Boston Marathon Bombing Criminal Complaint Download PDF Here

Boston Marathon Bombing Criminal Complaint is available here:

Excerpts from Special Agent’s Affidavit:

“I submit this affidavit in support of an application for a complaint charging DZHOKHAR TSARNAEV with (1) unlawfully using and conspiring to use a weapon of mass destruction (namely, an improvised explosive device) against persons and property within the United States …”

“I have reviewed videotape footage taken from a seculity camcra located on Boylston Street near the corner of Boylston and Gloucester Streets. At approximately 2:38 p.m. (based on the video’s duration and timing of the explosions) — i.e., approximately 1 I minutes before the first explosion –two young men can be seen turning left (eastward) onto Uoylsion from Gloucester Street. Both men are carrying large knapsacks.”

“Approximately 30 seconds before the first explosion, he lifts his phone to his ear as if he is speaking on his cell phone, and keeps it there for approximately 18 seconds. A few seconds afler he finishes the call, the large crowd of people around him can be seen reacting to the first explosion. Virtually every head turns to the east (towards the finish line) and stares in that direction in apparent bewilderment and alarm. Bomber

Two, virtually alone among the individuals in front of’the restaurant, appears calm.”

“In addition, from the scene of the shootout on Laurel Street in Watertown, the FBI has recovered two unexploded IEDs, as well as the remnants of numerous exploded IEDs.”

“The remnants of at least one of the exploded IEDs at the scene of the shootout indicate that a low-grade explosive had been contained in a pressure cooker. The pressure cooker was of the same brand as the ones used in the Marathon explosions. The explosive also contained metallic BBs contained within an adhesive material as well as green-colored hobby fuse. The intact low-grade explosive device found in the abandoned car was in a plastic container and wrapped with green-colored hobby fuse.”

“On April 21, 2013, the FBI searched DZHOKHAR TSARNAEV’s dormitory room at 7341 Pine Dale Hall at the University of Massachusetts at Dartmouth, pursuant to a search warrant. The FBI seized from his room, among other things, a large pyrotechnic, a black jacket and a white hat of the same general  appearance as those worn by Bomber Two at the Boston Marathon on April 15, 2013, and BBs.”

“Based on the foregoing, there is probable cause to believe that on or about April 15, 2013, DZHOKHAR TSARNAEV violated 18 U.S.C. $5 2332a (using and conspiring to use a weapon of mass destruction, resulting in death) and 844(i) (malicious destruction of property by means of an explosive devicc, resulting in death). Accordingly, I respectfully request that the Court issue a complaint charging DZHOKHAR TSARNAEV with those crimes. Special Agent Federal Bureau of Investigation”