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Fraudulent Re-registration: The seized documents were used to fraudulently transfer the ownership of these three companies from Hermitage (HSBC) to a shell company (“Pluton”) owned by a convicted murderer, Viktor Markelov , effectively stealing the companies.8 Fabrication of Liabilities: The stolen companies were then sued by other shell companies controlled by the Klyuev Group for fake debts (breach of non-existent contracts).9 Judicial Corruption: Lawyers appointed by the criminals (posing as Hermitage lawyers) appeared in court and immediately pled guilty to the fake debts.10 Judges, complicit in the scheme, issued judgments requiring the companies to pay nearly $1 billion.11 The Tax Theft: The criminals used these court judgments to file amended tax returns.12 They claimed that because the companies now had massive “losses” (the fake debts), the $230 million in capital gains taxes Hermitage had paid in 2006 should be refunded.13 Official Complicity: On December 24, 2007 , the heads of Moscow Tax Offices No