In Stewart's case the prosecution took five lies about one deception--made in untaped and unsworn interviews with federal agents--and wove them into five criminal counts, winning four guilty verdicts (the fifth was thrown out).
After Enron's collapse, I remember being asked how business schools could be training people with so little respect for the truth--how the company's executives could engage in such deception.
In court documents, Christie's says it became concerned that Rose or Berry-Hill may have engaged in a "deception and effort to manipulate" prices in order to set new benchmarks for works they could resell.