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l _______ ,
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BENJAMIN WEY,
a/k/a "Benjamin Wei,"
a/k/a "Tianbing Wei," and
SEREF DOGAN ERBEK,
a/k/a "Dogan Erbek,"
15 Cr.
15 CRIM 611
Defendants.
-
COUNT ONE
(Conspiracy to Commit Securities Fraud and Wire Fraud)
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3.
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SmartHeat, Inc.
At various times,
stock was traded on the Nasdaq under the ticker symbol "DEER."
6.
CleanTech.Innovations, Inc.
manufacturer of windmills.
stock was traded on the Nasdaq under the ticker symbol "CTEK."
Overview of the Conspiracy
7.
'
For
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Pacific Goldrim
In fact, to
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The
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Wei
11
1
11
a/k/a "Tianbing
In certain
subject Issuers.
Manipulation of Issuers' Stock Prices
18.
For example, on
"Cleantech
buys the stock at $5 per share, stay at $5 per share bid price,
9
not less.
:----------
ERBEK
"Obviously, we need to be
I may explain
For example, in or
share
After this
Wei," a/k/a "Tianbing Wei," and SEREF DOGAN ERBEK, a/k/a "Dogan
Erbek," the defendants, were causing the share prices of the
Issuers' stock to be manipulated in the ways described above,
WEY caused shares held in the name of Wey's Sibling and other
10
,-
WEYand
13
Overt Acts
26.
from New York, New York to ERBEK in Switzerland for the purpose
of causing the market price and demand for the common stock of
CleanTech to be manipulated artificially.
b.
from Switzerland to WEY in New York, New York, advising WEY that
ERBEK was working to ensure that the common stock of CleanTech
would be traded at an artificially manipulated price.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Securities Fraud)
14
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COUNT THREE
{Securities Fraud)
16
17
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to manipulate the market price and demand for the common stock
of SmartHeat, Deer, and CleanTech.
(Title 18, United States Code, Sections 1343 and 2.)
COUNT FIVE
(Failure to Disclose Ownership in
Excess of Five Percent of Deer Stock)
"I
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20
21
BENJAMIN WEY,
~a/k/a
b.
diligence;
d.
e.
court;
PREET BHARARA
United States Attorney
24
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1-
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1------,-;-
(Ed. 9-25-58)
- v. BENJAMIN WEY,
a/k/a "Benjamin Wei,"
a/k/a "Tianbing Wei," and
SEREF DOGAN ERBEK,
a/k/a "Dogan Erbek,"
Defendants.
INDICTMENT
15 Cr.
(15 U.S.C. 78rn(d), 78j (b) & 78ff;
17 C.F.R. 240.10b-5 & 240.13d-1;
18 u.s.c. 2, 371, 1343,
1348 & 1956)
PREET BHARARA
United States Attorney
A TRUE BILL
Foreperson