The Complaint by the US Federal Government .
I am a Special Agent with the Federal Bureau of Investigation ("FBI") and have
been so employed since 2009. I am currently assigned to one of the Boston Field Office's
Counter-terrorism Squads. Among other things, I am responsible for conducting national
security investigations of potential violations of federal criminal laws as a member of the Joint
Terrorism Task Force ("JTTF"). During my tenure as an agent, I have participated in numerous
national security investigations. I have received extensive training and experience in the conduct
of national security investigations, and those matters involving domestic and international
terrorism.
2. During my employment with the FBI, I have conducted and participated in many
investigations involving violations of United States laws relating to the provision of material
support to terrorism. I have participated in the execution of numerous federal search and arrest
warrants in such investigations. I have had extensive training in many methods used to commit
acts 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 on
April 15, 2013, resulting in death. More specifically, 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 used in interstate and foreign commerce and in an
activity 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 10interstate and foreign commerce (including, but not limited to, the Boston Marathon, private
businesses in Eastern Massachusetts, and the City of Boston itself), resulting in death, in violation...
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