Objects of the Conspiracy. Fraud In Connection With ThePurchase Or Sale Of Securities. 2. It was a part and an object of the conspiracy that SCOTT D. SULLIVAN and DAVID F. MYERS, the defendants, and others known and unknown, unlawfully, willfully, and knowingly, directly and indirectly, by use of the means and instrumentalities of interstate commerce, the mails, and the facilities of national securities exchanges, would and did use and employ manipulative and deceptive devices and contrivances in connection with the purchase and sale of securities issued by WorldCom, Inc., in violation of Title 17, Code of Federal Regulations, Section 240.10b-5, by (a) employing devices, schemes, and artifices to defraud; (b) making and causing WorldCom, Inc. to make untrue statements of material facts and omitting to state material facts necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; and (c) engaging in acts, practices, and courses of business which operated and would operate as a fraud and deceit upon the purchasers and sellers of WorldCom, Inc. securities, in violation of Title 15, United States Code, Sections 78j(b) and 78ff.

False Statements InAnnual And Quarterly SEC Reports, 3, It was further a part and an object starlord iphone case of the conspiracy that SCOTT D, SULLIVAN and DAVID F, MYERS, the defendants, and others known and unknown, unlawfully, willfully, and knowingly, in applications, reports, and documents required to be filed under the Act and the rules and regulations thereunder, would and did make and cause to be made statements which were false and misleading with respect to material facts, in violation of Title 15, United States Code, Section 78ff..

False Statements to Auditors. 4. It was further a part and an object of the conspiracy that SCOTT D. SULLIVAN and DAVID F. MYERS, the defendants, being directors and officers of WorldCom, Inc., an issuer with a class of securities registered pursuant to Section 12 of the Act, and others known and unknown, unlawfully, willfully, and knowingly, would and did, directly and indirectly: (a) make and cause to be made materially false and misleading statements; and (b) omit to state, and cause others to omit to state, material facts necessary in order to make the statements made, in light of the circumstances under which such statements were made, not misleading to accountants in connection with: (i) audits and examinations of the Financial Statements of WorldCom, Inc.; and (ii) the preparation and filing of documents and reports required to be filed with the SEC pursuant to rules and regulations enacted by the SEC, in violation of Title 17, Code of Federal Regulations, Section 240.13b2-2 and Title 15, United States Code, Section 78ff.

False Books starlord iphone case and Records, 5, It was further a part and an object of the conspiracy that SCOTT D, SULLIVAN and DAVID F, MYERS, the defendants, and others known and unknown, unlawfully, willfully, and knowingly would and did, directly and indirectly, falsify and cause to be falsified books, records, and accounts subject to Section 13(b)(2) of the Act, namely books, records, and accounts of WorldCom, Inc., an issuer with a class of securities registered pursuant to the Act, which WorldCom, Inc, was required to make and keep in reasonable detail, accurately and fairly reflecting the transactions and dispositions of the assets of WorldCom, Inc., in violation of Title 15, United States Code, Sections 78m(b)(2)(A), 78m(b)(5) and 78ff, and Title 17, Code of Federal Regulations, Section 240.13b2-1..

6. In furtherance of the conspiracy and to effect its illegal objects, SCOTT D. SULLIVAN and DAVID F. MYERS, the defendants, and their co-conspirators, committed the following overt acts, among others, in the Southern District of New York and elsewhere. a. In or about April 2001, at SULLIVAN's direction, MYERS directed employees of the General Accounting department at WorldCom, Inc. ("WorldCom") to transfer approximately $771 million in "line cost" expenses to various Property, Plant & Equipment ("PP&E") accounts in WorldCom's general ledger.