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
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 interstate 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 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 affecting interstate 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, my training and experience, my review of relevant evidence, and information supplied to me by other law enforcement officers. It does not include each and every fact known to me about the investigation, but rather only those facts that I believe are sufficient to establish the requisite probable cause.
FACTS AND CIRCUMSTANCES
A.
5. The Boston Marathon Explosions
The Boston Marathon is an annual race that attracts runners from all over the United States and the world. According to the Boston Athletic Association, which administers the Marathon, over 23,000 runners participated in this year's race.
The Marathon has a substantial impact on interstate and foreign commerce. For example, based on publicly available information, I believe that the runners and their families -- including those who travel to the Boston area from other states and countries -- typically spend tens of millions of dollars each year at local area hotels, restaurants and shops, in the days before, during, and after the Marathon. In addition, a number of the restaurants and stores in the area near the finish line have special events for spectators.
I, Daniel R. Genck, being duly sworn, depose and state:
1. 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 interstate 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 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 affecting interstate 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, my training and experience, my review of relevant evidence, and information supplied to me by other law enforcement officers. It does not include each and every fact known to me about the investigation, but rather only those facts that I believe are sufficient to establish the requisite probable cause.
FACTS AND CIRCUMSTANCES
A.
5. The Boston Marathon Explosions
The Boston Marathon is an annual race that attracts runners from all over the United States and the world. According to the Boston Athletic Association, which administers the Marathon, over 23,000 runners participated in this year's race.
The Marathon has a substantial impact on interstate and foreign commerce. For example, based on publicly available information, I believe that the runners and their families -- including those who travel to the Boston area from other states and countries -- typically spend tens of millions of dollars each year at local area hotels, restaurants and shops, in the days before, during, and after the Marathon. In addition, a number of the restaurants and stores in the area near the finish line have special events for spectators.
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