Affidavit in Support of Criminal Complaint

August 5, 2022

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Randi Beck

Author's Title: 

Special Agent, Federal Bureau of Investigation
I, Randi Beck, being first duly sworn, state as follows:


1. I am a Special Agent with the Federal Bureau of Investigation (hereinafter referred to as "FBI") and have been so employed since August 2010. As such, I am an officer of the United States who is empowered by law to conduct investigations of and to make arrests for offenses enumerated in Titles 18 and 21 of the United States Code. I have been the lead agent for extraterritorial investigations targeting foreign terrorist organizations. I have testified before Grand Juries, conducted physical and electronic surveillance, administered confidential sources, and received training as investigative techniques evolve.
2. This affidavit is being submitted in support of a criminal complaint alleging that SHAHRAM POURSAFI, a/k/a "Mehdi Rezayi" (hereinafter referred to as "POURSAFI"), violated the following federal criminal laws: (l) 18 U.S.C. § 195 8(a) (Use of interstate commerce facilities in the commission of murder for hire), and (2)18 U.S.C. § 2339A (Providing and attempting to provide material support to a transnational murder plot).
3. This affidavit is based on my personal knowledge, information provided to me by other law enforcement agents, law enforcement records, court-authorized searches, witness interviews, and my training and experience, as well as the training and experience of other law enforcement agents. When I provide in this affidavit direct quotations of statements, they are often preliminary translations of statements that were made in the Farsi language.
4. Because this affidavit is being submitted for the limited purpose of establishing probable cause in support of a criminal complaint, I have not included each and every fact known to me concerning this investigation. I have only set forth the facts that I believe are necessary to establish probable cause that the defendant violated the federal criminal laws set forth herein.