'etoa WW 1 Case Document 1779 Filed 11/13/19 Page 1 of 27 UNITED STATES DISTRICT COURT ms'rmcr OF MASSACHUSETTS In the matter of the Search of 1999 my Honda CR-V, .. bearing Massachusetts license plate number 3161289 i 3 The United States Attorney hereby reapect?tliy moves the Court to seal the search warrant, supporting a?davit, this motion and all related documents (except for a copy of the warrantto be served at the location to be searched), until further onierof this Court. As grounds for this motion, the government states that public disolosuae of those materials might jeopardize the ongoing investigation of this case, as well as the govermnent?s ability to effectuate the search without intetference or the destruction of property sought by this warrant. Respect?ally submitted, Date: June 3, 2013 .- o. .. SAdd.17 Case Document 1779 Filed 11/13/19 Page 2 of 27, AO {0?chth UNITED- STATES DISTRICT COURT- -- - for the District ofMessechneetts in the Matter of the Search of (Br-i describe the proper-aria be searched . arr? rl?rrfreperoonbymandor?me) Came. - my- qum?? 1999 grey Honda OR-V, bearing Massachusetts license plate number 318589 APPLICATION FOR A SEARCH WARRANT i. a federal law enforcement of?cer or an attorney for the government, request a search warrant and state under penalty ofpenury that i love reason to believe that on the following person or property Warm? tremor-dual!? (In prepay In its marched autism it: location): 1999 gray Honda CR-V, bearing Massachusetts license plate number 316839. as described in AttachmentA located in the District ot? Massachusetts there is new concealed ?damn!? person or describe the (2:1:pr ?hero: oevldence. fruits and lnetrurnentailties of violations of 18 U.S.C. 51951 (Robbery Affecting interstate Commerce). 18 U.S.C. ?1519 (Obstruction of Justice). 18 0.8.0. ?924(o) (Use oi a Firearm during a crime 01 violence). 18 U.S.C. ?1001 (Providing False Material Information). and 371 (conspiracy to Commit Offenses). as desalted in Attachment The basis for the search under Fed. R. Crim. P. 410:) is (duct one armors): evidence of a crime; doontrebend, traits of crime. or other items illegally possessed; of property designed for use, Intended for use. cursed in committing a crime; 0 a person to be arrested or a person who is unlaw?rliy restrained. The search is related to a violation of: Code Section 0,0?ense Description 18 use ??1951, 1519. 924 Robbery Affecting Interstate Commerce. Obstruction oi Justice. (0) 1001. 371 Use of a Firearm during a crime of violence. Providing False Material Information Conspiracy to Commit Olfenses l?he ?puma? '3 hm" ?n mm See attached Af?davit of Special Agent Steven A. Kimball of Continued 5.. the attached sheet. Cl Delayed notice of days (give exact ending date if more than 30 days: under 18 U.S.C. 3103a, the basis is set forth on the attached sheet. is requested Sworn to before me and signed in my presence. Dale: "City and stole: Printed name and title DT-0000573 Case Document 1779 Filed 11/13/19 Page 3 of 27 AFFIDAVIT OF SPECIAL AGENT being duly swom, depose and state: 3. I am currently pattioipating in the investigation of the two explosions that occurred on April 15, 2013 in Boston during the Boston Marathon and a subsequent curjneking and shootout that occurred on April 18?19, 2013 in Cambridge and Watertown, Massachusetts. i believe that the same individuals, 'l?amerlan Tsarnacv (?'I'nmorlan?) and his brother Dzhokhar Tsurnaev (?Dzholdiar?), were involved in the Marathon bombing, the 'carjaclcing, and the shootout. This af?davit is submitted in support of a second search warrant for a 1999 gray Honda CR-V, bearing Massachusetts license plate number 3161389 (?the Target Vehicle?), as Page I SAdd.19 Case Document 1779 Filed 11/13/19 Page 4 of 27 more particularly described in Attachment A hereto, which is.incorporatcd herein by referencet'i As set forth below, the Target Vehicle is the vehicle of Tamerlan and Dzhokhar. This requested second search warrant seeks a limited search of the Target Vehicle to seize blood, DNA, trace evidence and other items, all of which are more fully described below, that may have been transferred to or from the vehicle by Tamerlan or Ibragim Todashev (?Todashev?), one of his associates, after a triple murder that occurred in Waltham, Massachusetts in September 2011. I have probable cause to believe these additional items may be evidence of the commission of criminal offenses, in violation of 18 U.S.C. 1951 (Robbery Affecting Interstate Commerce), 924(0) (Use of a Firearm During a Crime of Violence), 1519 (Obstruction of Justice) and 371 (Conspiracy to Commit Offenses). SAdd.20 Case Document 1779 Filed 11/13/19 Page 5 of 27 Case Document 1779 Filed 11/13/19 Page 6 of 27 Case Document 1779 Filed 11/13/19 Page 7 of 27 Case Document 1779 Filed 11/13/19 Page 8 of 27 Case Document 1779 Filed 11/13/19 Page 9 of 27 Case Document 1779 Filed 11/13/19 Page 10 of 27 Case Document 1779 Filed 11/13/19 Page 11 of 27 Case Document 1779 Filed 11/13/19 Page 12 of 27 Case Document 1779 Filed 11/13/19 Page 13 of 27 Case Document 1779 Filed 11/13/19 Page 14 of 27 Case Document 1779 Filed 11/13/19 Page 15 of 27 if. 20]] Walrham Murders 33. On the evening of September 11. 201 1, three young men were killed at a residence at 12 Harding Avenue, Waltham, Massachusetts. One of the victims, Brendan Mess, Russell described as Tamerlan's very close ?iend. The murders were particularly grisly: the victims were bound, beaten, and had their throats out. In addition, the victims were covered with mam 39. On May 21, 2013, as referenced above, law enforcement agents interviewed Todashev. Todashev canfessed that he and Tamer-tan participated in the Waltham murders. He said that he and Tamerlan had agreed initially just to rob the victims, whom they knew to be drug dealers who sold marijuana. 'l?odashev said that he and Tamerlan took several thousand dollars from the residence and split the money. Todeshcv said that Tamerlan had a gun, which he brandished to enter the residence. Tamerlan decided that they should eliminate any witnesses to the crime, and then Todashev and Tamerlan bound the victims, who were ultimately murdered. Todashev went on to say that a?er the murders, Tamerlan and Todashev tried to clean the crime scene in order to remove traces of their ?ngerprints and other identifying details. . ?dd-3? Case Document 1779 Filed 11/13/19 Page 16 of 27 I Todeshcv said that they spent over an hour cleaning the scene. Todashev said that Tamerlan had picked Todashev up in the Target Vehicle and they traveled to the scene of the Waltham murders together. After the robbery and murder, they left the scene in the Target Vehicle. SAdd.32 Case Document 1779 Filed 11/13/19 Page 17 of 27 Case Document 1779 Filed 11/13/19 Page 18 of 27 Case Document 1779 Filed 11/13/19 Page 19 of 27 Case Document 1779 Filed 11/13/19 Page 20 of 27 The location to be searched is a 1999 gray Honda CR-V, bearing Massachusetts license plate number 316ES9. The vehicle has been previously searched by the FBI, and was seized from across the street from 410 Norfolk Street, Aparhtent 3, Cambridge, Massachusetts, the residence of Tamerlan and Dzhokhm' Tsamaev. Case Document 1779 Filed 11/13/19 Page 21 of 27 ATTACHMENT TEMS TO BE SEIZED Evidence, in whatever form inside or on the Target Vehicle, related to violations of 18 U.S.C. ?1951 (Robbery Affecting Interstate Commerce), 18 U.S.C. ?1519 (Obstruction of Justice), 18 U.S.C. ?924(c) (Use of a Firearm during a crime of violence), 18 U.S.C. ?1001 (Providing False Material information), and 371 (Conspiracy to Commit Offenses), in connection with the robbery and triple murder in Waltham, Massachusetts in 2011, including: 1. Blood, tissue, DNA, hair and bodily ?uids samples; 2. Fibers and portions of surfaces containing ?bers; 3. Swatches of carpet, upholstery, fabric, wood, plastic metal and any other surface or under~surface anywhere on or in the vehicle; 4. Any absorbent substrate or materials; 5. Property, records, or information related to the September 2011 Waltham triple homicide; 6. Property, records, or information related to the state of mind and/or motive of Tamerlan Tsamaev or Ibragim.Todashev 0r others to undertake the September 201] Waltham' triple homicide; 7. Property, records, or other information related to contacts between Ibragim Todashev and Tamerlan Tsarnaev or Dzhokhar Tsarnaev or other co-conspirators; 8. Property, records, or other information, related to travel of the vehicle or Tamerlan Tsarnaev or Ibragim Todashcv in September 20] 9. Property, records, or information related to any bank records, checks, credit card bills, account information, and other ?nancial records; 12. Chemical and physical testing of the vehicle. SAdd-37 Case Document 1779 Filed 11/13/19 Page 22 of 27 13. Evidence of property, records, or information related to the victims of the September 201 Waltham tripie homicide, Brendan Mess, Erik Weissmen, or Raphael Token, or related to Tamcrlan or Dzhokhm', or am as yet-unidenti?ed co?oonspirator; 14. Property, records, or other information related to martial arts, combat, or ?ghting; 16. Evidence not previously seized, evidencing a relationship between the 201 Waltham tn'ple homicide and the 2013 Boston Marathon bombings. Case Document 1779 Filed 11/13/19 Page 23 of 27 A0 93 (Rev. 1209) Searchud Wm ?4 m- - UNITED STATES DISTRICT COURT for the District of Massachusetts in the Matter ofthe Search of (Brie?y to be searched CaseNo. (3 . 3-3351" M86 1999 grey Honda CR-V. bearing licence plate number erases SEARCH AND SEIZURE WARRANT To: Any authorized law enforcement of?cer An application by a federal law enforcement officer or an attorney for the government retreats the of the following person or property located in the District of Mg?gmw tire person or Who to be roommates its location): 1999 grey Honda CR-V. bearing Massachusetts license plate number 818589. 88 described in AttechmentA The person or property to be searched. described above. is believed to conceal (Mamas- ?amenco. ??2?ng instrumentatiilee of violations of 18 U.S. 0. 51951 (Robbery Affecting interstate Commerce). 18 U. 8.0. 51519 (Obstruction of Justice). 18 U. 8. c. 924(0) (Use Pheerm during a crime of violence). 18 U. 3.0. ?1001 (Providing False Material information). end 371 (Conspiracy to Commit Offenses). as described in Attachment I find that the amdavlt(s). or any recorded testimony. establish probable came to search and seize the person o?r YOU ARE COMMANDED to execute this warrant on or before June 11 2 1 (not (a weed I4 date) 21' in the daytime 6:any time in the day or night as 1 ?nd reasonable cause has been established. Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the person from whom. or from whose premises. the property was taken, or leave the copy and receipt at the place where the property was taken. The officer executing this warrant. or an otticer present during the execution of the warrant, must prepare an inventory as required by law and return this warrant and inventory to United States Magistrate Judge Marianne B. Bowler time) i find that immediate noti?cation may have on adverse result listed in -I I xcept for delay oftriei), and authorize the officer executing this Warrant to delay notice tot I Vila property, will be searched orseized (checumeppeprtaeoax) for daysoroma. 11135,?. p35,. ?11? C) until. litefeclsiustiiying. atcrispegi?cdet . 1 I . .rg rr?2,m? ray'?h of, Date and time issued: 0810312013 0:00 egg ?25 .HS ii?t, . . .?Ei 1m"? - We: 1. . '111 r" I City and state: Boston. Megwchueelte HonJAario Mg} S.Megietr_ete .m_dge Madmuondtitle SAdd.39 DT-0000594 -- Case Document 1779 Filed 11/13/19 Page 24 of 27 no 93 (Rev. Wm {PageZ} Return Case No.: Date and time warrant matted: Copy ofwatrant and inventory te? wtth: Inventant made in the presence of: Inventam of the property taken and name of any pemau?e) seized: Date: Certt catto I declare under penalty ofpetyury that this inventory is correct and was returned along with the warrant to the destgnatedjudge. Exeeuttng amm- stamtm Mandamus SAdd.40 DT-0000595 Case Document 1779 Filed 11/13/19 Page 25 of 27 The location to be searched is a 1999 gray Honda CR-V, bearing Massachusetts license plate number 3163189. The vehicle has been previously searched by the FBI, and was seized from across the street from 410 Norfolk Street, Apartment 3, Cambridge, Massachusetts, the residence of?I?amerlan and Dzhokhar Tsameev. DT-0000596 Case Document 1779 Filed 11/13/19 Page 26 of 27 ATTACHMENT ITEMS TO BE SEIZED Evidence, in whatever form inside or on the Target Vehicle, related to violations of 18 U.S.C. ?l951 (Robbery Affecting Interstate Commerce), 18 U.S.C. ?1519 (Obstruction of. Justice), 18 U.S.C. 924(c) (Use of a Firearm during a crime of violence), 18 U.S.C. ?lOOi (Providing False Material Information), and 371 (Conspiracy to Commit Offenses), in connection with the robbery and triple murder in Waltham, Massachusetts in 201 1, including: 1. Blood, tissue, DNA, hair and bodily ?uids samples; 2. Fibers and portions of surfaces containing ?bers; 3. Swatches of carpet, upholstery, fabric, wood, plastic metal and any other surface or under-surface anywhere on or in the vehicle; 4. Any absorbent substrate or materials; 5. Pr0perty, records, or information related to the September 2011 Waltham triple homicide; 6. Property, records, or information related to the state of mind andfor motive of Tamerlan T-sarnaev, or Ibragim Todasheyr or others to undertake the September 2011 Waltham triple homicide; 7. Property, records, or other information related to contacts between Ibragim Todashev and Tamerlan _Tsamaev or Dzhokhar Tsarnaev or other co~conspirators; 8. Property, records, or other information, related to travel of the vehicle or Tamerlan Tsamaev or lbragim Todashev in September 201 l; 9. Property, records, or information related to any bank records, checks, credit card bills, account information, and other ?nancial records; 12. Chemical and physical testing of the vehicle. SAW-42 Case Document 1779 Filed 11/13/19 Page 27 of 27 l3. Evidence of propeity, records, or information related to the-victims of the September 201 1 Waltham triple homicide, Brendan Mess, Erik Weissman, or Raphael Teken, or related to Tamerlan or Dzhokliar, or an as yet-unidenti?ed co-censpirator; 14. Property, records, or other information related to martial arts, combat, or ?ghting; 16. Evidence not previously seized, evidencing a relationship between the 2011 Waltham triple homicide and the 2013 Boston Marathon bombings. SAdd.43 DT-0000598