34. The Court has jurisdiction over the action pursuant to 28 U.S.C. § 1331 (federal question), 18 U.S.C. § 1964 (RICO), 18 U.S.C. § 2333 (Anti-Terrorism Act of 1991), 28 U.S.C. § 2201 et seq. (Declaratory Judgment Act), 18 U.S.C. § 2441 (War Crimes Act of 1996), 18 U.S.C. § 4 (Misprision of Felony statute) and 18 U.S.C. § 2382 (Misprision of Treason Statute). Venue as to the several defendants is proper, pursuant inter alia to 18 U.S.C. § 1965(a) and/or 18 U.S.C. § 1965(b).

35. Plaintiff, William Rodriguez, is a resident of New Jersey who suffered personal injuries, severe and continuing emotional distress, and the loss of his employment of nineteen years, as proximate results of the 9-11 attacks on the WTC, and the acts of the defendants as herein alleged.

36. Defendant, George H. W. Bush is a private citizen with homes in Texas, Florida and Maine. Beginning in or about the mid to late 1950s, he was an agent of the Central Intelligence Agency (“CIA”), and was later a Congressman from Texas, Director of Central Intelligence, Vice President of the United States in the Reagan Administration (1981-1989), and President of the United States (1989-1993). He is currently an employee or paid consultant of The Carlyle Group, an investment vehicle which, generally described, affords investment opportunities, mainly in weapons manufacture and other war-related and government-regulated industries, to select former insiders of the Reagan and Bush I Administrations, former British Prime Minister John Major, and others. George H. W. Bush is the father of Defendants George W. Bush, John “Jeb” Bush, Neil Bush, and Marvin Bush.
37. George W. Bush is the President of the United States. Note that while many of the acts and omissions alleged in this complaint against George W. Bush and other defendants who are now, or who were at the time of the acts complained of, the holders of public offices (federal or other) and such acts and omissions were or may have been done under color of their official authority, plaintiff sues each of said defendants in his or her individual capacity or capacities only as to Counts “One” through “Eight” and Count “Eleven” of this Complaint, as the acts complained of were not within the scope of such defendants’ official duties, but were crimes and unlawful acts outside the scope of such duties, and plaintiff seeks recovery for the acts and omissions of each such defendant individually and from his or her personal assets, not against the government body that is (or was) such defendant’s employer at the time of the acts complained of.
38. John “Jeb” Bush (“Jeb Bush”) is the Governor of the State of Florida. He is a son of George H. W. Bush, and a brother of George W. Bush, Neil Mallon Bush, and Marvin Bush.
39. Neil Mallon Bush (“Neil Bush”) is a private citizen residing in Colorado. He is a son of George H. W. Bush, and a brother of George W. Bush, Jeb Bush, and Marvin Bush.
40. Marvin Bush is a private citizen residing in Florida. He is a son of George H. W. Bush and a brother of George W. Bush, Jeb Bush, and Neil Mallon Bush.

41. Richard Cheney (“Cheney”) is the Vice-President of the United States. He was formerly Secretary of Defense in the Bush I Administration, and a Republican Congressman from Wyoming.
42. Donald H. Rumsfeld (“Rumsfeld”) is the Secretary of Defense.

43. Dov Zakheim (“Zakheim”) was formerly Deputy Under Secretary of Defense for Planning and Resources (1985-87) and was later CEO of SPC International Corp., a subsidiary of System Planning Corp. of which he was corporate vice president. System Planning Corp. is noteworthy, among other things, in that it has been engaged on remote-control technology for aircraft, and another of its subsidiaries, Tridata Corp., headed the investigation into the attack on the WTC in 1993. Zakheim, a co-signer of the Project for the New American Century’s which statement that encouraged mentioned, longingly, a “New Pearl Harbor,” became Under Secretary of Defense (Comptroller), the CFO of the Pentagon, in May 2001. After 9-11, Zakheim took a lucrative position at Booz Allen Hamilton, another high-tech warfare and “homeland security” firm, whose website boasts of its “global presence” and “spotlight on next-generation outsourcing and offshoring.” Upon information and belief, Zakheim holds an Israeli passport as well as a United States passport.

44. Colin Powell (“Powell”) is the Secretary of State.
45. Richard Armitage (“Armitage”) is the Assistant Secretary of State.
46. Condoleeza Rice (“Rice”) is the National Security Advisor to President George W. Bush.
47. John Ashcroft (“Ashcroft”) is the Attorney General of the United States.
48. Robert S. Mueller III (“Mueller”) is the Director of the Federal Bureau of Investigation (“FBI”).
49. David Frasca (“Frasca”) is an employee of the FBI, and at times prior to 9-11, Frasca was in charge of the FBI’s so-called Radical Fundamentalist Unit.
50. George J. Tenet (“Tenet”) was formerly and at times hereinbelow mentioned (including 9-11) Director of Central Intelligence (of the Central Intelligence Agency [“CIA”]).

51. Porter Goss (“Goss”) has affiliations with the CIA dating back to the early 1960s. In recent years and as of 9-11, he was a Republican Congressman from the State of Florida. He is now the Director of Central Intelligence. For many years, he has been involved in dubious financial dealings with members of the Bush family, including the Destin Country Club group, Swissco Management, Topsail Development Ltd., and the Destin Dome development, among others. He is widely reported to have been a member of an illegal international CIA murder squad (which included other associates of George H. W. Bush, and persons who would become Iran-Contra figures) while still in his twenties, and among other disreputable things in his first CIA stint was involved in illegal efforts to maintain the Somoza regime in Nicaragua and later, to overthrow the Sandinista government of that country. Goss has also figured prominently, also, in suppressing the truth of extensive trafficking in illegal drugs, within and without the United States, by the CIA.

52. Norman Y. Mineta (“Mineta”) is the Secretary of the United States Department of Transportation (“USDOT”).
53. General Larry K. Arnold (“Arnold”) was Commander of the U.S. Central Command on 9-11.
54. Tom Ridge (“Ridge”) is the Director of the United States Department of Homeland Security (“USDHS”).
55. Mark Racicot (“Racicot”) is the Chairman of the Republican National Committee.

56. The Republican National Committee, Inc. (“RNC”) is the umbrella organization for all of the Republican Party organizations in the United States.

57. Alan Greenspan (“Greenspan”) is the Chairman of the Federal Reserve. As such, he is not an employee of the United States government, and is not entitled to be represented by attorneys of the U.S. Justice Department.

58. Thomas A. Kean (“Kean”) is the chair of the Commission, which purported to investigate certain matters related to the attacks of 9-11. The Commission released a final report on or about July 26, 2004.
59. Jamie S. Gorelick (“Gorelick”) is a member of the same Commission.
60. Phillip D. Zelikow (“Zelikow”) is Executive Director of the Commission.
61. John F. Lehman (“Lehman”) is a member of the Commission.
62. Fred F. Fielding (“Fielding”) is a member of the Commission.

63. Karl Rove (“Rove”), the legendary political “dirty trickster, works” works in the White House with the title of Senior Political Advisor to the President.
64. Richard Perle (“Perle”) is a private citizen, and a principal of the Project for the New American Century, Inc. (“PNAC”).
65. Paul Wolfowitz (“Wolfowitz”) is Assistant Secretary of Defense.
66. Richard Myers (“Myers”) is a General in the United States Army and Chairman of the Joint Chiefs of Staff. As of 9-11, Gen. Myers was Acting Chairman of the Joint Chiefs of Staff.
67. Ralph E. Eberhart (“Eberhart”) is a General in the U.S. Air Force. On 9-11, he was in charge of NORAD, a joint U.S.-Canadian military operation responsible for to protecting the skies of the two countries from enemy attack. Today, he is head of the “Northern Command” instituted after 9-11, making the United States a zone of anticipated future military operations, probably related to martial law and the suspension in whole or in part of the U.S. Constitution.

68. Kenneth R. Feinberg (“Feinberg”), as Special Master, headed the 9-11 Victims Compensation which Fund that was created by the Enterprise, among other things, to use public funds to deter lawsuits by family members of the persons killed on 9-11, and thereby conceal the truth concerning Enterprise sponsorship of the attacks.

69. Halliburton Company (“Halliburton”) is a private corporation engaged in, among other things, construction and oilfield services.
70. Kellogg Brown & Root (“KB&R”) is a subsidiary of Halliburton, and is engaged in, among other things, construction.

71. Election Systems & Software (“ES&S”) is a corporation that designs, manufactures and sells, among other things, touch-screen machines for recording and tabulating votes in elections.
72. Diebold Voting Systems (“Diebold”) is a corporation that designs, manufactures and sells, among other things, touch-screen machines for recording and tabulating votes in elections.
73. Walden O’Dell is a resident of Ohio, in which state he has acted as a leading fund-raiser for President George W. Bush and the Republican Party, and the CEO of Diebold.
74. Sequoia Voting Systems, Inc. (“Sequoia”) that designs, manufactures and sells, among other things, touch-screen machines for recording and tabulating votes in elections.

75. Chuck Hagel (“Hagel”) is United States Senator from Nebraska, and now or formerly the owner of a beneficial interest in ES&S. Conveniently, in both of the statewide elections in which Senator Hagel was elected and re-elected to his Senate seat, roughly 80% of the votes cast were recorded and tabulated on voting machines manufactured by ES&S — which is to say on voting machines made by the Senator’s own company.

76. Saxby Chambliss (“Chambliss”) is United States Senator from Georgia, to which office he was elected in November 2002 in a statewide election that was the first in which touch-screen voting machines, designed and manufactured by Diebold, were used to record and tabulate the votes cast throughout a state (the state in question being Georgia). Although lagging badly in the polls within days prior to the election, the votes as tabulated by Diebold made Mr. Chambliss, a right-wing Republican who did not serve in the Armed Forces during the Vietnam conflict, a surprise, upset winner over incumbent Sen. Max Cleland, a Democrat. Senator Chambliss, in addition to having the vote counted on machines manufactured by a company owned by right-wing Republicans and that left no “paper trail” as might permit a recount, relied heavily in his campaign on impugning the patriotism of Sen. Cleland, a triple amputee of the Vietnam conflict.

77. New Bridge Strategies LLC (“New Bridge”) is a business vehicle, established by and for the benefit of present and former officials and supporters of the Bush I and Bush II Administration, and intended to profit from business opportunities afforded to private investors in the United States owing to the overthrow of the Saddam Hussein regime in Iraq by U.S. military forces, the continuing presence of U.S. and other western troops in Iraq, and the planned installation and maintenance of permanent U.S. military bases throughout Iraq and a government having effective sovereignty to be limited by an ongoing large-scale U.S. military presence in Iraq.

78. Joe M. Allbaugh (“Allbaugh”) is the CEO of New Bridge. This lucrative position was, in part, a reward to Mr. Allbaugh for services rendered by him, in his former position as director of the Federal Emergency Management Agency [FEMA] in seizing control of the “Ground Zero” World Trade Center site, and seeing to the speedy removal to foreign lands of the debris from the collapse of buildings at the site, and obstruction of justice in keeping from the public and from local law enforcement proof concerning the manner and cause of the collapse of World Trade Center Buildings Nos. 1, 2 and 7.

79. James A. Baker III (“Baker”) is at present a private citizen, and a partner of the law firm of Baker & Botts LLP in Houston, Texas. Formerly, he was Chief of Staff and Secretary of State during the Presidential administration of George H. W. Bush. Among other accomplishments, Mr. Baker boasts of having been the man who “fixed Florida” for George W. Bush and Richard B. Cheney after the 2000 presidential election.

80. John Sweeney (“Sweeney”) is a Republican Congressman from New York. Upon information and belief, on behalf of the Bush-Cheney 2000 Campaign and the RNC, he dispatched persons to cross state lines, using the means of interstate commerce, to intimidate local officials endeavoring to recount votes cast in Florida in the 2000 presidential election, and thereby to commit extortion as defined under the statutes of the State of Florida, and predicate acts under the RICO statute.

81. Thomas Pyle (“Pyle”), Garry Malphrus (“Malphrus”), Charles Royal (“Royal”) and Kevin Smith (“Smith”), on information and belief, who were paid by the RNC or by the Bush-Cheney 2000 Campaign to travel across state lines, using commercial airlines or other means of transit in interstate commerce, to intimidate local officials endeavoring to recount votes cast in Florida in the 2000 presidential election, and who participated in the so-called “Brooks Brothers Riot” which was intended to, and did, coerce and intimidate such officials and caused them to cease their attempts to recount votes. Although guilty of membership and participation in the Enterprise, and the commission of crimes that are predicate acts under the RICO statute, the defendants named in this paragraph are not believed by plaintiff to have had foreknowledge of, or to have sponsored, planned, carried out or participated in, the attacks of 9-11.

82. Defendant, United States of America is the federal government. It is named herein as a Defendant only as to those counts of the Complaint that do not arise under RICO, 18 U.S.C. §§ 1961 et seq.
83. The United States Department of Homeland Security is a cabinet-level agency or branch of the United States Government. It is named herein as a Defendant only as to those counts of the Complaint that do not arise under RICO, 18 U.S.C. §§ 1961 et seq.
84. The Federal Emergency Management Agency [“FEMA”], prior to 9-11, a separate agency, was later merged into the Department of Homeland Security. It is named herein as a Defendant only as to those counts of the Complaint that do not arise under RICO, 18 U.S.C. §§ 1961 et seq.
85. The “Doe” Defendants are persons and entities, not identified by name, who participated as principals, co-conspirators and/or who aided and abetted and/or who were accessories to acts committed by other Defendants.

86. The “Enterprise” alleged herein is not fully coextensive with the United States (that is, the federal government, its officers, agencies and instrumentalities) which, for the most part, is comprised of well-meaning civil servants. The “Enterprise” does, however, embrace all of the other defendants, and the United States to the extent that the latter, its officers, agencies and instrumentalities are controlled by defendants individually named, and other persons not named who act in concert with and on the instructions of named defendants, and have (acting by, through or at the direction of senior officials) served as instrumentalities in the planning, sponsorship, funding, provision of the means to carry out, execution, and concealment of RICO predicate acts alleged in this complaint, and in secreting or destroying evidence, intimidating and killing possible witnesses to or concerning predicate acts, suborning perjury and breach of duty and providing knowingly false information to Congress, the Commission, the media and hence to the public concerning 9-11 and other predicate acts, and have acted to delay, hinder, prevent and obstruct the carrying out of a true, complete, apolitical, adequately funded, and bona fide investigation of 9-11, intended not to conceal the truth and promulgate a knowingly false depiction intended to appease the public and survivors’ families — which is, manifestly, the function of the Commission — but to determine justly the facts of the occurrences, and to bring the guilty parties to justice.

87. All of the Defendants, including the “Doe” Defendants and additional persons not known to the Plaintiff [but excluding, nevertheless, the United States and its agencies, including the Department of Homeland Security, to the extent described in the last preceding paragraph] together comprise an “Enterprise,” as such term is used in the RICO statute. The objectives of the “Enterprise” include, but are not necessarily limited to, the following:
To enrich members and associates through the commission of multiple crimes, including predicate crimes under the RICO statute (e.g., murder, arson, kidnapping, extortion, wire fraud, interstate travel in promotion of racketeering) and other grave felonies, including but not limited to wars of aggression and crimes against humanity that are condemned under international law; the rigging of elections, the bribery of members of Congress, foreign officials, and others, obstruction of justice, trafficking in weapons and narcotics, and the corruption of various agencies and instrumentalities of government to carry out and to cover up the foregoing and other crimes.

To advance the interests of certain corporate entities — especially those in the oil, energy services, and weapons industries, in which a number of the individual defendants are heavily invested;
To use both political control and the giving and withholding of favors (e.g., approval for mergers and relaxation of FCC rules limiting common ownership of media outlets) to induce major media outlets and media celebrities to fail to report, or to under-report, matters unfavorable to the Enterprise and its members, or as might incite further inquiry, and thereby disclose unlawful acts committed by them, and to manage and control public opinion for the benefit of the Enterprise and its members;
To strengthen and perpetuate Enterprise and U.S. control, direct and through client governments, of petroleum, natural gas, and other natural resources in the Middle East, Central Asian republics, and throughout the world;
To cause the United States to wage war as widely and as frequently as possible, consistent with the objective of avoiding any large-scale exchange of nuclear and other “weapons of mass destruction,” in part to achieve external ends (control of petroleum resources, the overthrow of insufficiently servient foreign governments) and in part for its own sake, since war profiteering, and investments in arms manufacturing and other war-related companies, being are major sources of Enterprise money and influence;
To develop and — by the overthrow of competing governments, and the murder of prominent scientists — to achieve and to maintain a monopoly on a variety of biological and chemical weapons, and the means of delivering them, notwithstanding that the development and use of such weapons are crimes under international and domestic law;
To supplant multi-party, representative democracy having a Bill of Rights and checks and balances with a regime insulated from removal, by elections or otherwise, using raw, arbitrary power, aggressive abroad and despotic at home;
To establish de facto one-party (Republican Party) rule at the national level in the United States, with all other parties reduced to the status of impotent “window-dressing”;
To perfect the “merger of political and corporate power” (the definition of fascism given by Benito Mussolini, an authority on the subject) if possible covertly, among other means by rigging of elections, the control of judicial appointments, influence over major media suppressing reporting of Enterprise activities; the exploitation of the fear of terrorism, the exaggeration of the threat posed to America and its citizens by foreign terrorists (including, but not limited to, the staging of terror attacks against Americans that are then blamed on foreigners), and the increased militarization of society (e.g., the “War on Terror” and planned re-institution of military conscription) and suppression of dissent and Constitutional rights (through the “Patriot Act” and other legislation, enacted with little or no publicity);

To complete, also under the guise of “homeland security,” the “war on terrorism,” and largely under the auspices of FEMA, an unelected, extra constitutional and impregnable “shadow government” of far-right interests, as well as preparations for martial law as a backup to the preferred means of achieving virtually absolute power (including the power, already inchoate in the “Patriot Act,” to imprison American citizens indefinitely, without charges and without the right to counsel, and even to kill American citizens at the unreviewable direction of the President);
To disarm the civilian population of the United States, or such elements thereof as are deemed to be unfavorable to the Enterprise, via gun-control legislation and, in the future, the confiscation of firearms and other weapons and ammunition;

To markedly reduce the living standards of approximately 80% of the population of the United States, among other means by the subsidized exportation of most better-paying jobs to low-wage countries that do not have free labor unions, environmental standards, and human rights protections; by bankrupting and, over time, abolishing Social Security, Medicaid, and Medicare; by shifting the burden of supporting the federal government through the income tax to the upper-middle class, while conferring enormous tax reductions on the extremely wealthy; by slashing federal and other public support to a host of social programs that benefit the middle and lower classes; and by permitting large numbers of immigrants to enter and remain in the United States, with the threefold objectives of (1) depressing wages; (2) fomenting conflict between native-born, low and middle-income Americans on the one hand, and immigrants on the other hand; and (3) creating a class of persons who, owing to the threat of discovery of their undocumented status and their fear of deportation, can readily be exploited;
To use martial law and the threat of martial law – already openly enunciated by General Tommy Franks in 2003 – to intimidate and marginalize dissenters;
To advance “American” interests – more truly, the interests of the Enterprise and corporate interests within and without the Enterprise that are favorable to it – by means both covert (e.g., the “destabilization” of disfavored regimes, such as was recently effected in Haiti and is underway in Venezuela, by CIA and other Enterprise vehicles) and overt (by the kidnapping [e.g., President Aristide of Haiti] and murder [e.g., President Allende of Chile] of foreign leaders, the invasion of countries under various pretexts [e.g., Afghanistan, Iraq] and the installation of servient regimes);
To augment the “black” budgets of the CIA, FEMA, and other government Enterprise vehicles (i.e., the federal funds appropriated under cover of Defense and other programs, but without meaningful review by Congress, and used largely for assassinations, the undermining and overthrow of foreign governments, the payment of bribes to foreign governments and politicians, and other crimes) by black market trafficking in weapons and narcotics worldwide;
To reward financial donors, agents, and persons aiding and abetting their unlawful acts with political patronage, employment with companies controlled by, or friendly to, the Enterprise, government contracts, and other benefits;
To slander, intimidate, silence and, if need be, murder persons — including loyal United States citizens, not guilty of any crimes — who disclose or threaten disclosure of Enterprise activities, or information tending to discredit major Enterprise actors.

88. The essence of Plaintiff’s complaint is that a classic RICO “Enterprise,” having gained control of key offices and instrumentalities of the United States government (including semi-Constitutional “black ops” organizations, such as the CIA and FEMA) and the Armed Forces, are guilty of (among other crimes that are “predicate acts” under RICO) kidnapping, arson, and murder including, but not limited to, the carrying out of the 9-11 terror attacks that resulted in the death of nearly 3,000 persons.

89. As will be described in more detail below, Plaintiff alleges that in carrying out, or causing the air defenses of the United States to “stand down” so as to ensure the success of the 9-11 attacks, the motives of the Enterprise included (but were not necessarily limited to) the following:
To create and to maintain a climate of fear throughout the United States;
To create and to maintain a climate in which neither the public, the media, nor Congress would resist or consider critically plans already made in secret to launch military attacks on Afghanistan and Iraq;
By military action in Afghanistan, to secure a right-of-way for a natural gas pipeline, for the benefit of private interests related to the Enterprise;
To benefit Kenneth Lay – the largest contributor to the Bush II presidential campaign – and Enron Corporation, both by diverting public attention away from the crimes committed by Enron executives and, if possible, to enable Enron to avoid bankruptcy by helping to rescue Enron’s troubled facility in Bhopal, India;
By deposing the conservative Muslim clerics of the Taliban, to reverse the clerics’ suppression of opium cultivation in Afghanistan;
By restoring large-scale opium production in Afghanistan, to re-establish markets of opium and heroin trafficking that directly benefit CIA and others’ “black ops,” and the vast proceeds of which are deposited to financial institutions, thereby directly and indirectly benefiting the Enterprise (certain of whom, notably Jeb Bush and other members of the Bush family, upon information and belief, are intimately involved with laundering drug and other criminal proceeds of Enterprise activities, for which they are compensated with deposits to offshore accounts controlled by them);
By overthrowing Saddam Hussein’s regime in Iraq, to remove a perceived threat to the government of Israel;
By overthrowing Saddam Hussein’s regime in Iraq, to obtain by force access to permanent military bases on Iraqi soil. (Retired Gen. Jay Garner, who was in charge of planning and administering postwar reconstruction from January through May 2002, stated that “[O]ne of the most important things we can do right now is start getting basing rights with [the Iraqi authorities]” and compared Iraq with the Philippines, which served the U.S. Navy as a “coaling station” around the turn of the 20th century. “That’s what Iraq is for the next few decades: our coaling station that gives us great presence in the Middle East.”)

By overthrowing Saddam Hussein, establishing permanent military bases in Iraq, and installing a government which, however the same might be adorned with trappings of “democracy” and “sovereignty,” would lack effective sovereignty, given limits on its power, a de facto U.S. veto over its acts and appointments, provisions being imposed to exempt U.S. civilian and military personnel from liability for crimes, including murder, torture, war crimes, crimes against humanity, and the spoliation of the environment resulting from, among other things, the use of depleted uranium-containing munitions, and the ongoing presence of hundreds of thousands of heavily armed U.S. and other “coalition” forces on its territory;
To ensure access to — indeed, control of — the petroleum of Iraq, constituting the second-largest known reserves of any country (after Saudi Arabia);
To eliminate or reduce any U.S. military presence in Saudi Arabia, (a sensitive issue especially given the precariousness of the Saudi rulers’ political situation in difficult economic times, and a source of particular resentment amongst Muslims, due to the location of the holy sites of Mecca and Medina in the Saudi kingdom) by taking, in effect at gunpoint, long-term basing rights in Iraq;
To create political and military pressure against Iran through a substantial and ongoing U.S. military presence in Afghanistan and Iraq;
To carry out one or several projected “regime changes” as advocated by Wolfowitz and other “neo-cons,” and envisaged in the manifesto of the Project for a New American Century;
To create a political climate (fear and uncritical patriotic fervor) favorable to the passage of unconstitutional legislation included in the “Patriot Act,” and tolerance for extensive surveillance and the suppression of dissent;
To increase military and related spending at the expense of U.S. taxpayers, while the wealthiest Americans receive unprecedented tax cuts;
By increases in military spending, to conceal misappropriation of monies already appropriated for that purpose, and to bring about the award of large, mostly “no-bid” contracts to Halliburton, Brown and Root, various corporate “armies” (mercenaries) and contractors favorable to the Enterprise;
To efface from the consciousness of the public the revelations made by Defense Secretary Rumsfeld shortly before 9-11 that roughly one-fourth of the nation’s vast military expenditures are disappearing, and cannot be accounted for;
To keep from widespread public attention that Federal Reserve Chairman Alan Greenspan, and financial institutions extensively tied to the Enterprise, were accused of manipulating the price of gold over a period of years, concealing their acts and, and lying about it;
To destroy records maintained in the World Trade Center offices of the FBI, SEC, and other government agencies of investigations into the burgeoning (but since unnoticed) gold price-fixing scandal, and possible crimes committed in connection therewith, as well as literally thousands of other corporate scandals under SEC investigation;
To enable persons connected with the Enterprise to reap millions in profits from short sales and put options on stocks of companies including the affected air carriers (American and United) and companies based in the World Trade Center;
To create and to maintain the illusion of George W. Bush, a corruptly-installed President with an under-reported history of serious, long-term alcohol and cocaine abuse, whose successes in life had been attributable to amiability, amorality, and family connections, as a “strong leader” in a phony “war against terrorism,” a significant part of such “terrorism” to be created by the Enterprise itself;
To distract the attention of voters and financial markets from corporate scandals, a stock market that dropped approximately 900 points just in the three weeks immediately preceding 9-11, the outsourcing of American jobs to foreign countries, outrageous favoritism benefiting the very rich, and disastrous environmental policies;
To distract public scrutiny away from the Cheney energy-policy group and its formulating energy policy for the Bush II Administration as a virtual “wish-list” for the fossil fuel companies;
To reward Larry Silverstein, the principal of Silverstein Properties (lessee of the World Trade Center) and friend of Rupert Murdock (right-wing media baron, and ardent Bush supporter) for his aid and assistance in effecting and concealing the crimes involving the destruction of the World Trade Center, by conspiring to commit a multi-billion dollar insurance fraud, redounding to Silverstein’s benefit;
To prepare for future, even more odious operations (the launching of wars overseas, possible martial law and wide-scale extra-judicial detentions and killings within the United States) by testing the extent to which the “mainstream,” corporate-controlled mass media will fail to report, or will under-report, information concerning crimes committed by the Enterprise, or otherwise unfavorable to the Enterprise and its principals;
By carrying out a relatively small-scale operation that, while disguised for public consumption as an act of “Islamic terror,” would be recognized by senior government and military figures as what it was — treason and mass murder — thereby permitting the Enterprise to further corrupt the government and the military, drive many government employees and military officers loyal to the Constitution and not approving of the attacks into retirement, and allowing the Enterprise to identify, isolate and neutralize dissenters in sensitive positions, in anticipation of later, larger operations yet to be carried out.

90. In light of the extraordinary character of the allegations and the identities of the Defendants, plaintiff sets forth below, in abridged form, some of the facts that reveal the implausibility of the Official Story of “9-11.”

RICO Complaint Part 6 here