SEQ CHAPTER \h \r 17. Plaintiff's RICO claim is supported by the following compelling facts, among others, which he intends to prove at trial:
a. Scientific data clearly indicates that the World Trade Center buildings, including the little-discussed Building 7, were destroyed by means of controlled demolitions, of the sort that take weeks or months to prepare and could only have been an "inside job"; there were large explosive charges in the sub-basements of both of the Twin Towers, as well as smaller charges used to bring the buildings down in an orderly fashion, and neither tower collapsed due solely to the aircraft impacts or heat generated by the burning of jet fuel on the aircraft;
b. FDNY employees were and continue to be under a “gag order” imposed by senior FDNY officials on instructions of ex-CIA director James Woolsey and others, which forbids them to talk about (among other things) multiple explosions at the WTC on 9-11;
c. WTC Building 7 was deliberately “pulled” (demolished) by agreement between the FDNY and Larry Silverstein shortly after 5:00 P.M. on 9-11, as he himself admitted on public television;
d. FEMA, the agency that deliberately removed or destroyed the physical WTC evidence before independent experts could examine it could examine it, has as its principal purpose the perpetuation of an invisible government designed to replace our existing elected government;
e. All of the planes, excepting possibly Flight 11, could and ought to have been intercepted before striking their putative targets;
f. Military intervention was delayed because of a military exercise that simulated an attack on the Pentagon, which was being carried out on the morning of 9-11 – an attack of which the perpetrators could have known only with access to inside information;
g. To successfully make the many and lengthy cell phone calls allegedly made by passengers from the hijacked planes was statistically impossible, given the prevailing state of cell phone technology;
h. The sophisticated flight maneuvers attributed to the terrorist pilot who allegedly flew into the Pentagon were far too complex for a man who flunked flight training school;
i. No reliable evidence puts any Arabs, or persons with Arab names, on any of the four diverted aircraft of 9-11;
j. The missile that struck the Pentagon was not Flight 77; the hole made in the Pentagon on 9-11 was too small to accommodate an airliner, and no airliner debris appears in any photograph of the wreckage;
k. President Bush and other senior officials had multiple, actionable warnings of the attacks (if, indeed, they did not sponsor and schedule the attacks);
l. The “insider trading” on United, American Airlines and other 9-11-affected stocks was the subject of an ongoing cover-up, to conceal the identities of persons who had advance notice of the 9-11 attacks;
m. Significant evidence indicates that Flight 93 was shot down, and did not crash due to a struggle between hijackers and passengers; and that stories to the contrary were fabricated by the Enterprise (as defined in paragraphs 88-91 hereafter) for the media, which it largely owns and controls; and
n. The Enterprise, and American oil, gas, weapons, private security (mercenary) and other Enterprise-affiliated and Enterprise-friendly financial interests have profited, and continue to profit, from the “war on terror” within the United States, the military actions taken in Afghanistan and Iraq, and the extreme right-wing view of “national security”; and economic advantage favors the continuation and expansion of those efforts.

8. As will be shown, the Official Story of 9-11, in all or most of its material details, is a propaganda exercise and untrue, which untruth the Enterprise and the Bush II Administration dearly wish to maintain in the minds of the majority of the American people. A number of the points raised above are detailed in this complaint as a sampling of the weight of evidence currently available. Plaintiff submits that the cumulative body of this evidence mandates a fair hearing in a court of law.

9. Without a true investigation — not a cover-up, not a “limited, modified hang-out” largely restricted to supposed “intelligence failures” — plaintiff, and indeed every victim of 9-11 and the country at large, will be denied justice, and the American people will be denied the truth of the most stunning, catastrophic and consequential event within our borders since (at least) the assassination of President John F. Kennedy in 1963. Owing to the Republican Party’s control of Congress and the immense power of the defendants at bar, as a practical matter either the truth concerning 9-11 will emerge because of and through discovery and a public trial in this lawsuit, or the same will remain concealed, perhaps for decades.

10. Plaintiff avows at the outset that he does not know all the facts of the catastrophes of 9-11, but his study of facts available in the public domain — most of which come from “conventional” or “mainstream” news media, or agencies of the U.S. government — have convinced him, to a moral certainty (as they have convinced millions of Americans who, regrettably, are being ignored by Congress and establishment media) that the “Official Story” is a government propaganda exercise, and a “Big Lie” in the ugly tradition of Joseph Goebbels, to maintain the control of the elite over the masses.

11. Plaintiff’s study of 9-11 leads him to conclude, and therefore to allege upon information and belief as set forth below, that President George W. Bush, his father, former President George H. W. Bush, his brothers, Jeb Bush, Neil Mallon Bush, and Marvin Bush, Vice President Richard Cheney, Secretary of Defense Donald H. Rumsfeld, National Security Advisor Condoleeza Rice, then-Acting Chairman of the Joint Chiefs of Staff, General Richard Meyers, then-NORAD chief Gen. Ralph E. Eberhart, then-FEMA Director Joe M. Allbaugh, Senior Political Advisor Karl Rove, and others of the Defendants had actual knowledge, prior to September 11, 2001, that on or about that date one or more commercial airliners would be commandeered or diverted, flown into a landmark building or structure within the territory of the United States, and that the deaths of all or most of the passengers on the airplane(s), as well as hundreds or thousands of people in and about the targeted building(s), would result.

12. Plaintiff further alleges on information and belief that Defendants not only had foreknowledge that the World Trade Center and other landmark targets would be attacked on 9-11, with mass casualties being an intended result, but that they actively conspired to bring about a “new Pearl Harbor,” in order to promote a criminal enterprise classically within the reach of the RICO statute. Plaintiff will not be equivocal. His complaint is not based on allegations of the defendants’ negligence, nonfeasance, errors in judgment, poor management of various branches of the government bureaucracy, or intelligence failures (e.g., failing to resolve “turf battles” among security agencies such as the CIA and the FBI, or failing to “connect up the dots” of supposedly sketchy information that threatened possible attacks on American soil). Although all of the foregoing may have occurred, plaintiff is accusing the defendants of foreknowledge of, and (in the case of most of the defendants) approval and sponsorship of the 9-11 attacks, kidnapping, arson, murder, treason against the United States, conspiracy to commit the foregoing and multiple other crimes (many of which are enumerated “predicate acts” under the RICO statute), aiding and abetting such crimes, and/or being accessories after the fact to the same.

13. In today’s world — and especially in the United States, where agricultural employment has virtually disappeared and manufacturing jobs are fleeing overseas — more than in any other sectors (with a few favored exceptions, of which the pharmaceutical companies are an example) big money is made primarily in the following areas: (1) war preparations, and the international trade in weapons, both legal and illegal; (2) oil, gas, and related energy services; (3) trafficking in narcotics and other illegal drugs; (4) “white collar crime,” e.g., embezzlement, securities fraud, insider trading, price-fixing, the illegal manipulation of markets, denuding funds from banks and pension plans, large-scale identity and credit-card theft, stealing huge sums of money from government-funded programs, blackmailing public officials, etc.; (5) trafficking in humans, in part for forced labor, but primarily the abducting and selling of women and children for sex; and (6) money laundering, to “cleanse” the (mostly) illegal proceeds of the foregoing. Although space does not permit the full exposition of the same in this complaint, upon information and belief, members of the Enterprise alleged herein have been directly involved, or long and closely associated with persons known to be involved, in some or all of the aforementioned activities. Their activities have been, and continue to be, in large part criminal per se. And, even to the extent that some of their business activities (e.g., oil and gas investments, investments in defense-related industries) may not be illegal, those activities are intertwined with, and supported by, murder, drug-trafficking, financial scams, the blackmailing of politicians, vote-rigging, the planning and waging of wars of aggression, and the torture and abuse of prisoners that are crimes under treaties and the law of nations.

14. Broadly described, Defendants’ paramount (but by no means its only) motive in orchestrating the 9-11 attacks was to obtain a “blank check” to conduct wars of aggression, to consolidate economic and political power by the seizure of the oil fields of Iraq and a right-of-way for a natural gas pipeline to be built in part across the territory of Afghanistan, and to promote their own financial interests and those of their RICO “enterprise,” which exists and carries out crimes on a scale that “traditional” organized crime organizations, such as the New York Mafia “families,” could never dream of achieving. (The “Enterprise” is defined in paragraphs 88-91 hereafter.)

15. In addition, the attacks and the destruction of three buildings at the World Trade Center complex in New York City destroyed, and were intended by the Enterprise to destroy, a large volume of documents, books and records in offices of the Federal Bureau of Investigation in the North Tower, the Security and Exchange Commission in World Trade Center Building 7, and other offices in those buildings, to thwart investigations contrary to the interests of and potentially damaging to the fortunes of the Enterprise, corporations friendly to the Enterprise that were under investigation by the FBI and SEC, Federal Reserve Chairman Alan Greenspan, a number of prominent banks and brokerage houses with strong ties to the Enterprise, the Council on Foreign Relations, the CIA, and others.

16. As will be set forth below, in broad terms Plaintiff’s allegations rest upon three sets of facts. First, the official story of 9-11 promulgated by Defendants, and investigated by no one (private researchers aside), is unsupportable. As will be explained, the “Osama and the 19 Muslim Zealots” story, promulgated by Defendants and the media they control, is a factual impossibility, and a deliberate fabrication.

17. Second, as any detective knows, a major part of any investigation of any crime of this kind is to ask, cui bono? (who benefits?). A review of the facts concerning 9-11, and the enormous benefits (political, financial, and other) reaped by the defendants, shows that it is scandalous in the extreme that no highly-experienced, truly apolitical and independent prosecutor, fully supported with sufficient funding and staff — and armed with broad subpoena powers to compel sworn testimony from everyone from the President of the United States on down — has not been investigating this mass murder from the outset.

18. Third, the guilt of the defendants is compellingly suggested by their myriad lies, their thwarting of any proper investigation, and their stonewalling and failure to truly cooperate even with the “limited hangout” Commission “investigation” that culminated in the Final Report issued in July 2004. It is further confirmed as the most plausible, or even the only rational, explanation as to why the Bush Administration effected a massive reconfiguration of the federal government — conjoining many agencies into a new “Department of Homeland Security” - and then proceeded to starve it for funding, doing almost nothing to truly secure the homeland from terrorist threats from afar, while doing much to attack freedom at home, while and aggressively and unlawfully pursuing empire overseas.

19. While assuredly many individual employees of the FBI are loyal to their lawful responsibilities, and not individually part of the criminal enterprise herein alleged, it is a matter of public record, not disputed, that the Bush Administration had called the FBI off of its investigation of the bin Laden family in the months that preceded the attacks.

20. While one would expect that the City of New York would have an interest in thoroughly and honestly investigating the murder of more than 2,500 persons (to say nothing of the destruction of an appreciable percentage of the financial center’s “Grade A” office space) within its jurisdiction, agents of the Enterprise — acting through FEMA, a shadowy “black budget” agency created not by Congress but by Executive Order, and which combining largely secret martial-law preparations with benign, disaster-relief functions — were immediately in place. FEMA took and maintained strict control over the crime scene, and, with stunning dispatch, removed the principal evidence — the wreckage of the buildings — to Third World countries. Amazingly, there has been no homicide investigation by local authorities, who have primary jurisdiction, in New York City or in Somerset County, Pennsylvania (where Flight 93 is alleged to have crashed) or in Arlington, Virginia (site of the Pentagon, which allegedly was struck by Flight 77 on 9-11). Literally within hours of the attacks, the U.S. government and major media (largely under the indirect control of the U.S. government) had “solved” the crime, and “convicted” Osama bin Laden, allegedly the “black sheep” of a wealthy Saudi family having close financial and personal ties to the Bush family (and others of the Defendants), and 19 Arabs, 15 of them Saudis like bin Laden, who were quickly “identified,” even though all presumably perished in the attacks, there are no photos of any of them on the aircraft or in any of the airports from which the planes departed on 9-11, and the passenger manifests included none neither any of the alleged hijackers’ names (nor any names that appear to be Arab or suggestive of origins in any predominantly Muslim lands).

21. The Department of Justice [“DOJ”] has not, and will not, conduct a true investigation into 9-11. Indeed, again with a dispatch that defies belief unless Attorney General Ashcroft and others within the Department of Justice knew that a “new Pearl Harbor” was impending – the primary response of the DOJ was to muscle through Congress the grotesquely misnamed “Patriot Act.” That legislation, comprising hundreds of pages and amending dozens of existing laws, was passed by Congress without hearings, and without any but a handful of members having read it, or having even been provided with the text, before a vote called in the dead of night.

22. A few members of Congress, notably Senators Daschle (D-SD) and Leahy (D-VT), briefly resisted the “Patriot Act” with its many unconstitutional provisions. Messrs. Daschle and Leahy, however, were thereupon sent potentially fatal dosages of “weaponized” anthrax, from American stores. Congress has been mostly supine since.

23. Curiously, and little reported by the media, the first of the half-dozen fatalities in the October 2001 anthrax attacks was a tabloid newspaper photo editor from Florida, Robert Stevens. While most Americans probably believe to this day that these anthrax attacks were the deeds of radical Islamists – notwithstanding that all evidence points to domestic sources – whom had Mr. Stevens offended? The answer is that he had offended the Bush family, by selecting for publication in the supermarket tabloid that employed him an embarrassing photograph of the President’s daughter, Jenna Bush, appearing tipsy and holding a cigarette, while staggering across a dance floor with a female friend in a nightclub.

24. When former Senator Max Cleland (D-GA) left the “independent” 9-11 Commission and Senator Daschle had the opportunity to designate his replacement, he ignored thousands of e-mails urging him to name Kristen Breitweiser of New Jersey, a valiant, eloquent 9-11 widow with a law degree, and opted instead for former Senator Bob Kerrey (D-NE). The determination to cover up the truth was so complete, and so “bipartisan,” that not even one outsider, not one person directly injured by the attacks, not even the estimable (and, as it happens, Republican) Ms. Breitweiser could be brought into that sanctum in which “truth” is fabricated for the masses. While Mr. Kerrey has an impressive résumé (if one overlooks admitted war crimes during his military service in Vietnam) in recent times he has stood out as perhaps the most prominent Democrat to enthusiastically call for the invasion of Iraq, to “liberate” it from Saddam Hussein. Obviously, as 9-11 and contrived connections between 9-11 and Saddam Hussein led, in a direct line, to an invasion of that country, Mr. Kerrey, as a wholehearted supporter of the war, would be unlikely to stray from the course prescribed for the Commission – namely, to produce a “modified limited hang-out” acknowledging “failures,” while steering clear of investigating actual high-level U.S. complicity in the attacks. That Sen. Daschle named the avidly pro-war Mr. Kerrey to replace the Commission’s most (perhaps its only) skeptical and independent member, Mr. Cleland, suggests that the minority leader has been thoroughly sobered by his near-death encounter with U.S. Government anthrax.

25. In connection with the anthrax attempt on Senator Daschle’s life, the New York Times reported:
The dry powder used in the anthrax attacks is virtually indistinguishable in critical technical respects from that produced by the United States military before it shut down its biowarfare program, according to federal scientists and military contractor documents. The similarity to the levels achieved by the United States military lends support to the idea that someone with ties to the old program may be behind the attacks that have killed five people. Its high concentration is surprising, weapon experts said, and far beyond what military analysts once judged as the likely abilities of terrorists. The anthrax sent to the Senate contained as many as one trillion spores per gram. If a lethal dose is estimated conservatively at 10,000 microscopic spores, then a gram in theory could cause about 100 million deaths. The letter sent to Tom Daschle, the Senate Democratic leader, is said to have held two grams of anthrax. (Emphasis added).

26. Thus, neither the FBI, nor the Justice Department, nor the New York Police Department, nor Congress, nor the “independent” 9-11 commission has conducted a true and thorough investigation into exactly who killed almost 3,000 people on 9-11, and set in motion events that have brought about the deaths of more than 1,050 United States military personnel — with no end to the bloody war in Iraq in sight— and many thousands of Afghan and Iraqi citizens (to say nothing of incalculable property damage, much of which will ultimately be borne by American taxpayers, with companies that are members or friends of the Enterprise reaping vast profits from “rebuilding” that which was wantonly and unlawfully destroyed).

27. The supposedly “independent” 9-11 commission, apart from being headed by a blood relative of the President (Thomas A. Kean, upon information and belief a distant cousin) and comprised in large part of people with resounding conflicts of interest, has allowed the President and Vice President to dictate the terms of their testimony, and has tiptoed past the critical issues. As will be described, the “fix-is-in” Commission (to which tender hands the Administration acceded most reluctantly, and which it has sought to stonewall) has been created to produce a foreordained result: that while there may have been “intelligence failures” (for which no one has been, or is to be, held accountable), the attacks were planned and carried out by nineteen radical Islamists, under the leadership of Osama bin Laden, out of hatred for America and resentment over the American military presence in Saudi Arabia, its support of Israel, and its perceived opposition to Islam.

28. If it does not suffice to show the practical uselessness of the Commission to point to its membership, loaded with intelligence, military, corporate and other pro-Administration “insiders,” the narrowness of its mandate, and its deference in permitting persons who should be suspects from testifying under oath, the Commission’s final report was completed only in July 2004, whereupon “the White House [reviewed] the text . . . and could determine when the report will be released.” Thus — and to date plaintiff is aware of no howls of indignation from the Commission or the media — the persons plaintiff believes to be guilty for the 9-11 attacks, having appointed half of the Commission in the first place, has it well within its power to excise any damaging findings (in the name of “national security,” of course) and, had it so chosen, could have delayed public release of the Commission’s report until after the November 2004 presidential election. The Commission almost makes the Warren Commission look like a model of truth-seeking and alacrity. At least the Warren Commission required witnesses to be sworn.

29. Plaintiff has every expectation that this lawsuit will be met by attempts on the part of the enormously powerful members of the Enterprise to silence the Plaintiff — if not by more drastic measures, than at least by delay and obstruction to disclosure, in the name of “executive privilege,” “national security” and the esoteric “state secrets privilege.” If we do not live already in a de facto police state, there is no “privilege” that protects kidnapping, arson, and mass murder, or even gross misfeasance that permits attacks on the scale of 9-11. As for “national security,” even if plaintiff can be shown to be in error as to actual participation, sponsorship, and approval of the attacks on the part of senior Bush II Administration figures, the words “national security” should stick in these defendants’ throats. Having – at the very least -- failed so abjectly in their primary task, which is the protection of American lives, the Defendants must not be allowed to hide either their malfeasance or their misfeasance behind the curtain of “national security.” If the principal defendants were honorable individuals, most of them would have resigned for their abject failure to discharge adequately their primary duties to the nation. The lone high-level resignation since 9-11, that of Mr. Tenet, occurred more than 2-1/2 years after the event, and was not accompanied by any expression of contrition, or admission of failure or of wrongdoing.

30. In the more than three years since 9-11, most Americans, as indeed the entire world, have been made aware that the U.S. government and many of the defendants have been falsifying information about what knowledge they had of the dangers of attacks prior to 9-11, and fabricated a pretext to carry out a prior (pre-9-11) determination to attack and occupy Iraq, based on knowingly false claims concerning non-existent “weapons of mass destruction.” Not yet making the conventional news is that the Bush II Administration, despite the end of the Cold War more than a decade ago, plans (at enormous cost, of course) to “revitalize [America’s] nuclear weapons manufacturing infrastructure” and to build nuclear “robust nuclear earth-penetrator” warheads.

31. Although the idea of the United States government, or key elements of it, planning and carrying out terror attacks against American citizens on American soil may seem incomprehensible, there is documented precedent for a plot essentially the same as that alleged in this complaint. In the early 1960s, a plan code-named “Operation Northwoods,” endorsed in writing by all of the then-Joint Chiefs of Staff, envisaged the possible assassination of Cuban émigrés, sinking boats carrying Cuban refugees on the high seas, hijacking airplanes, blowing up a U.S. ship, and even orchestrating violent terrorism in U.S. cities. If plans such as “Operation Northwoods” could be proposed in earnest, at a time when Cuba was under the wing of a rival, nuclear-armed superpower, it should not be impossible to believe that the Bush II Administration — not constrained by the existence of any power corresponding to the USSR forty years ago — might consider similar plans to gain license to seize the second-largest known petroleum reserves on the planet, those of Iraq.

32. Against the criminals who have hijacked not just four airplanes but the government of the United States, and who have virtually unlimited financial and other resources at their disposal, stands a solitary American hero — whose valor shone brightly on that day, as defendants were flown hither and yon, and skulked in “undisclosed secure locations.” Plaintiff has continued to shine in his selfless, unpaid efforts to relieve the suffering of the victims, as the defendants have launched wars and inflicted measureless suffering, to benefit themselves and their cronies. Plaintiff, in the utmost good faith, alleges that there is much evidence that this happened, or at the very least was allowed to happen, to further the defendants’ imperial aspirations and their monetary greed, and (as no one in government has done their duty to investigate, expose and prosecute these crimes) this lawsuit may be the only peaceable means to reveal the truth.

33. Plaintiff, to say nothing of the people of the United States, whose security, democracy and freedom are in peril, must have a full, true and fearless accounting, wherever that path may lead. History at times casts unlikely candidates, often unwillingly, into situations in which it matters greatly that they summon all of their courage, all of their integrity, to take the path of truth and resistance to tyranny. Into that breach, William Rodriguez invites the judges before whom his action may come to join him.

RICO Complaint Part 4 here