A. Conduct an impartial investigation or appoint an independent, impartial,
randomly selected grand jury to:
1. Generally, answer the unanswered questions, those posed to the Kean
Commission by the relatives of September 11 victims and those posed in this
Complaint and Petition and in the materials provided with it.
2. Obtain any as-yet unpublished or classified investigatory analyses,
reports, or physical or other evidence from law enforcement authorities,
government agencies and courts of New York City, New York State and other
localities and states, US federal and foreign agencies, Congressional
offices, Pentagon, White House, Department of Justice, Department of
Homeland Security, the Mission to the United Nations, the Port Authority of
New York and New Jersey, CIA, FAA, FBI, FEMA, NIST, NTSB, SEC, Underwriters
Laboratories, former members of the Kean Commission and its staff, and
others, and identify any anomalies from the official assumptions,
declarations, media reports, and other accounts put forward to the people of
New York as explanations for the absence of official culpability for the
crime and damages arising from it.
3. Interview witnesses, alleged perpetrators, whistleblowers, and other
sources whose accounts of the events of 9/11 have been suppressed,
classified, or otherwise withheld from public scrutiny.
4. Determine to what extent insider
trading in the form of "put" or "short" positions—and
any other suspicious securities trading activity—took place with respect
to stocks in companies adversely affected by the 9/11 tragedy (including,
but not limited to, United Airlines, American Air Lines, Merrill Lynch and
Morgan Stanley). In addition, identify the holders of any suspicious
positions or principals of trades and any individuals or firms in the
securities business who may have furthered any such insider trading or had
5. Determine the validity of those assumptions (as described in Part
I, Section 5 of this Complaint and Petition) upon which the findings of
the Kean Commission are based, and if not valid, determine what effect any
so-identified discrepancies (between the official assumptions and the actual
events) would have upon the conclusions as to (a) the cause of the 9/11
crimes and (b) the identity of the perpetrators and conspirators who carried
out the 9/11 crimes.
6. Determine, based upon the work of independent scientists, engineers,
and other experts, whether the collapse of each World Trade Center building
a. Solely due to the crash of two airliners and resulting fires (or, in
the case of Building 7, fire alone);
b. Due in part to the storage of flammable chemicals or other
combustibles within the buildings;
c. Due in part to fraud or criminal negligence or recklessness in the
building materials, construction techniques, or maintenance of the
d. Due in part to detonation of explosive materials;
7. Identify those responsible for the destruction of evidence of the
crimes committed in connection with the events of 9/11 and for the
suppression of witness accounts through threats of reprisal, intimidation,
harassment, or otherwise.
8. Determine from medical or other experts the cause of the many physical
maladies suffered by the residents of, workers in, and visitors to New York
City during and following the 9/11 tragedy from exposure to toxic substances
and related causes and:
a. Identify individuals in key decision-making positions with respect
to the official response to the ongoing health dangers posed by the 9/11
tragedy to New York City residents, workers, and visitors.
b. Determine what decisions were made and what actions were taken by
the responsible individuals to safeguard or not safeguard the health and
well-being of victims of toxic substance exposure in New York City and its
c. Determine whether the actions taken by those in authority or in key
advisory positions within and outside federal, state, and local government
contributed to such physical maladies.
d. Identify any conflicts of interest by decision-making officials and
determine whether such conflicts of interest contributed to or aggravated
such physical maladies.
9. Identify those who authorized departure from US jurisdiction of
potential individual co-conspirators, facilitators, or aiders and abettors.
Specifically, identify the actions taken by those in authority and their
superiors or principals to effectuate the premature departure of members of
the bin Ladin family and other Saudis from US jurisdiction and what effect
such departure had upon the investigation of crimes related to the 9/11
10. Generally, identify those responsible (including, if appropriate,
those in government and government contractors) for murder, monetary damages
to public authorities, property damage, and damage to the health and general
welfare of New York residents and owners and employees of New York
11. Identify government officials and contractors, if any, responsible
for failure of the nation's air defenses, including those involved in any
capacity in the war games that coincided with the attacks.
12. Identify conflicts of interest among key public and private sector
players involved in the events of 9/11 or their aftermath and identify any
related patterns of profiteering, including stock market profits, with
respect to, for example, the award of government contracts and the lobbying
for and passage of legislation.
13. Identify bank accounts and other sources of funding for crimes
related to 9/11 and "follow the money" from its ultimate sources
through its use for purposes furthering the conspiracy of 9/11, in the
process identifying and interviewing individuals whose actions furthered the
14. Identify law firms, accounting firms and banks, if any, that aided
and abetted the 9/11 crimes, their financing and other activities in
furtherance of crimes related to the tragedy.
15. Calculate the damages to the State of New York, the City of New York
and their authorities, funds, and other instrumentalities, including both
past costs and damages and the increase in the costs of future legal,
contractual, or moral imperatives of such governmental entities, funds, or
16. Identify sources of financial redress from:
a. Responsible federal government officials;
b. Complicit local officials;
c. Government contractors and private corporations (and their control
persons), banks, and individuals who aided and abetted, criminally
facilitated, conspired or breached contracts or duties arising under
contract or otherwise—or engaged in illegal or immoral profiteering
while in a position of public trust or fiduciary obligation.
B. Generally, hold responsible persons accountable under state law, both
personally and through their employers or principals, and in so doing seek the
following sanctions and remedies, and such other sanctions and remedies as may
be available under New York law, or charge the federal government with
pursuing federal remedies:
1. Indictments of responsible individuals, corporations or groups you
believe are guilty of crimes under New York law, including crimes— such as
criminal conspiracy, official misconduct, accessorial conduct, illegal
profiteering, obstruction of justice, intimidation of potential witnesses,
and destruction of evidence—that support or arise out of the underlying
2. Disgorgement of profits obtained by illegal or immoral means and
contractual payments for incomplete, incompetent, faulty, or otherwise
wrongfully compensated work under breached contracts and illegal activities
contributing to, exacerbating, or covering up the crimes committed on or in
connection with 9/11 and related activities thereafter in connection with
the 9/11 tragedy and its aftermath.
3. Resignation or demotion of culpable individuals.
4. Consent decrees or other legally enforceable agreements or assurances
to prevent the repetition of culpable behavior, negligence, recklessness, or
other causes of harm to New Yorkers.
5. Debarment of culpable individuals, corporations, and organizations or
groups from future business with the State of New York.
6. Recovery of damages and the levy of the maximum penalties available at
7. Prohibition of culpable businesses from continuing to transact
business in the State of New York, where they:
a. Have stock traded on New York-based exchanges.
b. Have headquarters and US offices of foreign corporations (especially
money center banks).
c. Qualify to do business in the state only through state grant, which
can be withdrawn for illegal conduct.
d. Have submitted to jurisdiction of the State of New York by reason of
admission to transact business in New York.
e. Have New York bank accounts that can be attached.
8. To the extent possible, address military failures and/or crimes,
including actions of or effects on civilian military employees, turning over
evidence to military tribunals, if appropriate.
C. If the federal government refuses to enforce federal laws: use state
power to enforce state laws; challenge federal authority to supersede state
and local authorities; challenge federally invoked state secrets privilege to
examine whether it was genuinely invoked for security or abused to cover up
wrongdoing; and work with international banking and other authorities to
investigate and follow money trails.
D. Coordinate with the attorneys general of other states with interests in
9/11, as occurred in the "tobacco settlements" and other cases where
multiple states had jurisdiction and sustained damages. (Appendix
E. Take action to protect whistleblowers within and outside government from
F. Disclose your findings to the people of New York and the nation as a
means of upholding truth and justice as the standards of the public realm,
restoring the "shattered trust" of the people in their democratic
institutions and honoring the memories of those who lost their lives on
September 11, 2001.