NEW YORK, SEPT. 26 -- Federal prosecutors, calling Michael Milken the biggest white-collar criminal of the 1980s, said today that the former junk bond financier committed more crimes than has previously been disclosed and that his string of fraudulent stock deals not only disrupted financial markets but helped bring about the collapse of his old firm, Drexel Burnham Lambert Inc.

In a lengthy sentencing memorandum urging U.S. District Judge Kimba Wood to give Milken "a substantial" prison term, prosecutors outlined several new transactions in which they accuse Milken of commiting insider trading and other financial market crimes over the past decade. These accusations are in addition to the 98 original charges they brought against him last year. He pleaded guilty to six of those.

The prosecutors, who made public the document in advance of Milken's scheduled sentencing on Monday, provided the most sweeping and detailed account yet of Milken's suspected violations and cast new light on the government's overall case against the former Drexel executive.

Allegations disclosed in the documents released today include not only charges of insider trading but also charges of illegal stock price manipulation and other crimes involving the securities of Caesars World Inc., Republic Airlines and an unspecified number of other companies that remained unidentified.

"Milken's crimes formed a pattern of calculated fraud, deceit and corruption of the highest magnitude," the document said. "In a highly sophisticated and systematic way, Milken endeavored to enhance his power and enlarge his wealth by willingly cheating clients, manipulating the markets and evading the laws and rules designed to safeguard the investing public."

Milken -- who was dubbed the junk bond king for his preeminence in the risky, high-yielding securities that transformed U.S. finance in the past decade -- faces a maximum sentence of 28 years in prison after pleading guilty to six felonies in April as part of a plea bargain in the biggest securities fraud case in Wall Street's history.

The prosecutors said he merits stiff punishment because he does not genuinely regret committing the crimes he pleaded guilty to. They also argued that a lengthy prison term is needed to deter other executives from committing crimes and to encourage Milken to help investigators catch other white-collar criminals in the future.

"He has committed a range of serious white-collar crimes unmatched in the 1980s," the prosecutors said. "The court's sentence must demonstrate that persons who possess great wealth and prominence cannot expect that their privilege or their money will insulate them from certain and serious punishment."

Milken's lawyers, in their sentencing memo made public yesterday, said their client's crimes were isolated infractions and did not constitute a pattern of wrongdoing. They also specifically disputed many of the government's individual charges against Milken, particularly the allegations that he had engaged in insider trading.

Even with today's disclosure, however, many details of the government's case against Milken remain secret. On Wood's orders, 88 pages of the 210-page sentencing memorandum were not made public in order to protect the identities of persons who are suspected of having conspired with Milken to commit crimes but who have not been formally charged.

In the plea bargain last spring, the government dropped 92 charges against Milken in return for his guilty plea on six counts and his agreement to pay $600 million in fines and restitution to victims of his swindles.

Although Wood is to sentence Milken only for crimes to which he pleaded guilty, the prosecution maintains that the severity of the prison term should reflect the other crimes that the government believes he has committed.

The government also maintains that Milken himself, in pleading guilty to a conspiracy count, has acknowledged that he committed unspecified crimes beyond the six that he admitted committing. Prosecutors point out that it is perfectly legal for a judge, in fixing a sentence, to consider the government's suspicions of wrongdoing beyond crimes for which a convict has been found guilty.

"The court has virtually unlimited authority to consider all relevant information concerning the character, background, criminal conduct and other activities of a defendant," said the prosecution, led by Acting U.S. Attorney Roger S. Hayes.

In contrast, Milken's principal attorney, Arthur L. Liman, insisted that the judge should weigh only the six crimes Milken admitted to in the plea agreement.

"If the government wanted Mr. Milken punished for other crimes it should have gone to trial or insisted on a plea to an insider trading" or racketeering count, the defense said.

The defense also argued at length that none of the government's own witnesses -- including many former Drexel employees who have been granted immunity -- had been able to support the allegation that criminal activity was at the root of Milken's fabulous success as a financier.

"Although the government repeatedly asserts that Mr. Milken's business and success was built on illegal conduct, the government fails to disclose to the court that not a single one of its cooperating witnesses supports this unfair charge," Liman wrote.

The prosecution made an indirect but revealing admission in urging Wood to give Milken a stiff sentence that could later be cut to encourage him to cooperate with prosecutors. That recommendation showed that the government no longer believes that the original plea bargain provides sufficient inducement to help investigators catch other suspected white-collar criminals.

Without making a specific recommendation for a sentence, the prosecution hinted that it would like a substantially longer prison term than that given to former premier arbitrageur Ivan Boesky, who received a three-year sentence. While saying it did not seek an "arithmetic" computation of the sentence, the prosecution noted that Milken had pleaded guilty to six felonies, compared to only one admitted to by Boesky, and that Milken's $600 million penalty was six times that of Boesky's.


"Michael's offenses were neither venal nor motivated by greed. ... Michael gained very little from the crimes he committed."


"Milken's astonishing suggestion that he was 'never a member' of the 'generation of materialistic professionals devoted to the accumulation of wealth' borders on the comical. ... his crimes ... were committed for venal reasons -- to enhance Milken's personal power and increase his wealth."


"Milken's crimes stand in sharp contrast to the characteristics and values he has displayed throughout his life."


"Milken's crimes formed a pattern of calculated fraud, deceit and corruption of the highest magnitude. ... The six charges to which Milken pleaded guilty provide but a sampling of the larger pattern of criminal activity that permeated Milken's {junk bond} department."


"Deception -- whether through false filings, obstruction of justice, perjury, bags of cash, code words or secret offshore accounts -- became the hallmark of {convicted insider trader Ivan} Boesky's operation. ... Milken ... cannot be compared to ... Boesky"


Badges of fraud {similar to Boesky's} were the hallmarks of Milken's crimes."


"The government's hostility is ... evidenced by its improper attempt to have Mr. Milken punished less for his crimes than for his wealth and status."


"By its sentence, this court must demonstrate that no man -- no matter how rich and how powerful -- may make his own rules."


"Michael should be sentenced based on the offenses to which he pleaded guilty. He should not be sentenced for crimes he did not commit."


"Milken has admitted -- albeit without specificity -- his participation in crimes additional to the crimes to which he specifically" pleaded guilty.


"Michael Milken's acceptance of responsibility and contrition for what he has done are not matters of form; they are genuine and heartfelt. ... Michael feels profound remorse for his actions."


"Milken's decision {to plead guilty to six crimes} reflects surrender, not contrition. ... His piety rings false.