Read the Criminal Complaint Filed Against Dzhokhar Tsarnaev

It's a fascinating account of his crimes.


Amid a lot of confusion about the exact events on Monday, Thursday, and Friday, the criminal complaint, written by FBI Special Agent Daniel R. Genck, fills in some unknowns and gives a fascinating official record of the way the government believes Tsarnaev’s crimes unfolded.

Dzhokhar Tsarnaev was charged in front of a magistrate judge from his hospital bed Monday with use of a weapon of mass destruction, resulting in death, as well as malicious destruction of property, resulting in death. Particularly interesting in the criminal complaint is the account of the unidentified man who went on a half-hour ride with the Tsarnaev brothers after they stole his car and before they left him at a gas station on Memorial Drive in Cambridge. According to the complaint, “the victim,” who has yet to be named publicly, was sitting in his car in Cambridge when a man tapped on the passenger side window. The victim rolled down the window, allowing the man to unlock the door, climb in, and point a gun at him:

The man pointed a firearm at the Victim and stated, “Did you hear about the Boston explosi0n?” and “I did that.” The man removed the magazine from his gun and showed the victim that it had a bullet in it, and then re-inserted the magazine. The man then stated, “I am serious.”

The guy with the gun then made the victim drive to another location, where they picked up a second man and made the victim give up the driver’s seat to the first man:

The second man entered the Victim’s vehicle and sat in the rear passenger seat. The man with the gun and the second man spoke to each other in a foreign language.

While they were driving, the man with the gun demanded money from the victim, who gave the man 45 dollars. One of the men compelled the victim to hand over his ATM card and password. They then drove to an ATM machine and attempted to withdraw money from the victim’s account. The two men and the victim then drove to a gas station/convenience store in the vicinity of 816 Memorial Drive, Cambridge. The two men got out of the car, at which point the victim managed to escape.

Also interesting is the clearer way the affidavit explains how footage of Dzhokhar in the moments after the first bomb exploded, taken at the site of the Boston Marathon, incriminated him. We already knew something about this because on NBC’s Meet the Press, Gov. Deval Patrick said, “It does seem to be pretty clear that this suspect took the backpack off, put it down, did not react when the first explosion went off and then moved away from the backpack in time for the second explosion. It’s pretty clear about his involvement and pretty chilling, frankly.” The affidavit echoes that:

Approximately 30 seconds before the first explosion, he lifts his phone to his ear as if he is speaking on his cell phone, and keeps it there for approximately 8 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 [Dzhokhar], 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.

Chilling indeed. You can read the rest of the criminal complaint here.