General Allegations:

 

1. From at least December 2020 and continuing until in or around March 2021, the defendants and Co-Conspirator-I participated in a plot to murder two residents of the State of Maryland. The two targeted residents of Maryland are hereinafter referred to as "Victim-1" and "Victim-2" (hereinafter "the Victims"). Victim 1 defected from Iran and, together with Victim 2, fled to the United States.

 

2. To plan the murders of the Victims, the defendants and Co-Conspirator-1 used an end-to-end encrypted communication service called "SkyECC". SkyECC is a service through which customers buy a mobile phone for the exclusive purpose of using the app to send and receive encrypted messages via an anonymous identifier or pin code. Each SkyECC user, including the defendants identified herein, was provided with a unique identifier, or a "handle" which is comprised of a series of capital letters and numbers. The defendants' and Co-Conspirator-l's use of SkyECC  included sharing targeting information with the participants in the plot. This sharing included disseminating photographs of the Victims' faces as well as maps identifying where the Victims could be located. Further, as discussed below, the defendants and Co-Conspirator-1 used SkyECC messaging to recruit personnel to assist in the killings, discuss logistics of the murders, and negotiate payment for expenses associated with the murders.

 

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