UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

-----x

UNITED

STATES

OF AMERICA SEALED INDICTMENT

-v. RAJAT K. GUPTA, Defendant.
--------x

11]-CRIM 9 0 7
COUNT ONE

(Conspiracy The Grand

to Commit

Securities

Fraud)

Jury charges: Entities and Individuals to this Indictment, was a global The financial At all

Relevant 1. Goldman services

At all times relevant Inc.

Sachs Group, firm with

("Goldman Sachs")

its headquarters

in New York, New York. Goldman

times relevant company under whose

to this Indictment, stock

Sachs was a public ("NYSE")

traded on the New York Stock Exchange "GS." to this Indictment,

the ticker 2.

symbol

At all times relevant

RAJAT K.

GUPTA, Sachs

the defendant, (the "Goldman

served on the Board of Directors Sachs Board"). In his capacity received

of Goldman

as a member of

the Goldman information actual prior

Sachs Board, about Goldman

GUPTA regularly Sachs's

confidential and

earnings,

contemplated

corporate to Goldman

transactions, Sachs's public

and other significant announcement

developments

of such information.

3. Procter consumer all times whose

At all times relevant Company ("P&G
II )

to this Indictment

I

the

& Gamble products

was a global provider in Cincinnati
I

of branded Ohio. At

with its headquarters to this Indictment
I

relevant traded

P&G was a public symbol

company "PG.
I II

stock 4.

on the NYSE under the ticker

At all times relevant
I

to this Indictment

RAJAT K.

GUPTA

I

the defendant
ll ).

served on the Board of Directors as a member information

of P&G (the
l

"P&G Board regularly

In his capacity confidential

of the P&G Board about
I

GUPTA
I

received

P&G/s earnings

contemplated significant

and actual developments

corporate prior

transactions

and other announcement of

to P&G/s public

such information. 5. Galleon York
I

At all times relevant ("Galleon
ll )

to this Indictment

I

the

Group

operated Management

a family of hedge
I

funds in New
ll )

New York. a number

Galleon

LP
I

("Galleon Management including

managed

of those hedge FundI Ltd.
1

funds

the Galleon FundI Ltd.

Technology

Offshore

and Galleon
ll ) •

Diversified

(collectivelYI 6.

the "Galleon

Tech Funds

Raj Rajaratnam

("Rajaratnam

ll

)

was the founder and
I

head of Galleon. Rajaratnam general relevant

At all times relevant Member

to this Indictment Management
l

was the Managing of Galleon

of Galleon

LLC, the

partner

Management.
I

In addition

at all times manager

to this Indictment Tech Funds.

Rajaratnam

was a portfolio

for the Galleon

2

7. Hathaway Inc.

At all times relevant ("Berkshire in Omaha, engaged Hathaway")

to this Indictment, was a public holding of

Berkshire company

headquartered subsidiaries including

Nebraska,

that owned a number of business

in a variety business.

activities,

the insurance

The Relationship 8. GUPTA,

Between

GUPTA and Rajaratnam to this Indictment, had numerous RAJAT K.

At all times relevant and Rajaratnam

the defendant, with

business

dealings

each other.

In addition,

GUPTA and Rajaratnam Their business

maintained dealings

a personal included a.

relationship

and friendship.

the following: From in or about 2003 through had money invested in or about

August Galleon

2005, GUPTA offshore

in at least two different entity that GUPTA had

funds

through

an offshore

created.

On or about March was approximately b.

31, 2005, the value $2,444,518.

of those

investments

In or about 2005, GUPTA and Rajaratnam, formed an investment

along

with a third Capital GUPTA

individual,

fund called Voyager was formed, $40 million. $5 million interest and in In

Partners

("Voyager").

At the time Voyager invested

invested

$5 million 2007, GUPTA

and Rajaratnam invested

or about early Voyager,

an additional

resulting having

in GUPTA having a 20% equity an 80% equity interest.

Rajaratnam

Certain

of the assets

3

in Voyager managed

were

invested

in Galleon

hedge

funds,

including

funds

by Rajaratnam. c. In or about 2006, GUPTA and Rajaratnam, became founding partners along

with

other

individuals,

of a private in Asia

equity

fund focused Equity

on investments

in emerging

markets

("Private

Fund").

GUPTA made a commitment and Rajaratnam made

to invest to

approximately invest

$22.5 million

a commitment through

approximately

$50 million.

From inception

in or

about March Equity Fund.

2010, GUPTA

served as the Chairman through

of the Private 2008,

From inception

in or about December of the Private investment

Rajaratnam

served

as a limited partner Equity

Equity Fund committee. explored the

and a member

of the Private d.

Fund's

In or about late 2007, Rajaratnam a new Galleon in emerging fund that would markets in Asia.

possibility late-stage connection prepared GUPTA

of launching private equity

invest in In of Galleon

with that contemplated materials

fund, representatives potential

marketing

and contacted

investors. of

and Rajaratnam, investment

among others, committee.

were to serve as members

the fund's

Relevant 9. directors K. GUPTA,

Confidentiality

Policies the RAJAT

At all times relevant on the Goldman

to this Indictment, Sachs Board,

who served

including the

the defendant,

had an obligation received

to maintain

confidentiality

of information

in connection

with their

4

service

as directors, to others 10.

and an obligation for the purpose

not to provide

the

information

of securities

trading. the

At all times relevant served

to this Indictment, including

directors

who

on the P&G Board,

RAJAT K. GUPTA,

the defendant, of information directors, others

had an obligation received

to maintain

the confidentiality service as to

in connection

with their

and an obligation

not to provide

the information

for the purpose

of securities

trading. Scheme in or about and

The Insider Trading 11. January others 2009, known

From at least in or about 2008 through RAJAT K. GUPTA, the defendant,

Raj Rajaratnam,

and unknown,

participated

in a scheme relating

to defraud by to Goldman

disclosing

material,

nonpublic

information

Sachs and P&G securities GUPTA,

(the "Inside

Information")

and/or

executing Information. the

transactions

on the basis of the Inside known and unknown, ways: the Inside

Rajaratnam, scheme a.

and others

effectuated

fraudulent

in the following GUPTA obtained

Information

in his

capacity

as a member b.

of the Goldman In violation

Sachs Board

and the P&G Board.

of duties

of trust and confidence

that GUPTA owed shareholders, Rajaratnam,

to Goldman

Sachs and P&G, and their respective the Inside Information to

GUPTA with

disclosed

the understanding to purchase

that Rajaratnam

would use the

Inside Information

and sell securities.

5

c. disclosed the Inside

Rajaratnam, Information caused Sachs,

in turn, knowing

that GUPTA had of duties of in the

to him in violation

trust and confidence, securities of Goldman

the execution

of transactions

P&G, and other companies

on the basis with

of the Inside other

Information,

and shared the Inside thereby earning

Information

coconspirators

at Galleon, losses)

illegal profits

(and illegally

avoiding

of millions

of dollars.

GUPTA's Disclosure of Inside Information Concerning Berkshire Hathaway's $5 Billion Investment in Goldman Sachs 12. K. GUPTA, meeting Goldman For example, on or about September by telephone During 23, 2008, RAJAT in a special the

the defendant,

participated Sachs Board.

of the Goldman Sachs Board

that meeting, a $5 billion

considered

and approved

investment markets

from Berkshire

Hathaway

(at a time when the financial distress Holdings in the wake of the Inc. on or about of Berkshire following the

were experiencing filing

significant Brothers

bankruptcy September Hathaway's

of Lehman

15, 2008). investment

The public in Goldman

announcement

Sachs was announced 23, 2008.

4:00 p.m. close of the NYSE on September public announcement, 13. defendant, the Goldman 3:54 p.m., that information

Prior to the

was confidential. after RAJAT K. GUPTA, the meeting of

Approximately

16 seconds

disconnected

his telephone

from the special

Sachs Board on September GUPTA's assistant

23, 2008, at approximately at his office in GUPTA to the

called Rajaratnam thereafter,
6

New York, New York,

and shortly

connected

call.

During

that call, GUPTA disclosed Berkshire

Inside

Information

to

Rajaratnam Sachs.

concerning

Hathaway's

investment

in Goldman

14.

On September before

23, 2008, at approximately

3:58 p.m., to the

just two minutes public Sachs,

the close of the market, Hathaway's

and prior

announcement Rajaratnam

of Berkshire caused

investment

in Goldman the

the Galleon 350,000

Tech Funds to order

purchase stock,

of approximately was worth

shares of Goldman

Sachs common $43 million.

which

a total value of approximately Tech Funds purchased

Of that amount, 217,200 shares

the Galleon of Goldman

approximately $124

Sachs common

stock at approximately $27 million.

per share,

at a total 15.

cost of approximately

Later on September Sachs publicly Goldman

23, 2008, following announced

the close of by

the NYSE, Berkshire morning, increase closing

Goldman

the investment

Hathaway. September of more

Sachs's

stock opened

the following reflecting an

24, 2008, at $128.44 per share,

than $3.00 per share from the pre-announcement

price 16.

of $125.05 per share. On or about September 24, 2008, Rajaratnam its position Sachs caused Sachs

the Galleon stock.

Tech Funds to liquidate

in Goldman

The sale of the 217,200 at approximately for the Galleon $840,000.

Goldman

shares

that had been

purchased generated

3:58 p.m. on September Tech Funds an illegal

23, 2008 of

profit

approximately

7

17. approximately

On the morning

of September

24r

2008r

at with a told

7:05 a.m.rRajaratnam andr during

spoke by telephone

trader at Galleon the trader saying

that conversationr

Rajaratnam

that he had gotten

a call at 3:58 p.m. the day before to Goldman Sachs. Less than an
24r 2008r

something

good might happen

hour laterr at approximately Rajaratnam during again

7:56 a.m'r

on September

spoke by telephone Rajaratnam

with the same trader andr told the trader saying that he had good

that conversationr

gotten a call at 3:58 p.m. the day before was going to happen GUPTArs to Goldman Sachs.

something

October 2008 Disclosure Goldman Sachsrs Negative 18. As another

of Inside Information Concerning Interim Financial Results on or about October
23r 2008r

exampler

RAJAT K. GUPTAr meeting

the defendantr

participated

by telephone senior

in a of

of the Goldman advised

Sachs Board in which

executives

the company significant Sachsrs

the members

of the Goldman

Sachs Board of Goldman that for

developments

and issues at the company. financial
2008r

confidential ending

internal November
28r

analyses

showed

the quarter pointr

the company

hadr at that was as a public Goldman financial

lost nearly

$2 per share. because

That information in the firmrs

particularly companYr

significant

history

it had never

before

lost money

in any quarter. interim

Sachs did not publicly resultsr and that

disclose

those negative

information

was confidential.

8

19. defendant, on October Rajaratnam 13 minutes. Inside

Approximately

23 seconds

after RAJAT

K. GUPTA, the Sachs Board called

disconnected

from the call with the Goldman 4:49 p.m., GUPTA

23, 2008, at approximately and spoke to Rajaratnam During

by telephone

for approximately to Rajaratnam

that call, GUPTA disclosed concerning Goldman Sachs's

Information

negative

interim

earnings. 20. RAJAT K. GUPTA, On the basis of the Inside Rajaratnam in Goldman illegally Information caused Sachs provided by

the defendant, transactions Tech Funds

the Galleon

Tech

Funds to execute enabled

securities

that

the Galleon

to avoid a loss of on the morning beginning at Tech Funds of October

several million

dollars. after

Specifically, the NYSE opened,

24, 2008, shortly approximately

9:31 a.m., Rajaratnam long position

caused

the Galleon Sachs

to sell its entire consisted $97.74

in Goldman shares,

stock, which ranging from

of approximately

150,000

at prices

to $102.17. 21. At approximately 12:08 p.m. on October with a Galleon stated portfolio 24, 2008, manager.

)

Rajaratnam During

spoke by telephone

that conversation, from someone Goldman worse

Rajaratnam

that he had heard the that, among which was at the

day before

on the Goldman

Sachs Board

other things, substantially time.

Sachs was losing $2 per share, market

than the prevailing

expectations

9

22. publicly

On or about December

16, 2008, Goldman ended November

Sachs 28, 2008,

announced

that for the quarter

the company share. common avoided GUPTA's

had lost approximately approximately

$2.12 billion, 150,000

or $4.97 per Sachs

By selling

shares of Goldman

stock on October

24, 2008, the Galleon dollars.

Tech Funds illegally

a loss of several million

January 2009 Disclosure of Inside Information Concerning Procter & Gamble's Quarterly Financial Results 23. As another January example, beginning at approximately 9:00

a.m., on or about announced

29, 2009{ the day before RAJAT K. GUPTA,

P&G publicly the defendant, of the

its quarterly

earnings,

participated Audit

by telephone,

from Switzerland, During

in a meeting

Committee

of the P&G Board.

that call, the Audit release, a draft of of the Audit

Committee

discussed

the next day's earnings been circulated GUPTA.

which had previously Committee, things, related including

to the members stated,

That draft

among other (i.e., sales

that the company to preexisting which

expected

its organic

sales

business

segments)

to grow 2-5% for the that P&G

fiscal year, had previously 24. 2009, RAJAT Switzerland minutes. Rajaratnam

compared

negatively

to the guidance

provided

to the public. 1:18 p.m., called on or about January Rajaratnam from eight to 29,

At approximately

K. GUPTA, and spoke

the defendant, to Rajaratnam

for approximately Inside

During

that call, GUPTA provided P&G's earnings 10

Information

concerning

release

planned

for the next

day.

That same afternoon, that he had heard concerning

Rajaratnam

told a portfolio

manager at certain

Galleon

from someone on the P&G Board sales growth.

information beginning

P&G's organic

Thereafter, January 29,

at approximately

2:52 p.m., on or about

2009, on the basis provided

of the Inside Information certain Galleon

that GUPTA had

to Rajaratnam, 180,000 RAJAT

funds sold short stock. provided friendship the Inside and and

approximately 25. Information business hoped

shares of P&G common K. GUPTA,

the defendant, of GUPTA's

to Rajaratnam

because

relationships

with Rajaratnam.

GUPTA benefitted

to benefit

from his friendship in various

and business

relationships financial.

with Rajaratnam

ways, some of which were The Conspiracy

26.

From at least in or about 2008 up to and including 2009, in the Southern the defendant, willfully District of New York and and

in or about January elsewhere, others RAJAT

K. GUPTA,

Raj Rajaratnam,

known and unknown, confederate

and knowingly

did combine,

conspire, commit fraud,

and agree together the United

and with each other to to wit, securities Sections

offenses

against

States,

in violation

of Title 15, United

States

Code,

78j (b) and 78ff, and Title Section 240.10b-5.

17, Code of Federal

Regulations,

11

Object

of the Conspiracy Fraud of the conspiracy and others that

Securities 27. RAJAT K. GUPTA/ and unknown/

It was a part and an object the defendant/

Raj Rajaratnam, directly

known by

willfully

and knowingly/

and indirectly,

the use of the means and of the mails/ exchanges/ purchase devices would

and instrumentalities

of interstate

commerce/

and of facilities

of national

securities with the

and did use and employ,

in connection

and sale of securities/ and contrivances Section

manipulative of Title

and deceptive 17/ Code of Federal devices, schemes

in violation by:

Regulations/ and artifices

240.10b-S

(a) employing untrue

to defraud;

(b) making

statements

of material

fact and omitting make the statements which

to state material made,

facts necessary

in order to under

in the light of the circumstances and (c) engaging

they were made/ and courses

not misleading; of business

in acts/

practices

which operated

and would operate of Title

as a fraud and deceit 15/ United States

upon any person,

all in violation

Code/ Sections

78j (b) and 78ff, and Title 17, 240.10b-S.

Code of Federal

Regulations/ Means

Section

and Methods the means

of the Conspiracy by which RAJAT K.

28. GUPTA/

Among

and methods

the defendant/

Raj Rajaratnam,

and their coconspirators were the following:

would and did carry out the conspiracy

12

a. from Goldman other duties companies Sachs

GUPTA disclosed

Inside of

Information

obtained and

and P&G in violation

(a) the fiduciary

of trust and confidence shareholders,

that GUPTA owed to those of with Goldman

and their

(b) the expectations to transactions of Goldman

confidentiality

of the counterparties (6) the policies

Sachs and P&G, and regarding nonpublic

Sachs and P&G and material,

the use and safekeeping information. b. GUPTA,

of confidential

in breach

of his duties

of

confidentiality shareholders, understanding purchase and/or

to Goldman disclosed

Sachs and P&G, and their respective to Rajaratnam, with the to

Inside Information

that Rajaratnam

would use the Inside and thereby receive

Information

and sell securities, avoid losses.

illegal profits

illegally c.

Rajaratnam,

while

in possession

of Inside by GUPTA in

Information breach

that Rajaratnam

knew had been disclosed

of GUPTA's trades

duty to keep the information others to execute

confidential, trades based on the profits and/or

executed

and caused

Inside Information illegally avoided d. provided by GUPTA

and thereby losses. Rajaratnam

received

illegal

shared

the Inside

Information

with other coconspirators

at Galleon.

13

Overt Acts 29. illegal object In furtherance thereof, of the conspiracy and to effect the Raj overt

RAJAT K. GUPTA,

the defendant,

Rajaratnam, acts,

and their

coconspirators

committed District

the following

among others,

in the Southern

of New York and

elsewhere: a. portfolio manager On or about June 3, 2008, Rajaratnam at Galleon that he had learned its Folgers told a

from someone on to the

the P&G Board that P&G was selling J.M. Smucker Company. b. 5:41 p.m., officer GUPTA

business

On or about June 10, 2008, at approximately spoke by telephone Sachs. On or about June 10, 2008, at approximately Rajaratnam. with a senior executive

of Goldman c.

9:24 p.m, GUPTA called d. 9:31 p.m., Rajaratnam. e. 9:42 p.m., GUPTA

On or about June 10, 2008, at approximately and left a voice mail message for

GUPTA called

On or about June 10, 2008, at approximately spoke by telephone with Rajaratnam, who was in

New York, New York. f. 8:43 a.m., while On or about June II, 2008, at approximately in New York, New York, Rajaratnam called GUPTA.

14

g. approximately to purchase contracts. h. the Galleon Goldman Tech

On or about June 11, 2008, beginning caused the Galleon

at

9:35 a.m., Rajaratnam approximately

Tech Funds

5,500 Goldman

Sachs call option

On or about June 12, 2008, Rajaratnam Funds to purchase stock. On or about June 12, 2008, Rajaratnam Funds to purchase stock. approximately 75,000 approximately 50,000

caused shares of

Sachs

common i.

caused shares of

the Galleon Goldman

Tech

Sachs

common j.

On or about July 29, 2008, at approximately spoke by telephone with Rajaratnam during a meeting and disclosed of the Goldman

5:39 p.m., information

GUPTA

that GUPTA had learned

Sachs Board. k. approximately On or about September 23, 2008, from while in New of

3:13 p.m. to 3:54 p.m. and 34 seconds, GUPTA participated Board. On or about September by telephone

York, New York, the Goldman

in a meeting

Sachs 1.

23, 2008, at direction, in New York, New

approximately GUPTA's York.

3:54 p.m. and 50 seconds, called Rajaratnam

at GUPTA's

assistant

at his office

m. approximately

On or about September

23, 2008, at spoke

3:55 p.m., while

in New York, New York, GUPTA

15

by telephone concerning

with Rajaratnam

and disclosed investment

Inside

Information Sachs.

Berkshire n.

Hathaway's

in Goldman 23, 2008, at

On or about September

approximately caused Galleon Sachs common

3:58 p.m., while to purchase

in New York, New York, Rajaratnam 217,200 shares of Goldman

approximately

stock. o. On or about September
r

23, 2008, at

approximately message

6:16 p.m.

GUPTA called and left a voice mail

for Rajaratnam. p. On or about September 24, 2008, at with a

approximately

7:05 a.m., Rajaratnam

spoke by telephone

trader at Galleon q. approximately Trader-A,

who was in New York, New York On or about September

("Trader-A").

24, 2008, at with

7:56 a.m., Rajaratnam

spoke by telephone

who was in New York, New York. r. On or about October 23, 2008, from GUPTA Sachs Board.

approximately participated

4:16 p.m.

to 4:49 p.m. and 47 seconds, in a meeting of the Goldman

by telephone s.

On or about October spoke by telephone and provided interim

23, 2008, at approximately who was in concerning

4:50 p.m., GUPTA

with Rajaratnam, Information

New ~ork, New York, Goldman Sachs's

Inside

negative t.

earnings. 24, 2008, beginning the Galleon at

On or about October

approximately

9:31 a.m., Rajaratnam

caused

Tech Funds

16

to sell approximately 'Stock. u.
~2:08

150,000

shares of Goldman

Sachs common

On or about October

24, 2008,

at approximately portfolio

p.m., Rajaratnam

spoke by telephone

with a Galleon

manager. v. 9:00 a.m., GUPTA, On or about January while in Switzerland, Committee
29, 2009,

at approximately by telephone

participated

in a meeting

of the Audit w.

of the P&G Board.
29, 2009,

On or about January while in Switzerland,

at approximately who was

1:18 p.m., GUPTA,

called

Rajaratnam,

in New York, New York.
x. a Galleon portfolio On or about January manager,
29, 2009,

Rajaratnam

told

who was in New York, New York, that concerning P&G's organic sales

he had received growth

certain

information

from a contact y.

on the P&G Board.
29, 2009,

On or about January certain Galleon

beginning

at

approximately approximately

2:52 p.m., 180,000

funds sold short stock.
371.)

shares

of P&G common States

(Title 18, United

Code, Section

17

COUNTS TWO THROUGH SIX (Securities Fraud) The Grand 30. Jury further charges: in paragraphs 1 through

The allegations

contained

25 and 28 through forth herein. 31. Southern

29 are repeated

and realleged

as if fully set

On or about the dates set forth below, of New York and elsewhere, and knowingly, directly

in the the by

District

RAJAT K. GUPTA, and indirectly,

defendant,

willfully

the use of the means the mails connection

and instrumentalities of national

of interstate securities

commerce, in

and the facilities with the purchase

exchanges,

and sale of securities, devices

did use and in

employ manipulative violation 240.10b-5, defraudi omitting of Title by:

and deceptive

and contrivances, Section

17, Code of Federal devices,

Regulation, schemes,

(a) employing untrue

and artifices facts and

to

(b) making

statements

of material

to state material made,

facts necessary

in order to make the under which in acts, and would

statements

in the light of the circumstances not misleadingi and (c) engaging which operated

they were made, practices, operate

and courses

of business

as a fraud and deceit upon any person, Information

to wit, on the to Raj Rajaratnam of to execute

basis of Inside in violation

that GUPTA disclosed

of GUPTA's

fiduciary

and other duties and caused

confidentiality, the securities

Rajaratnam transactions

executed

others

listed below: 18

COUNT TWO

DATE September 23, 2008 at approximately 3:58 p.m. September 23, 2008 at approximately 3:58 p.m. October 24, 2008 at approximately 9: 31 a.m. October 24, 2008 at approximately 10:09 a.m. October 24, 2008 at approximately 10:37 a.m.

SECURITY Goldman Sachs Goldman Sachs Goldman Sachs Goldman Sachs Goldman Sachs

TRANSACTION Purchase of approximately 150,000 shares of common stock
\

THREE

Purchase of approximately 67,200 shares of common stock Sale of approximately 50,000 shares of common stock Sale of approximately 50,000 shares of common stock Sale of approximately 50,000 shares of common stock

FOUR

FIVE

SIX

(Title 15, United States Code, Sections 78j (b) and 78ffi Title 17, Code of Federal Regulations, Section 240.10b-5i and Title 18, United States Code, Section 2.) FORFEITURE 32. foregoing As a result ALLEGATION one or more in Counts of the One through shall States

of committing

securities

fraud offenses

alleged

Six of this Indictment, forfeit Code, to the United

RAJAT K. GUPTA, States pursuant

the defendant,

to Title

18, United States

Section

981(a) (1) (C) and Title 28, United real and personal,

Code or

Section

2461, all property, from proceeds fraud offenses but not limited

that constitutes of the Six,

is derived securities including

traceable alleged

to the commission in Counts

One through

to the following:

19

Money Judgment a. currency which commission At least a sum of money from proceeds in United states

was derived

traceable alleged

to the in Counts One

of the securities

fraud offenses

through Six. Substitute 33. as a result Assets Provision forfeitable property,

If any of the above-described

of any act or omission a.

of the defendant: of due

cannot be located upon the exercise

diligence; b. with, a third party; c. Court; d. e. cannot be divided has been substantially has been commingled without difficulty; diminished in value; or which has been placed beyond the jurisdiction of the has been transferred or sold to, or deposited

with other property

20

it is the intent United States

of the United Section

States, pursuant

to Title 21, of any

Code,

853(p), to seek forfeiture up to the value

other property property

of the defendant above.

of the forfeitable

described

(Title 15, United States Code, Sections 78j (b) and 78ff; Title 18, United States Code, Section 981(a) (1) (C); Title 28, United States Code, Section 2461(c); and Title 17, Code of Federal Regulations, Section 240.10b-5.)

21

Form No. USA-33s-274

(Ed. 9-25-58)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

UNITED

STATES OF AMERICA - v. -

RAJAT K. GUPTA, Defendant. INDICTMENT 11 Cr. (Title 15, United States Code, Sections 78j (b) and 78ff; Title 17, Code of Federal Regulations, Section 240.10b-5; and Title 18, United States Code, Sections 2 and 371.) PREET BHARARA United States Attorney. A TRUE BILL

ForepeiJ.

Sign up to vote on this title
UsefulNot useful