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USDC MA ECF 3 2013-04-21 USA v Tsarnaev - Criminal Complaint

USDC MA ECF 3 2013-04-21 USA v Tsarnaev - Criminal Complaint

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Published by Jack Ryan
Boston Marathon Bombing Suspect - CRIMINAL COMPLAINT
Boston Marathon Bombing Suspect - CRIMINAL COMPLAINT

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Categories:Types, Research
Published by: Jack Ryan on Apr 22, 2013
Copyright:Attribution Non-commercial

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04/27/2013

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AO
91
(Rev. 11/11) Criminal
Complaint
UNITED STATES DISTRICT COURT
for theDistrict
of
MassachusettsUnited States
of
America)
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Dzhokhar Tsarnaev)
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DeJendant(s)
CRIMINAL COMPLAINT
I, the complainant in this case, state that the
following
is true to the best
of
my knowledge and belief.On or about the date(s)
of
April
15,2013
in the county
of
~_~_U!!~
 
in the
~
 
~~~~_
 
District
of
Massachusetts , the defendant(s) violated:
Code SectionOffense Description
18 U.S.C. s 2332a(a) Use of a Weapon of Mass Destruction
18
U.S.C. s
844(i)
Malicious Destruction of Property Resulting in DeathThis criminal complaint is
based
on these facts:See Attached Affidavit of Special Agent Daniel
R.
Genck
if
Continued on the attached sheet.
Complainant's signature
Daniel
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Ge~~.~~"pec~1
 
Agen~,fBI
 
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Printed name
and
title
Sworn to before me and signed in
my
presence.Date:
04/21/20.~13-----..@=-
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Case 1:13-mj-02106-MBB Document 3 Filed 04/21/13 Page 1 of 1
 
AFFIDAVIT OF SPECIAL AGENT
I, Daniel
R.
Genck, being duly sworn, depose and state:1. I am a Special Agent with the Federal Bureau
of
Investigation ("FBI") and havebeen so employed since 2009. I am currently assigned to one
of
the Boston Field Office'sCounter-terrorism Squads. Among other things, I am responsible for conducting nationalsecurity investigations
of
potential violations
of
federal criminal laws as a member
of
the JointTerrorism Task Force ("JTTF"). During my tenure as an agent, I have participated in numerousnational security investigations. I have received extensive training and experience in the conduct
of
national security investigations, and those matters involving domestic and internationalterrorism.2. During my employment with the FBI, I have conducted and participated in manyinvestigations involving violations
of
United States laws relating to the provision
of
materialsupport to terrorism. I have participated in the execution
of
numerous federal search and arrestwarrants in such investigations. I have had extensive training in many methods used to commitacts
of
terrorism contrary to United States law.3. This affidavit is submitted in support
of
an application for a complaint charging
DZHOKHAR A. TSARNAEV
of
Cambridge, Massachusetts
("DZHOKHAR TSARNAEV")
with using a weapon
of
mass destruction against persons and property at the Boston Marathon onApril 15, 2013, resulting in death. More specifically, I submit this affidavit in support
of
anapplication for a complaint charging
DZHOKHAR
TSARNAEV
with
(1)
unlawfully using andconspiring to use a weapon
of
mass destruction (namely, an improvised explosive device) againstpersons and property within the United States used in interstate and foreign commerce and in anactivity that affects interstate and foreign commerce, which offense and its results affected
Case 1:13-mj-02106-MBB Document 3-1 Filed 04/21/13 Page 1 of 10
 
interstate and foreign commerce (including, but not limited to, the Boston Marathon, privatebusinesses in Eastern Massachusetts, and the City
of
Boston itself), resulting in death, in violation
of
18 U.S.c. § 2332a; and (2) maliciously damaging and destroying, by means
of
an explosive,real and personal property used in interstate and foreign commerce and in an activity affectinginterstate and foreign commerce, resulting in personal injury and death, in violation
of
18 U.S.C.
§ 844(i).
4. This affidavit is based upon my personal involvement in this investigation, mytraining and experience, my review
of
relevant evidence, and information supplied to me by otherlaw enforcement officers.
It
does not include each and every fact known to me about theinvestigation, but rather only those facts that I believe are sufficient to establish the requisiteprobable cause.
FACTS AND CIRCUMSTANCES
A.
The Boston Marathon Explosions5. The Boston Marathon is an annual race that attracts runners from all over theUnited States and the world. According to the Boston Athletic Association, which administersthe Marathon, over 23,000 runners participated in this year's race. The Marathon has asubstantial impact on interstate and foreign commerce. For example, based on publicly availableinformation, I believe that the runners and their families --including those who travel to theBoston area from other states and countries --typically spend tens
of
millions
of
dollars each yearat local area hotels, restaurants and shops, in the days before, during, and after the Marathon. Inaddition, a number
of
the restaurants and stores in the area near the finish line have special eventsfor spectators.6. The final stretch
of
the Boston Marathon runs eastward along the center of
2
Case 1:13-mj-02106-MBB Document 3-1 Filed 04/21/13 Page 2 of 10

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