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12. In general terms, covertcommunication via a private wireless network is a form of electronic communication through paired laptop computers. Such covert communication utilizes temporary wireless networks that spring up between two computers and can be used to transmit data between them. The way this system typically works is as follows: a laptop computer ("LAPTOP A") is preconfigured to create its own private wireless local area network. This wireless net work is programmed to only communicate with another specific laptop ("LAPTOP B"), based on LAPTOP B's Media Access Control ("MAC") address. Once LAPTOP A transmits the signal to establish its own private wireless network, it will be "joined" by LAPTOP B when LAPTOP B comes within a certain physical distance of LAPTOP A. Once the two laptop computers are both on the private wireless network, they can communicate with each other by exchanging data. The data can be encrypted so that it can only be read with the aid of specialized decryption software, similar to that used to decrypt messages hidden through steganography, as described in the Complaint attached hereto.

On or about August 25, 2007, JUAN LAZARO, the defendant, in a South American country, received a package containing money from a representative of the Russian government.

21. Steganography is the process of secreting data in an image. Moscow Center uses steganographic software that is not commercially available. The software package permits the SVR clandestinely to insert encrypted data in images that are located on publicly-available websites without the data being visible. The encrypted data can be removed from the image, and then decrypted, using SVR-provided software. Similarly, SVR-provided software can be used to encrypt data, and then clandestinely to embed the data in images on publicly-available websites.

23. During the 2005 New Jersey Search, law-enforcement agents observed and photographed apiece of paper; the paper said "alt," "control," and "e," and set forth a string of 27 characters. Using these 27 characters as a password, technicians have been able successfully to access a software program ("Steganography Program") stored on those copies of the Password Protected Disks that were recovered during the 2005 New Jersey Search and at subsequent searches of the New Jersey Conspirators' residence.

24. In the course of the 2005 New Jersey Search, lawenforcement agents also saw, among other things, acomputer; the hard-drive of the computer was copied and analyzed. This analysis led to an electronic address book that contained links to website addresses, as well as information as to various website addresses that the computer's user had accessed. These addresses, in turn, had links to other websites. Law-enforcement agents visited some of the referenced websites, and many others as well, and have downloaded images from them. These images appear wholly unremarkable to the naked eye. But these images (and others) have been analyzed using the Steganography Program. As a result of this analysis, some of the images have been revealed as .containing readable text files. These text files of which there are well over 100 - are referred to hereinafter as the "New Jersey Conspirators' Electronic Messages."

During the 2006 Boston Search, law-enforcement agents observed and copied numerous computer disks. Anumber of these computer disks contained traces of deleted electronic messages. Technicians recovered these "deleted" messages. Based on my training, experience, and participation in this investigation, Ibelieve that the "deleted" messages (hereinafter, "Boston Conspirators' Electronic f1essages") were drafts of messages that were subsequently conveyed between Moscow Center and the Boston Conspirators, using steganography.

In addition, and among other things, a number of the Boston Conspirators' Electronic Messages appear directly to concern communication by means of steganography. For example, one mes,sage, dated December 15, 2004, discussed the process of "decrypt[ing]" messages embedded in images; another message, dated February 22, 2005, discussed "decypher [ing] [sic]" data embedded in images. Similarly, on or about October 3, 2004, lawenforcement agents, acting pursuant to ajudicial order, intercepted aural communications taking place inside the Boston Townhouse. TRACEY LEE ANN FOLEY, the defendant, was heard saying to DONALD HOWARD HEATHFIELD, the defendant: "Can we attach two files containing messages or not? Let's say four pictures..."

27. Radiograms are coded bursts of data sent by aradio transmitter that can be picked up by aradio receiver that has been set to the proper frequency. As transmitted, radiograms generally sound like the transmission of Morse code. As is set forth below, the Illegals have communicated with Moscow Center by means of radiograms.

[...]

29. In asimilar vein, large numbers of the New Jersey Conspirators' Electronic Messages mention the sending or receipt of an "RG." For example, aJanuary 2009 message from Moscow Center for the New Jersey Conspirators reads, in relevant part: "PIs, make sure your radioequipment [sic] for RG rcptn is in order. We plan to send acouple of test Rgs[.]" Based on my training, experience, and participation in this investigation, Ibelieve that "RG" and "Rg" connote "radiogram."

34. To cite another example, during the summer of 2009, the New Jersey Conspirators argued with the SVR in a series of encrypted messages about the status of the Montclair House, into which the New Jersey Conspirators had recently moved. The New Jersey Conspirators contended that they should be permitted to own the Montclair House; Moscow Center responded that the Director of the SVR had personally determined that Center would own the Montclair House, but would permit the New Jersey Conspirators to live in it. The New Jersey Conspirators wrote:

In order to preserve positive working relationship, we would not further contest your desire to own this house... We are under an impression that C. views our ownership of the house as a deviation from the original purpose of our mission here. We'd like to assure you that we do remembe rwhat it is. From our perspective, purchase of the house was solely a natural progression of our prolonged stay here. It was a convenient way to solve the housing issue, plus to 'do as the Romans do in a society that values home ownership... [W]e didn't forget that the house was bought under fictitious names.

43. TRACEY LEE ANN FOLEY, the defendant, purports to be a naturalized United States citizen, and a native of Canada. On or about January 23, 2001, law-enforcement officials, acting pursuant to a judicial order, searched a safe deposit box located in Cambridge, Massachusetts ("Cambridge Safe Deposit Box"). The Cambridge Safe Deposit Box is registered in the name of "Tracey Lee Ann Foley" and "Donald Howard Heathfield." Inside the Cambridge Safe Deposit Box, officials observed and photographed a series of photographic negatives; the negatives appear to be of FOLEY when she was in her 20s. On all the negatives of the younger FOLEY save one, the name of the company that produced the film on which the negatives were printed has been excised. On one negative , the name of the film company remains visible . The name on the film is "TACMA"; based on law-enforcement research I know that TACMA was a Soviet film company.

48. Similarly, TRACEY LEE ANN FOLEY, the defendant, has traveled on a fraudulent British passport prepared for her by the SVR. One of the Boston Conspirators' Internet Messages provided instructions for FOLEY with respect to her then-upcoming trip to Moscow:

Itinerary to M. [Moscow] for D.; Paris - Wien (by train), Mar 18 in Wien exch[ange] doc's for British pass [port] - [Moscow] (Mar 19, flight OS 601). Very important: 1. Sign your passport on page 32. Train yourself to be able to reproduce your signature when it's necessary. 2. Pls, be aware that you just visited Russia (see stamps on page 14 - entry - Mar 16, departure - Mar 17). If asked, we suggest you use the following story : you flew to Moscow on Mar 16 from London for example flight SU 211 to participate in business talks (your business is international consultancy seminars - pls , copy sample of your husband) on invitation by Russian Chamber of Commerce. In the passport you'll get a memo with recommendation. Pls , destroy the memo after reading. Be well.

53. On or about May 16, 2004, pursuant to a judicial order, law-enforcement agents conducted video surveillance from multiple cameras positioned in the immediate vicinity of the Long Island Railroad's Forest Hills Station in Queens, New York ("Forest Hills Train Station"). The May 16, 2004 video surveillance of the Forest Hills Train Station reflects that CHRISTOPHER R. METSOS, the defendant, and Russian Government Official #2, were initially in the vicinity of the Forest Hills Train Station, and that METSOS and Russian Government Official #2 were each carrying an all-but identical orange bag. CHRISTOPHER R. METSOS, the defendant, and Russian Government Official #2 then converged on a staircase at the Forest Hills Train Station. METSOS walked up the stairs; Russian Government Official #2 walked down the stairs . Toward the middle of the stairs , as they passed one another , METSOS quickly handed Russian Government Official #2 his orange bag, and Russian Government Official #2 quickly handed METSOS his orange bag. METSOS then continued ascending the stairs and Russian Government Official #2 continued descending the stairs.

70. In addition to arranging the defendant, RICHARD MURPHY'S travel to Moscow Center, in its January 2010 messages, the SVR also instructed MURPHY to buy certain computer equipment using "all necessary precausions [sic]: no preliminary order, pay cash, destroy receipts , etc.," and to bring that computer equipment to Center.

71. After RICHARD MURPHY, the defendant, received these instructions, on or about February 9, 2010, law-enforcement' agents conducting surveillance of MURPHY saw him enter a computer retailer (the "Computer Store") in Manhattan, and then leave the store a short time later carrying what appeared to be a laptop computer box. Later that day, three Computer Store employees spoke with investigating agents and identified MURPHY from a photograph as having bought a laptop computer from the Computer Store earlier in the day. One of the employees reported that MURPHY had said his name was "David." A database of sales maintained by the Computer Store reflected that, earlier that day, an individual who identified himself as "David Hiller" had paid cash for, interalia, an ASUS EEE PC 1005HA-P laptop computer. This was the make and model of computer that the SVR had directed MURPHY to buy.

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