Case 1:13-cr-10200-GAO Document 980 Filed 01/22/15 Page 1 of 2

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
UNITED STATES OF AMERICA
v.
DZHOKHAR TSARNAEV

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CRIMINAL NO. 13-10200-GAO

THIRD MOTION FOR CHANGE OF VENUE
Defendant, Dzhokhar Tsarnaev, by and through counsel, and pursuant to Fed. R. Crim. P.
21, and the Fifth, Sixth, and Eighth Amendments to the United States Constitution, hereby
moves that the Court cease jury voir dire in Boston, order a change of venue, and move his trial
outside the District of Massachusetts.
Data from the 1,373 questionnaires completed by potential jurors who were summoned
require fresh evaluation of all the circumstances and criteria that inform a venue determination.
Great local prejudice will prevent a fair trial by an impartial jury in violation of Mr. Tsarnaev’s
constitutional rights to due process of law and a fair trial.
In support of this motion, the defense submits an accompanying Memorandum and
incorporates by reference the jury questionnaires and record of voir dire to date. The defense
also incorporates by reference the substantive filings (with appended exhibits) made in
connection with the second venue motion [DE 686, 696, 774, 779, 780, 852] and the first venue
motion [DE 376, 461], as well as filings concerning “leaks” of non-public information by law
enforcement. [DE 280, 336, 438, 616, 680.]
The Court should hold a hearing on this motion, order a change of venue, and determine
the appropriate district of transfer.

 Case 1:13-cr-10200-GAO Document 980 Filed 01/22/15 Page 2 of 2

Respectfully submitted,
DZHOKHAR TSARNAEV
By his attorneys
/s/ Timothy G. Watkins
Judy Clarke, Esq. (CA Bar # 76071)
CLARKE & RICE, APC
1010 Second Avenue, Suite 1800
San Diego, CA 92101
(619) 308-8484
JUDYCLARKE@JCSRLAW.NET
David I. Bruck, Esq.
220 Sydney Lewis Hall
Lexington, VA 24450
(540) 460-8188
BRUCKD@WLU.EDU
Miriam Conrad, Esq. (BBO # 550223)
Timothy Watkins, Esq. (BBO # 567992)
William Fick, Esq. (BBO # 650562)
FEDERAL PUBLIC DEFENDER OFFICE
51 Sleeper Street, 5th Floor
(617) 223-8061
MIRIAM_CONRAD@FD.ORG
TIMOTHY_WATKINS@FD.ORG
WILLIAM_FICK@FD.ORG
Certificate of Service
I hereby certify that this document filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing (NEF)
and paper copies will be sent to those indicated as non-registered participants on January 22,
2015.
/s/ Timothy G. Watkins

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