top of page

A Civil RICO Lawsuit



Civil RICO suit     1:19-cv-01208 JD


Jury trial demanded.

I. Introduction

1. On April 15, 2013 two bombs went off during the Boston Marathon race. This crime was blamed on Tamerlan Tsarnaev and his younger brother, Dzhokhar "Jahar" Tsarnaev (hereinafter Jahar). Tamerlan was killed four days later. Jahar was wrongly convicted of the bombing and is currently on Death Row in Florence, Colorado federal prison, where he is not allowed to send or receive mail.

2. The FBI submitted a video of the brothers walking near the Marathon. It is clear that Jahar is carrying a grey backpack, in that photo, minutes before the bombing, yet the FBI presented a bomb- ripped backpack, of black color, as proof that Jahar did it.

3. A friend of the Tsarnaevs, Khairullozhon Matanov, was harassed by the FBI for making false statements, and was unfairly convicted and later deported. This was probably because he had information that would exculpate the convict. Another friend, Ibragim Todashev, who could have been a witness in the Tsarnaev trial, was killed by the FBI in his home in Florida, in May 2013, as is admitted by the FBI.

II. Jurisdiction and Venue

4. This is the proper court because it is a federal RICO case under 18 USC 1961, and one of the predicate crimes is obstruction of justice, per 18 USC 1503.

5. The New Hampshire venue is proper because the plaintiff lives in New Hampshire and also because it is considered problematic to file the case in Boston where emotions run high on the subject of the Marathon bombing.

III. Parties

6. The plaintiff is Mary Maxwell, widow, age 72, who works fulltime as a law researcher and writer. She has a PhD in Politics and a Law Degree from the University of Adelaide, Australia.

7. She suffered stress and financial loss as a result of the Tsarnaev trial that occurred in April 2015, and devoted much of her work time in 2016 and 2017 to offering correctives.

IV. Statute of Limitations

8. The statute of limitations for federal civil RICO is four years. Plaintiff's injury and losses occurred from 2016 through 2019.

9. The enterprise to be identified in this case has existed from at least 2001 until now.

V. The Racketeering Enterprise

10. A racket, within the intent of the RICO Act, means organized crime. An example of this is a child-trafficking racket in which top members of schools, churches, adoption agencies, and hospitals start to do the opposite of what one would expect them to do -- protect minors from harm. They network secretly to achieve their criminal goals.

11. The racket related to the Boston Marathon bombing has to do with carrying out a psychological operation (a "psy-op") on the people of Boston via a terrorist incident.

12. A terrorist event may be used for three things -- to cause social fear, as a way for people to be rendered weak (and thus not challenge the power-holders); to set the stage for invasion of an enemy nation for having done the deed (in this case setting off two bombs on Boylston St, Boston, helps justify United States' crackdown on terrorists such as ISIS in the Middle East); and to pave the way for legislation that supports the security state, wherein all neighbors gradually become distrustful of one another.

13. The media are essential to this enterprise of psy-ops, as they are able to purvey the racketeers' narrative to everyone who watches television or reads a newspaper.

14. Police and lawyers, working within the enterprise, have the means of making sure the wrong person gets blamed for a so-called terrorist incident. Police can intimidate and/or arrest persons who create any obstacles to the enterprise's plans. Within a court case there may be falsified evidence (the production of which is a known skill of the FBI), tampering with witnesses or jurors, and other violations of due process.

15. Of the 11 Defendants is this case, the racketeers of the enterprise, only four are outside of the categories of media, law enforcement, and the legal profession, namely the Director of the federal Bureau of Prisons (BOP), MIT, Dr Wolfe, and John Doe.

16. The Director of BOP participates in the enterprise by being the custodian of Jahar Tsarnaev, keeping him incommunicado.

17. MIT, the site-owner of the place where Sean Collier was murdered, is included for having contributed a misleading video surveillance that was used against Tsarnaev.

18. Dr Wolfe, chief of emergency, Beth Israel Deaconess Hospital, is named for giving an eyewitness description of Tamerlan's last moments of life that can't possibly be accurate.

19. A RICO case must show pecuniary gain. The Marathon bombing may have enriched the media, the security industry, and war-makers. But tricking citizens and their elected representatives gives an indirect gain to all members of the wealthy, powerful class.

20. John Doe, "high officer of the ruling cabal," is listed speculatively. To prove a RICO enterprise, one must show collaboration of criminal parties. But there probably exists a set of society's masters, imagined as "the cabal." Their man, "John Doe," may have worked behind the scenes, dictating the agenda to media, cops, lawyers, and others.

21. A theme of Jahar's trial is that he was motivated by Islamic ideology. This helped galvanize Americans against Muslims, with President Trump saying they should be barred from entering the United States, even if they had permanent residence status.

VI. RICO Requirements of Continuity and Relationship

22. A RICO suit must show continuity of the crimes involved. There had to be continuity at least from, say, January 2013 to plan the bombing, then publicize the false story, until the present time, in late 2019, when Jahar is holding his appeal in the First Circuit.

23. A RICO case must also show relationship. All eleven Defendants may have colluded. The doctor at Beth Israel Deaconess had to misreport Tamerlan's death, to suit the story of the Watertown shootout; the Director of the BOP keeps under wraps anything that Jahar might want to share with the public; MIT had to know what the enterprise required when its man, Matthew Isgur, was selecting surveillance footage, and so forth.

VII. Two or More Predicate Acts

24. For RICO, a minimum of two pertinent crimes, known as predicate acts, must have been committed. Plaintiff names the murder of Tamerlan as one predicate act, and the Public Defenders' refusal to let the jury know that Jahar's plea was Not Guilty as the other predicate act, an obstruction of justice. A spectacular crime allegedly occurred in Russia.

Maret Tsarnaeva says in her affidavit: "Dzhokhar's parents expressed willingness to engage independent counsel.... Mr Fick replied that government agents would obstruct independent counsel." And the Public Defenders shockingly warned "that, if their advice were not followed, Dzhokhar’s life in custody near Boston would be more difficult."

VIII. Injury to Business and or Property

25. Plaintiff has suffered distress and monetary loss resulting from the bombing of the 2013 Boston Marathon. For example, she sent a petition for a Writ of Error Coram Nobis to the District Court in 2016 and a follow-up on that to the Massachusetts legislature a year letter. The price of postage (sent from Australia) was approximately $20.

26. Plaintiff also lost valuable time from her business interests, in responding to the scandalous trial -- time she could have spent marketing some of her books and plays.

27. To produce a book on the matter, entitled The Soul of Boston and the Marathon Bombing, Plaintiff had to pay $1600 for printing it and spend $240 on postage to distribute copies. She also had major travel costs, for example going to Sydney to film the Youtube video "To Massachusetts Governor, Please Arrest the FBI."

IX. Facts and Allegations

28. The Marathon bombing was presented to the public as a terrorist incident, similar to many others in the world. Typically, these incidents are "false flag operations," blamed on the chosen enemy. A "patsy" is assigned to be accused of the crime.

29. Media immediately built up the excitement in Boston and emphasized both the personal tragedies involved and the human- goodness aspects of the day's events. This is a well-developed tactic; psychologists know that raising any emotion, sad or happy, will deepen one's impression of an experience. The media arranged to spotlight a Marathon amputee at a sports match waving the flag, with a slogan for the event: Boston Strong.

30. After the bomb crisis was over, on Monday, April 15, 2013, no news came out as to who did it. Then, on Thursday at 5:00pm, FBI leader Richard DesLauriers -- along with Senator Elizabeth Warren, Governor Deval Patrick, Boston Police Commissioner Ed Davis, and many others -- held a press conference to announce that they had picked out two men, Suspects One and Two, that were recorded on a Boylston St surveillance camera.

31. The FBI said it did not know the Suspects' names, but that is a lie. The FBI had been in contact with Tamerlan for years prior to the Marathon. He was probably an FBI informant. Many immigrants are asked to be informants and are afraid to refuse.

32. DesLauriers then made a statement that cannot possibly have an innocent interpretation. He told the TV audience that the photos he had chosen are the only ones "the public should view to assist us. Other photos should not be deemed credible."

33. In other words, if you were holding in your cell phone a perfect shot of some other person planting the bomb, you should realize it is not to be given credence, even by you!

34. The brothers probably did not see this TV spot. But the psy-op story has them starting to act like fugitives. Allegedly, around 11:00pm, Tamerlan carjacked a parked SUV (sports utility vehicle), and its driver, despite his having his own Honda with him.

35. Carjackings are diagnostic of scripted events, as in the Brian Nichols case in Atlanta or the Martin Bryant case in Tasmania. Real fugitives do not add to their woes by taking a hostage who will only be a burden, and a witness, later. The media relayed a comical story in which Tamerlan said to the SUV owner, Dun Meng, that he had just killed a cop at MIT. Has there ever been a man who volunteered to a stranger that he was a cop killer? The Boston Globe expected people to believe that item on the basis of human nature -- a man wants to throw his weight around, to another man, pulling rank.

36. Next, all three persons in the carjacked SUV stopped at an ATM machine so Jahar could steal $800 from Meng's account. For purposes of the script, this beefed up the story that the brothers needed cash for their next stop -- Times Square -- to do more bombing. (Meng eventually said there was no discussion about a trip to New York, but the media had creatively carried it.)

37. The bank's photo of Jahar at the ATM machine does not look like Jahar. The carjacking probably did not happen at all, nor did the ATM heist.  

38. Next, they reportedly go to a Shell station for gas. Meng makes his escape and thus, very conveniently, he is able to alert police to the identity of the bombers' SUV and the fact that it can be tracked. Thus the police see the car headed for Watertown. Members of the enterprise would no doubt have made advance plans for a drama in Watertown. 

39. By now it's Friday morning, April 19, 2013, around 12:30am. Something violent occurs on Laurel St, Watertown but most likely it did not include the Tsarnaevs. The Enterprise may have arranged for two guys to start shooting at cops in the dark and even toss an explosive device. At least one cop, Rick Donohue, was seriously wounded. Plaintiff notes that the enterprise put all those lives at risk. Have others also died over this affair?

40. Soon the media spread a story that the younger brother, Jahar (but not saying his name) had tried to escape from the Laurel St shootout in the SUV and in the process ran over his brother. He allegedly sped away, then abandoned the car and was met by Officer St Onge, who did not kill or capture him. A capture would have been awkward for the enterprise, as it would have precluded the important Friday event -- a huge manhunt with military style trucks and soldiers, incredibly, entering homes with guns drawn.

41. Meanwhile, the allegedly run-over man, who isn't Tamerlan, perhaps a "stooge," is still at Laurel Street. (In one variation on this story, he was dragged 40 feet.) Reportedly this man acts aggressively with cops despite his injuries. Sgt John MacLellan was close up and saw this man bleed to death. (He said "unless I'm mind controlled.") MacLellan later figured it was Tamerlan. There hadn't been. any way to identify the participants during the Laurel St shoot-out. The FBI later said they did it by testing the corpse's fingerprints.

42. That unidentified (bled-out) man's corpse was dispatched in an ambulance, yet Dr Wolfe says he supervised "Tamerlan's" final moments in hospital and blood was transfused. In court Wolfe testified: "multiple injuries, probably, we believe, a combination of blast, potentially gunshot wounds." Nothing about run-over wounds or drag marks (road rash). And it is odd to say the wounds were only "potentially" gunshot.

43. The real Tamerlan appeared, as can be seen in two different films, at about 1:05am (around 20 minutes after the run-over man's body was taken by ambulance). The scene is Mt Auburn St. A cop in a phosphorescent yellow jacket has the real Tamerlan pinned to the sidewalk. Tamerlan yells "Podstava" -- Russian for "I've been set up."

44. The brothers had probably come to Watertown on their own, under FBI instructions. A "pal" of Tamerlan's seems to be on the ground with him; maybe he had lured him to the right place. Lawyers did not call that person to court.

45. The Podstava video was reportedly filmed by a Mt Auburn resident named Big Headphones who posted it on Youtube shortly after.

46. This man, the real Tamerlan, may have been stripped naked as a precaution that he could be carrying explosives. He was then escorted into a police car. Anyone can see this on CNN's Youtube video, originally broadcast live as news. CNN man Gabe Ramirez is standing nearby and narrates to the audience that "It may be Suspect 1."

47. Tamerlan's relatives agree that the man pinned down on the sidewalk who yelled "Podstava" is Tamerlan, and the naked man getting into the car is also Tamerlan. It is obvious that the naked Tamerlan has no blood on him and is not making any gestures of pain. He is healthy. This raises the question of how he subsequently died in custody.

48. Five hours later, at 6am, residents of Boston got a robo call telling them to "shelter in place," that is, not to go out. The reason given was that a 19-year old terrorist (Jahar) was on the loose. This is theatre.

49. It made possible a rare scene for Americans: an army-like group rode down the residential streets and forced their way into any homes, even where the homeowner came to the door and assured law enforcement that all was well. Some people were made to stand in their front yard for hours, in Watertown.

50. Excitement was high in Boston, too. Trains and buses were cancelled for the day at the request of Massachusetts Governor Deval Patrick. A governor who was not in on the enterprise's psy- op plans would more likely have kept transportation normal.

51. The RICO enterprise in which the Defendants were engaging, on that occasion, has to do with controlling the public. The unconstitutional, warrantless raid on people's homes had the desired effect of giving citizens the impression that the United States Constitution is no longer able to shield them. After all, if a raid happened once it can happen again. And it must now be "acceptable."

52. Recently, on December 2, 2019, The Boston Globe's editor Kevin Cullen wrote an article headlined "After a few years of respite, Dzhokhar Tsarnaev is about to invade our consciousness again," referring to the upcoming Appeal. Of course, it is not Tsarnaev, but the Globe, that will be invading our consciousness again, telling us where we stand.

53. On December 3, 2019, an investment website, Stock Daily Dish, had the headline "Defending the world from terror: Fascinating pictures show anti-terror police in action around the world." The article said "Some of the photos document training exercises, while others show the reality of operations in Boston following the marathon bombing in 2013 and in Paris after the Charlie Hebdo massacre in 2015. ... [They] show the innovative tactics being used to combat new terror threats and the advanced weapons technologies being deployed." Perforce, we are expected to take this all as a given, as the new norm.

54. Governor Patrick's shelter-in-place order was lifted at 7pm, Friday, April 19, 2013. At that time, a resident of Watertown, the late David Henneberry, went outside for a smoke. Henneberry's house had been spared from the police raid earlier in the day. Henneberry noticed that the cover on his drydocked boat was loose. So he got his ladder to climb up and look inside. He saw blood and a body. His wife called 911, which led to the discovery of Jahar in the boat. Probably the "going out for a smoke" was choreographed. Without it, the media would have no blood-stained boat wall confession saying "I bear witness that there is no God but Allah." (Were those blood marks ever tested for identity?)

55. A police helicopter used thermal imagery and saw that a person in the boat was still warm, but not moving. Jahar may have been unconscious from being drugged. He could hardly have climbed into the boat with no ladder. And was it his blood on the floor? The police then "went wild," shooting 228 bullets into the boat. This was technically not necessary. The enterprise's plan may have been for Jahar to die, like his brother.

56. In scripted terrorist events, or school shootout cases, it is the norm for the gunman to be shot dead by police, even though police need only taser someone to render them harmless. Alternatively, the mass shooter "turns the gun on himself." That is the desired ending, as it eliminates a man who may otherwise reveal how he actually got there.

57. When Jahar emerged from the boat, dazed and bloody, someone may have tried to slit his throat. CNN's Anderson Cooper interviewed Jeff Campbell of the MBTA Transit Police, whose members are in an SOG (Special Operations Group). Campbell said "I did see a throat injury. To me it looked more like a knife wound." No follow-up on that.

58. Jahar was then taken to Beth Israel Deaconess Hospital and operated on. In between surgeries he was interrogated by a team that interrogates high-value suspects at Guantanamo Bay military camp. Interrogators did not record anything Jahar said, but they told the public that he said this or that, and that he asked "Where is my brother?" In 2019, photos of an alleged notebook he scribbled on, in the hospital, were publicized.

59. The team announced that they believed Jahar's alleged statement that he had no further accomplices in the outside world, so it would be safe for Boston to resume normal life. This is an unusual way for interrogators to behave. Why trust a mass killer?

60. The next day, Saturday, a district attorney came to the hospital to charge Jahar with one count of murder. When discharged from hospital, Jahar was sent to Fort Devens to await his trial. He waited two years. We don't know if they made life "difficult" for him.

61. On April 16, 2013, the FBI zoomed in on three of Jahar's friends, as though to make sure they did not have a chance to talk to the public in a way that would support Jahar's innocence. Certain FBI agents are trained to intimidate citizens, standardly threatening them with criminal charges however inappropriate. Rule of law be damned.

62. In the vicinity of Tsarnaev's dorm room at University of Massachusetts, Dartmouth, two students from overseas were arrested for lying to the FBI or throwing evidence away. One was Dias Kadaebayev, the other was Azamat Tazhayakov, friends of Jahar.

63. In July 2014, before Jahar had a trial, those two students were tried and found guilty, and sent to prison. Upon release, three years later, they were deported.

64. Jahar 's best friend, Stephen Silva, appears to have been set up on drug charges, and imprisoned. The authorities then gave Silva a chance to testify against Jahar in regard to ownership of a gun, and in exchange for that testimony Silva was sentenced in December 2015 to "time served."

65. Robel Phillipos, Jahar 's classmate from Cambridge Rindge and Latin, was accused of lying to the FBI -- by saying he was asleep when Dias and Azamat went into Jahar's room. An appearance in court by former Massachusetts Governor Michael Dukakis, as a character witness for Robel, did not prevent conviction.

66. Another friend, Khairullozhon Matanov, a taxi driver, remained free until 2016 but then was arrested, and has since been deported. He had stated that he dined with the two Tsarnaev brothers at Satwas Restaurant on the night of the Marathon, April 15, 2013, and that Tamerlan was bearded. A beard on Tamerlan challenges the validity of the video that shows the brothers walking singe-file at the Marathon with Tamerlan shaven.

67. An aunt has suggested that the photo may date to 2012, not 2013, since Tamerlan, for religious reasons, had grown a beard in 2012 and never removed it. In other words, FBI's all-crucial video of the boys may be no proof that they even attended the Marathon.

68. Matanov's prison time was spent in Plymouth Prison where he was teargassed in his cell by the authorities. He says that before his arrest, the FBI engaged in stalking him on the Freeway, causing dangerous driving, and also that a helicopter was used to track him.

69. Thus, for purposes of RICO, we can discern a coordinated effort to make sure no one could speak on behalf of Tsarnaev when he came to trial in 2015. Then, after he was tried and convicted, Jahar became unavailable to anyone who may want to ask him some questions. The trial judge put him under SAMs, special administrative measures.

70. The Bureau of Prisons (BOP) is enforcing the SAMs on Jahar as though he were a terrorist who may somehow commit crimes from his prison cell. But there is no worthy evidence of Jahar's being a terrorist or of his preaching religion to anyone.

71. The inclusion of the director of the BOP in the list of RICO Defendants is meant to show how many factors have to be monitored in a psy-op. All normal freedom of a client to choose his own attorneys has been denied to Tsarnaev as he cannot phone or write to any attorney except the ones appointed to him, the court- appointed Public Defenders.

72. Administrators of Plymouth prison must also have been alerted to prevent Matanov, SAMs-free, from contacting the press with allegations about Tamerlan's beardedness.

73. Although Plymouth Correctional Facility is county-run, the US Marshals were super- vising Matanov. When asked for information about his treatment, the US Marshals office said it could not be discussed as it is a "security-related matter." How can that be?

74. The persons in the enterprise must be aware of how the human brain tends to shut down when matters related to a foreign enemy are presented. People will side with the

authorities of their own group, unquestioningly, rather than feel doubt about their leader. Rarely do Americans question the torture that their government practices today, such as at Gitmo, preferring to think there must be a real need for it.

75. Matanov, now deported, seems to have acquired a lot of money. There may have been a payout in exchange for his silence or an agreement not to sue for mistreatment.

76. The enterprise must make it possible for particular prisoners to get roughed up, or even killed. Matanov wrote: "I fell down, my hands are on my back with the cuffs.... They jump on me so badly one of them stick his finger to my right eye, it's swollen right now full of blood."

77. The enterprise also makes for a corrupt police system. At Plaintiff's lecture of January 23, 2018, at the Watertown Public Library, Watertown Police Sergeant John MacLellan, who was the supervisor on duty at the scene of Henneberry's boat, at 8pm on April 19, 2013, was asked why so many bullets were aimed at the boat. He said they were not his cops doing the shooting; they were "outside agencies."

78. Sgt Maclellan also mentioned at that lecture that there was a female witness to the killing of Sean Collier who came forward to his office, via her father, but whose statement was not pursued because of the other pressures of the night. That contradicts all protocol and common sense.

79. Sgt MacLellan also said that he had tried unsuccessfully to identify "the other naked man," not Tamerlan, so he could apologize to him. One would think police could obtain the man's identity from either the CNN photographer or from the FBI whose agent was pictured next to him. Apparently MacLellan isn't allowed to interfere with the enterprise.

80. National Geographic is most likely a CIA proprietary (judging from its ability to enter foreign countries). It is named as a Defendant here on account of its role in creating a major piece of false evidence, a video called Inside the Hunt for the Boston Bombers.

81. A segment of that video, called White Hat, was used to persuade Bostonians that Jahar placed a bomb-filled backpack on the ground and then detonated it from his cell phone. Viewers were repeatedly shown this video on TV. But, as the credits of the film admit, this National Geographic video was all filmed in Phoenix Arizona, starring Alex Karavay as Dzhokhar Tsarnaev. It is a re-enactment, and not a truthful one.

82. The video gives the impression that the real FBI agents shown in White Hat are examining a real surveillance video taken on Boylston St. FBI man Richard DesLauriers narrates: "It was a video that shows a crowd that was watching the Marathon and we identified one individual in that crowd" (meaning Jahar, who was wearing a white baseball cap). But no, in White Hat they were watching the Arizona re-enactment.

83. Another real FBI man, Agent Jeffrey Sallett, says, "There is no magic bullet to get the identity of this man." But that was a lie. The Boston FBI office clearly knew, and later admitted that it knew, the Tsarnaev family. Sallett was the head of FBI in Chicago and is now chief of the FBI's Public Corruption and Civil Rights section.

84. Governor Patrick also appears in the White Hat segment stating "It was chilling ... to try to imagine what kind of person enables that kind of destruction of innocence." But Patrick was formerly a US Attorney; he would have dealt with many instances of destruction of innocence and not found them chilling. But this is part of theatre, directed at people's emotions to make them fall in, to believe a fiction about what was happening right there in their own Copley Square.

85. National Geographic's production and promoting of White Hat may constitute a crime of obstruction of justice. Every jury member would have seen it on TV in the lead-up to the 2015 trial. Everyone "understood" that Jahar had been caught on camera committing a crime (placing the backpack on the ground). But no, he hadn't, and he didn't.

86. Not mentioned in this RICO suit are the producers of the very deceitful movie Patriot's Day, but that was not released until after the 2015 trial of Jahar. Its function may be to reinforce in citizens minds the fact that there is "no doubt" as to what happened at the Marathon and after. "We all agree."

87. Also not mentioned in this RICO suit are the services of groups who spread disinformation, although the enterprise does depend on their existence. UK journalist Feliks Garcia said "US government spent $500m [half a billion] on fake Al-Qaeda propaganda videos that track location of viewers."

88. Senator Rand Paul and Rep Tulsi Gabbard sponsored a bill named "The Stop Arming the Terrorists Act." They said their own country was funding the organization known as the Islamic State. Like the Boston bombing, that funding can be a false flag designed to make Americans hate a foreign group (Muslims) so that the weapons industry can thrive.

89. One story about the Tsarnaevs is that they frequented terrorist websites such as "Inspire" which teaches folks how to make bombs. German scholar Elias Davidsson traced thus type of propaganda to MEMRI, a Zionist group, and Jihadology run by Aaron Zelin.

90. A professional propagandist, Martin Wells, told The Independent, UK, that US Marines would take his CDs and drop them into houses they were raiding, to cast a terrorist reputation on the house's residents. So, when we hear that the FBI "found" Inspire magazine on the Tsarnaevs' computer, there's not much reason to believe it.

91. For an enterprise whose goal is to change everyone's minds about their world, by creating a new false reality, it must follow that the new reality can't coexist with the normal practice of reasoning and debate. Instead of arguing the points, the enterprise dishes out slogans and entertainment, and incessantly spotlights social conflict. Meanwhile, children are not longer taught, in school, to tackle a problem intellectually.

92. The whole structure of society would need to change to suit the enterprise. Producing false statistics regarding a scientific experiment, or denying that major events in history even happened, would start to become normal. There would be no standard for judging anyone's claims. Civilization can be revoked. Humans can be remade into machines. Alternatively, as Plaintiff requests, we can break up the enterprise.

93. At Jahar's trial in 2015, four of the Defendants played major roles: the Prosecutor -- US Attorney Carmen Ortiz, two Public Defenders -- William Fick and Miriam Conrad, and the FBI. The main malfeasance of the Prosecutor was to proffer false accusations. The main malfeasance of the Public Defenders was to go along with the Prosecutor rather than defend their client. In the opening statement for the defense, Defender Judy Clarke said "It was him."

And despite the US Supreme Court's 2018 ruling in McCoy v Louisiana, which ruled against public defenders proclaiming a clients' guilt to the court against his wishes, Jahar has not had an opportunity to put that ruling to his own use. Almost cert- ainly he does not know that he now has a sure right to a new trial, as Mr MCoy got, in McCoy v Louisiana, since no one is able to write to Jahar about this. Albeit, Jahar may at this point have lost the mental capacity to choose an attorney who would actually help him.

94. The main malfeasance (actually criminality) of the FBI was to furnish dubious material evidence, and to round up Jahar's Tsarnaev's local friends and kill Tamerlan's friend Ibragim Todashev, preventing them from being defense witnesses. The FBI also took part in the crucial deceit of National Geographic's White Hat as mentioned in 82 above. And, the FBI bombarded the public with the video of the brothers walking single-file, with Jahar, "Suspect 2," carrying a grey backpack -- yet simultaneously proffered a black backpack as proof of Jahar's guilt. A true absurdity that went unnoticed by any lawyers.

95. The Prosecutor had to persuade the jury that Tsarnaev did all the things the story says he did, starting at the Finish Line of the Marathon. That is, he had to learn how to make a bomb, to obtain the ingredients, to plant the backpack at the site, to detonate the bomb by cell phone, to go to MIT campus and kill Officer Sean Collier, to steal money from Dun Meng's account at an ATM, to shoot at cops on Laurel St and throw an IED, to hide in a boat and write a confession on the boat wall, and to tell interrogators in the hospital that there were no more accomplices.

96. The Defenders could have, but didn't, punch many holes in the prosecution's story. Some easy targets were: 1. Tamerlan's carrying the January receipt for pressure cookers in his wallet until caught with it three months later, at the shootout, 2. Tamerlan being identifiable from his high school diploma that was found in his car, 3. the need for a second gun (for which they went to MIT to steal Collier's), 4. the fact that the eyewitness, Nathan Harman, never claimed to have seen Jahar attacking Collier, 6. the fact that Sgt Henniger's knowledge of the FBI swarming MIT wasn't queried, 7. the brothers' need for a second car (which caused the carjacking), 6. the changes in Meng's story as to what the brothers said, 8. the lack of resemblance between the ATM thief and Jahar, 9. the lack of any dashcam photo of the Laurel St shootout, 10. one brother running over the other, 11. inconsistent stories about being dragged by the SUV, 12. the acceptance of unclear reports from doctors as to "Tamerlan's" condition at the hospital,

13. Officer St Onge failing to capture Jahar, 14. complete omission of evidence of the Podstava video, 15. lack of curiosity about the naked man, 16. the delay in discovering that the boat's wall had a confession on it, 17. the impossibility of writing a neat statement on a fiberglass wall with a pencil, 18. the ridiculous wording of pious sentiment by a non-religious teenager, 19. the oddity of the hospital interrogation ending in a statement that there were no other accomplices out there, 20. the acceptance of law enforcement's right to shoot 228 bullets at the boat which would likely kill the suspect, 21. no follow-up on Jeff Campbell's observation of a knife wound on Jahar's neck at the boat side.

97. The most stunning suppression of information that occurred at trial was the lack of attention to an affidavit sent to court by the brothers' aunt, Maret Tsarnaeva, a lawyer. Maret was present during one of the 13 visits that the Defenders made to the Russian Federation before the trial, and has sworn that Public Defender William Fick refused to look at the Podstava video she offered him. That video shows Tamerlan being arrested at Mt Auburn St at 1:05am, which negates the whole story of the boys being in a Laurel St shootout 25 minutes earlier, and corrects Sgt MacLellan's mistaken belief that it was Tamerlan who bled to death. Also, Maret's affidavit says that Mr Fick, at that meeting, got angry when she asked the Defenders to consider others who may have been the real Marathon bombers. This would have taken the heat off her bereaved family.

98. Paragraph 97 is proof to any American that the Marathon bombing incident is surreal. The entire Department of Justice has become corrupted because some of its members are in on an enterprise that creates wars and seeks complete control of the people. "Justice" as a value is longer promoted. Due process is considered entirely dispensable. The members of the enterprise want us to move into an era in which the Bill of Rights means nothing and where no citizen can expect to get justice.

99. The acronym RICO stands for Racketeer Influenced and Corrupt Organizations. The Defendants must be held accountable for their participation in a radical change to our political system. And what better way to do so than to make them account for the particulars of the event known as the Marathon bombing.

100. What will posterity think? It is only a matter of time until everyone knows that the Boston case is a false flag. Similar bombings elsewhere, from London to Mumbai, have now been outed as false flags. Naturally it is difficult to prosecute powerful officers. But the American people have a means to sort things out without having to wait till all the players are dead. They have the law. The RICO Act of 1970 was originally intended as a way to circumvent the problems of arresting Mafia criminals; it has since expanded. It has been used in civil actions as a means of performing quasi-private prosecutions, to benefit the nation. RICO's concept of racketeering solves many puzzles of the Marathon case.

X. Possible Additional Defendants

Other media outlets, other doctors, other law enforcement person, other US Attorneys and Public Defenders could possibly be added to the list of Defendants. The three Attorneys General who have kept Jahar Tsarnaev quiet under SAMs are Eric Holder, Loretta Lynch, and William Barr. They could be named as individual defendants.

XI. Prayer for Relief 

Plaintiff asks for injunctive relief, monetary damages, and declaratory relief thusly:

1. For the Appeals panel to be enjoined to stay the case against Tsarnaev, and for him to be freed from prison.

2. For the state Medical Examiner to be ordered to carry out an inquest into the deaths of Tamerlan Tsarnaev, Sean Collier, Martin Richard, and the man who bled to death in view of Police Sgt John MacLellan, on Laurel Street Watertown, in the wee hours of April 19, 2013.

3. For Gabe Ramirez of CNN to be ordered to explain the filming of naked Tamerlan climbing into the police car at 1:05am on April 19, 2013, and to furnish the identity of the other naked man who was filmed standing against a wall with an FBI man beside him.

4. For Deval Patrick, Richard DesLauriers, and Jeffrey Sallett to be ordered to explain the statements they made in the National Geographic film White Hat.

5. For Matt Isgur, expert of MIT's cameras, to be ordered to explain why he omitted the crucial five minutes in the video he complied as evidence of Sean Collier's death.

6. For Carmen Ortiz to be ordered to explain why Sean Collier's car was destroyed.

7. For Richard Serino of Emergency Services to be ordered to state why his Power Point talk in 2008 suggested the Marathon Finish line as the place where a bombing may occur.

8. For William Fick, Judy Clarke, and their workers Jane and Olga, to be ordered to tell what they said to the parents of Tsarnaev on numerous trips to Russian Federation.

9. For MIT police Sgt Henniger to be ordered to say what he knew of the FBI swarming the MIT campus in the afternoon of April 18, 2019, and why he suppressed it.

10. For the Court, at its discretion, to seek prosecution of any person who may have committed crimes such as perjury, in connection with Jahar Tsarnaev's 2015 trial. And to seek indictments of any who committed the crimes at the Marathon Finish Line, or at the boat side, but with offers of amnesty for those who will swiftly report the truth.

11. For the Defendants to be ordered to pay $22,000 dollars (trebled, as punitive damages) to Plaintiff for her financial losses connected to the Marathon case.

12. Declaratory relief under RICO could issue, say, from a judgment that The Boston Globe wrote up the Marathon bombing and its sequelae according to the enterprise's agenda, both to establish a myth about Islamic terrorism coming to Boston, and to persuade Americans that they no longer live in that City Upon a Hill where, as Massachusetts Governor-to-be John Winthrop said, aboard the Arbella, en route hither in 1630:

“Now the onely way to avoyde this shipwracke and to provide for our posterity is to followe the Counsell of Micah, to doe Justly, to love mercy, to walke humbly with our God, for this end, wee must be knitt together in this worke as one man, wee must entertaine each other in brotherly Affeccion, wee must be willing to abridge our selves of our superfluities,for the supply of others necessities. Soe shall wee keepe the unitie of the spirit in the bond of peace, the Lord will be our God and delight to dwell among us...soe that wee shall see much more of his wisdome power goodnes and truthe then formerly wee have been eacquainted with. Therefore lett us choose life, that wee, and our Seede, may live; by obeyeing his voyce, and cleaveing to him, for hee is our life, and our prosperity.”

Respectfully submitted,  

Mary Maxwell, PRO SE

Note to readers: The case was lost on a technicality. I could submit it again, but so could anyone. Please use it if you wish. You must show that you suffered a financial loss -- one dollar will suffice -- on account of the Enterprise.

  • Facebook
  • Twitter
  • LinkedIn
  • Instagram
bottom of page