UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS
The Grand Jury charges that:
At all times relevant to this Indictment, unless otherwise indicated:
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 117th 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 2:49p.m., while the Marathon was still underway, two improvised explosive devices (“IEDs”) 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.