspirator Galeeva went so far as to instruct a law enforcement agent
regarding the objective of the conspiracy ?.mto gain control over the authorized capital and the
operating activities of P-Granit? and the law enforcement actions necessary to implement the
plan, including wiretapping, ?eld surveillance, searches, and pro?trial restrictions all applicable
to Mr. Poymanov.

201. As a direct and proximate result of Defendants? conduct, the Majority
Shareholders have been damaged and are entitled to relief.

WHEREFORE, Plaintiff seeks judgment against Defendants, under Count V1 for the

following relief:

A. Compensatory damages of no less than $500,000,000.00;

B. Punitive damages of no less than $250,000,000.00;

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Case Document 9 Filed 01/06/17 Page 61 of 62

202.

herein.

203.

Costs, attorney?s fees, and post-judgment interest; and

Such other and further relief as the Court deems proper.

COUNT VII
Unjust Enrichment

(Against All Defendants)
Paragraphs 1 through 201 are incorporated by referenced as if fully set forth

Through their wrongful actiOns described above, Defendants stole the assets of P-

Granit and diverted them into Defendant NAC for the bene?t of Defendant Zhukov. By reasons

of the foregoing, Defendants have been unjustly enriched at the Majority Shareholders? expense.

204.

As a direct and proximate result of Defendants? conduct, the Majority

Shareholders have been damaged and are entitled to relief.

WHEREFORE, Plaintiff seeks judgment against Defendants, under Count VII for the

following relief:

A.


C.


Compensatory damages of no less than $500,000,000.00;
Punitive damages of no less than $250,000,000.00;
Costs, attorney?s fees, and postajudgment interest; and
Such other and further relief as the Court deems proper.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff requests that this Court award a judgment on all claims and

award it such damages and compensation, interest, attorneys? fees, costs and such other relief as

this Court may deem just.

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Case Document 9 Filed 01/06/17 Page 62 of 62

PLAINTIFF DEMANDS A JURY TRIAL ON ALL CLAIMS SO TRIABLE.

Dated: November 22, 2016

Respectfully Submitted,

,4
{If 
Caroli?e Heller
Greenberg Traurig LLP
200 Park Avenue 
New York, NY 10166
202?801-9200
helierc@gtlaw.eom

1/24/11 22/ 

M. Saunders, Jr. (pro hac vice
ppiicatimz forthcoming)

Greenberg Trauri LLP

2101 Street, NW

Suite 1000

Washington, DC. 20037

202~33 1-3 130

saunderss@2tlaw.com

124"; elem Timofti
??reenberg Traurig LLP

2101 Street, NW

Suite 1000

Washington, DC. 20037

202?530~8536

timoftin@gtlaw.com

Counsel for PPF Management LLC

62