FULL TEXT Tsarnaev Criminal Complaint

April 22, 2013

USA v. Dzhokhar Tsarnaev (DMA, 13-2106, April 21, 2013)

Read the entire federal criminal complaint involving the recent Boston Marathon terrorism attack, alleging violations of:
  • 18 U.S.C. s 2332a(a) -- Use of a Weapon of Mass Destruction
  • 18 U.S.C. s 844(i) -- Malicious Destruction of Property Resulting in Death

14. The Forum Restaurant video shows that Bomber Two remained in the same spot for approximately four minutes, occasionally looking at his cell phone and once appearing to take a picture with it. At some point he appears to look at his phone, which is held at approximately waist level, and may be manipulating the phone. Approximately 30 seconds before the first explosion, he lifts his phone to his ear as ifhe is speaking on his cell phone, and keeps it there for approximately 18 seconds. A few seconds after 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. He glances to the east and then calmly but rapidly begins moving to the west, away from the direction of the finish line. He walks away without his knapsack, having left it on the ground where he had been standing. Approximately 10 seconds later, an explosion occurs in the location where Bomber Two had placed his knapsack.