Plaintiff, by his undersigned attorney, Philip J. Berg, Esquire, as and for his Complaint against the Defendants, respectfully alleges:

The Plaintiff, William Rodriguez, is a native of Puerto Rico, a citizen of the United States, and a resident of the State of New Jersey. On September 11, 2001, and for approximately nineteen years prior thereto, Rodriguez was employed as a maintenance worker at the World Trade Center (“WTC”) in New York, New York. On 9-11, Rodriguez single-handedly rescued fifteen (15) persons from the WTC, and — as Rodriguez was the only person at the site with the master key to the North Tower stairwells — he bravely led firefighters up the stairwell, unlocking doors as they ascended, thereby aiding in the successful evacuation of unknown hundreds of those who survived.

Rodriguez, at great risk to his own life, re-entered the Towers three times after the first, North Tower impact at about 8:46 A.M., and is believed to be the last person to exit the North Tower alive, surviving the building’s collapse by diving beneath a fire truck. After receiving medical attention at the WTC site for his injuries, Rodriguez spent the rest of 9-11 aiding as a volunteer in the rescue efforts, and at dawn the following morning, was back at “Ground Zero” continuing his heroic efforts.

Rodriguez lost his employment of 19 years and his means of earning a living as a direct result of the attacks on the WTC on 9-11. Deeply affected,
as one might imagine, by his experiences of 9-11, Rodriguez has, in a variety of capacities and through several different organizations, worked ever since that terrible day to help others who were affected by the atrocities committed. He has continued in these labors, notwithstanding the fact that,
due to the loss of his employment, he has been unable to earn a living, and was even homeless for a time.

While there have been convened two purported “investigations” of 9-11, one by a joint committee of Congress plus a second, “independent” investigation conducted, in the main, by the Commission chaired by Thomas Kean and comprised of persons with flagrant conflicts of interest,
neither investigation has addressed in earnest and transparently — much less made known to the public — the facts of what really happened on 9-11 to deprive plaintiff of his livelihood, and to cause the deaths of approximately 2,993 persons from some 83 countries (most of the deceased being citizens of the United States).

The government, and most of the major media allied with, or operating in fear of offending, the Bush II Administration, would have the public believe that the facts of by whom and in what manner the 9-11 attacks were carried out have been investigated, and the 2,993 homicide cases are “closed,” but for the hoped-for capture of Osama bin Laden and others of the “al Qaeda” network who may have aided in the attacks. Literally within just a few hours following the attacks, government and corporate media sources put forth an “Official Story” which, with minor patching-up to gloss over revelations that President George W. Bush and other high government and military officials had many, surprisingly specific warnings of terror attacks using airplanes as weapons, is essentially as follows. Four planes, American Airlines Flights 11 and 77, and United Airlines Flights 93 and 175, were hijacked by four teams of Arab hijackers totaling 19 men. The hijackers were part of a decentralized network of Islamist militants, whose leader (or one of whose top leaders) is Osama bin Laden, who although generally acknowledged as a onetime CIA “asset” (at the time that the U.S. Government and the CIA funneled funds to anti-Soviet militants fighting in Afghanistan) is now depicted as a devout enemy of America. Bin Laden, and the hijackers, are said to have been motivated by their hatred for America (in President Bush’s words by hatred of “our freedoms”) and resentment over U.S. troops remaining stationed in Saudi Arabia and other Muslim countries, U.S. support for Israel and its treatment of the Palestinian Arabs, and perceived American opposition to Islam. Initially, the “Official Story” claimed that the attacks came “without warning,” that “no one could have imagined [them].”

As such claims were resoundingly discredited, the story was revised to assert that such warnings as were received were too indefinite to allow actions as might have prevented the attacks from occurring. Upon information, not one American who held on 9-11 a position in the Government, the military, the affected airlines, the airport security systems, or the civilian air traffic control systems has been discharged, or forced to resign his or her job, or court martialled due to failure to do their duty in respect of the attacks. The Official Story, of course, fails even to consider as within the realm of possibility that high government or military personnel may have affirmatively desired that the attacks succeed, and for that reason failed to take measures as might have prevented the attacks or, once the same were in progress, mitigated the loss of life (such as intercepting the diverted aircraft before the WTC and the Pentagon were struck). That such persons might have actively participated in planning or sponsoring the attacks, or enabling the attacks to succeed, is considered so incredible as to be unworthy of refutation by the proponents of the “Official Story.”

As will be examined below, to accept the Official Story as true, one must ignore much evidence to the contrary, believe many facts that range from implausible to impossible, and ignore the stunning number of bizarre “coincidences” which alone can explain the events of 9-11, if one rejects that the attacks were an “inside job.” Although the infrequent references to “9-11 skeptics” in mainstream media generally denigrate them as “tinfoil hat-wearing” eccentrics, or persons who hate America, in point of fact large numbers of Americans harbor serious doubt as to the veracity of the Official Story. Indeed, a mainstream publication (Harpers) is running in its October 2004 issue a 12-page essay by Benjamin de Mott entitled “Whitewash as Public Service: How the 9/11 Commission Report Defrauds America.” On August 31, 2004, Zogby International, a respected polling organization, released the results of surveys taken in the days preceding the 2004 Republican National Convention, indicating that 49.3% of the population of New York City, and 41% of the residents of New York State, were of the belief that the U.S. government “knew in advance that attacks were planned on or about September 11, 2001 . . . and consciously failed to act.” Such figures, especially given that major media (like the Commission) have assiduously “whitewashed” the facts of the actual 9-11 attacks for more than three years, are astounding. Thus, however disturbing the implications of the plaintiff’s allegations in this lawsuit, he cannot be dismissed as a lone eccentric. As an American and as an undisputed hero of the events in question, Rodriguez, in demanding the truth of those events that cost him his job and anguish as few people are called upon to undergo, deserves the full benefits of American justice, and his day in court.

RICO Complaint Part 3 here