STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS UNITED STATES OF AMERICA Crim. No. Violations: 18 U.S.C. 2332a Use of a Weapon of Mass Destruction and Conspiracy; 18 U.S.C. 2332f -- Bombing of a Place of Public Use and Conspiracy; 18 U.S.C. 844(i) Malicious Destruction of Property and Conspiracy; l8 U.S.C. 924(c) - Use of a Firearm During and in Relation to a DZHOKHAR A. TSARNAEV, Crime of Violence; a/k/a "Jahar Tsarni," Defendant. 18 U.S.C. 924(j) -- Use of a Firearm During and in Relation to a Crime of Violence Causing Death; 18 U.S.C. 2119(2) -- Carjacking Resulting in Serious Bodily Injury; 18 U.S.C. 1951 -- Interference With Commerce by Threats or Violence; 18 U.S.C. 2 Aiding and Abetting; 18 U.S.C. 98l(a)(l)(G) -- Forfeiture. The Grand Jury charges that: At all times relevant to this Indictment, unless otherwise indicated: GENERAL ALLEGATIONS 1. DZHOKHAR A. TSARNAEV was a naturalized United States citizen residing in Cambridge, Massachusetts. 2. Tamerlan Tsarnaev was a Russian citizen residing in Cambridge, Massachusetts. 3. The 117" running of the Boston Marathon ("the Marathon") took place on April 15, 2013. The Marathon is an annual race that attracts thousands of runners from all over the United States and the world. It is normally held on Patriots' Day, a Massachusetts holiday that celebrates American patriotism and independence. Every year, friends and family members of the runners, and tens of thousands of others, line the race course to cheer on the runners and enjoy the race. 4. Many runners and their family members travel to the Boston, Massachusetts area from other states and countries and stay at local area hotels, eat at local area restaurants, and shop at local area businesses. 5. The final stretch of the Boston Marathon runs eastward along the center of Boylston Street in Boston from Hereford Street to the finish line, which is located between Exeter and Dartmouth Streets. Low metal barriers line both edges of the street and separate the spectators from the runners. Many businesses line the streets of the Marathon route. In the area near the finish line, businesses are located on both sides of Boylston Street, including restaurants, a department store, a hotel, and various retail stores. 6. On April 15, 2013, at approximately 2:49 while the Marathon was still underway, two improvised explosive devices exploded on the north side of Boylston Street along the Marathon's final stretch. The first exploded in front of Marathon Sports, located at 671 Boylston Street, and the second exploded in front of the Forum restaurant, located at 755 Boylston Street. The IEDs were placed near the metal barriers where hundreds of spectators were watching runners approach the finish line. Each explosion killed at least one person, maimed, burned, and wounded scores of others, and damaged public and private property, including property owned by people and businesses in the locations where the explosions occurred. 7. The IEDs that exploded at the Marathon were constructed from pressure cookers, low explosive powder, shrapnel, adhesive, and other materials. They were concealed inside black backpacks. 8. Inspire magazine is an English language online publication of al~Qaeda in the Arabian Peninsula. Volume One of Inspire magazine, which is dated summer 2010, contains detailed instructions for constructing IEDS using pressure cookers, explosive powder from fireworks, shrapnel, adhesive, and other materials. IEDs constructed in this manner are designed to shred flesh, shatter bone, and cause extreme pain and suffering, as well as death. 9. On April 18, 2013, at approximately 5:00 the Federal Bureau of Investigation published on its web site photographs of Tamerlan Tsarnaev and DZHOKHAR A. TSARNAEV, identifying them as the two individuals suspected of detonating IEDs at the Marathon. (It did not identify them by name because law enforcement had not yet learned their names). These photographs were widely disseminated on television and elsewhere. 10. On April 19, 2013, while DZHOKHAR A. TSARNAEV was hiding from police in a drydocked boat in a Watertown, Massachusetts backyard, he wrote a message on an inside wall and beams of the boat that said (among other things): "The U.S. Government is killing our innocent civilians;" can't stand to see such evil go unpunished;" "We Muslims are one body, you hurt one you hurt us all;" "Now I don't like killing innocent people it is forbidden in Islam but due to said [unintelligible] it is allowed;" and "Stop killing our innocent people and we will stop." COUNT ONE Conspiracy to Use A Weapon Of Mass Destruction Resulting in Death (18 U.S.C. 2332a(a)(2)) 11. The Grand Jury realleges and incorporates by reference paragraphs 1 through 10 and further charges that: 12. From at least in or about February 2013, up to and including on or about April 19, 2013, in the District of Massachusetts and elsewhere, the defendant, DZHOKHAR A. TSARNAEV, knowingly conspired with Tamerlan Tsarnaev to use a weapon of mass destruction, namely, a destructive device as defined by Title 18, United States Code, Section 921, without lawful authority, against a person and property in the United States, and (1) such property was used in interstate and oreigfi commerce and in an activity that affects interstate and foreign commerce; (2) the mail and a facility of interstate and foreign commerce were used in furtherance of the offense; (3) a perpetrator traveled in and caused another to travel in interstate and foreign commerce in furtherance of the offense; and (4) the offense, and the results of the offense, affected interstate and foreign commerce. 13. The conspiracy resulted in at least one person's death; specifically, it resulted in the deaths of Marie Campbell, Officer Sean Collier, Lingzi Lu, and Martin Richard. OVERT ACTS 14. In furtherance of the conspiracy, and to effect its illegal object, DZHOKHAR A. TSARNAEV, the defendant, and Tamerlan Tsarnaev committed the following overt acts, among others, in the District of Massachusetts and elsewhere: 15. At a time unknown to the Grand Jury, but before on or about April 15, 2013, DZHOKHAR A. TSARNAEV downloaded to his computer a digital copy of a book entitled, "The Slicing Sword, Against the One Who Forms Allegiances With the Disbelievers and Takes Them as Supporters Instead of Allah, His Messenger and The Believers." The version that DZHOKHAR A. TSARNAEV downloaded had a foreword by Anwar Al--Awlaki, who was a well~known al<