Justice for 9/11 Solidarity Petition


and print


(Oct. 28)




of all


Original Complaint of 10/28/04
(This has been superseded by the amended and restated 
Citizens' Complaint and Petition of 11/19/04.)

The following Complaint and Petition
was submitted today, October 28, 2004
by 20 Petitioners and 5 Signatories

By hand to William Casey
Chief Investigator

Office of the Attorney General
of the State of New York
120 Broadway, New York City

See signatories
(scan of signature page.)







OCTOBER 28, 2004



Sponsored by:


Justice for 9/11 Steering Committee


Comprised of Representatives from



9/11 Citizens Watch

World Trade Center Environmental Organization





Citing probable cause for convening an

independent grand jury or conducting an independent

investigation by other means

to examine the crimes of September 11th, 2001


requesting a hearing before the appropriate authorities regarding the same



Submitted to:

Office of Attorney General Eliot Spitzer

120 Broadway
New York City, NY 10271
(212) 416-8000

Thursday, the 28th of October, 2004

On behalf of the complainant signatories below, the millions of New Yorkers who also call for a fearless independent inquiry, residents of and workers in New York, most particularly in and near "Ground Zero," and other Americans who have lost employees, friends and family members as well as health, business and personal assets and civil, privacy and other rights in the 9/11 aftermath, we approach your office as the representative of the people for achieving truth and justice with respect to the treacherous events of September 11, 2001 and, where fault and liability is found, recovery of the billions of dollars of resulting damages that have been sustained and continue to accrue.

As reported to your office, a representative poll published by Zogby International on August 30 of this year found that 49% of New York City residents and 41% of New Yorkers overall believe there was official foreknowledge and conscious acceptance of the 9/11 attacks, and that 66% of city residents and 56% overall want a new investigation. These findings are stunning and provide conclusive evidence that the People of New York are not satisfied that official investigations and news media have adequately addressed the truth of the events of that fateful day. Nearly half of New Yorkers believe that serving US leaders deliberately permitted the killing of thousands of Americans by foreign enemies. If that is the case, the responsible officials would be guilty of both mass murder and treason, as well as conspiring to inflict untold suffering upon the people of New York and violating a host of New York State laws, in addition to federal terrorist, treason and other laws. However, no independent official investigation into these alarming, recurring and evidentially plausible allegations has ever been held or is now contemplated.

When citizens of New York widely suspect appalling criminal activity within our government and by bad actors doing business in the State of New York, activity that has caused us grievous harm, we believe we are well within our rights as sovereign citizens to demand the legal and investigative means to address these concerns. We were therefore deeply inspired to read the Attorney General's 2002 Law Day address on the critical importance of restoring public trust in our principal institutions. You focused then on financial markets, charities, and churches, but we believe your words aptly address the collapse of faith in government that the Zogby poll reveals today:

It is important that we understand that this crisis exists, that it has already damaged important institutions, and that we must take immediate action to restore the faith of a betrayed public… The process of restoring a shattered trust is a lengthy one. Unfortunately, we do not have time to wait… Too much will be lost during the time that this process naturally unfolds; the skepticism and distrust that exists will continue to exact a tremendous cost… Our system of law can provide - indeed, can itself be - the solution to the crisis created by the betrayal of their trust.

And that is precisely why we request your intervention, to swiftly investigate the grave concerns outlined below, enforce accountability, and restore the public trust.

As Attorney General, you hold ultimate responsibility for enforcing public safety, criminal and investor protection laws in the State of New York. As noted in the aforementioned poll, a clear majority of your constituents desires a full investigation of "still unanswered questions" either by Congress or your office. Since Congress has shown itself incapable of such an inquiry, we turn to you to take up the case we put forth in this Complaint and Petition. We therefore respectfully request that you immediately invoke your powers to open one or more urgent investigations, by your office alone or in conjunction with other state and local legal and enforcement offices with jurisdiction (which might include, for example, other state attorneys general and the Office of the District Attorney, Robert Morganthau) into apparent crimes before, during and after September 11, 2001. We are fully prepared to show probable cause for this complaint, and to present the necessary facts and lines of inquiry to lead reasonable persons to believe that numerous still unsolved crimes have taken place.

In this Complaint we submit compelling evidence constituting probable cause that some or all of the following crimes and possible additional crimes have been committed and that you have jurisdiction and prosecutorial discretion to investigate and prosecute the perpetrators of such crimes: murder, criminally negligent homicide or manslaughter; assault; reckless endangerment; official misconduct; criminal offenses relating to public safety; enterprise corruption; obstruction of justice and the infliction of emotional distress, untold suffering and billions of dollars in damages on the citizens, businesses and institutions of and upon the State of New York itself and cities, counties and other jurisdictions within New York, and the criminal facilitation or solicitation thereof and conspiracy or accessorial conduct in connection therewith. We submit that evidence exists to suggest that the requisite state of mind exists, one of negligence where appropriate to assign civil liability, one of an intentional, knowing or reckless state of mind to assign criminal charges.


Online version of this Complaint at
www.justicefor911.org (10/29/04)

Annotated with hyperlinks to supporting documents and news reports






Signatures of Complainants

Appendices to Part I and III

1. "Taxonomy of Damages Resulting From September 11"

2. New York State Assembly Economic Report: "New York City and September 11"

3. "Zogby International 9/11 poll and New York Legislator Survey Ė Results"

4. Members of the Family Steering Committee for the 9/11 Independent Commission: "FSC Questions to the9/11 Commission, with ratings of its performance in providing answers"

5. 9/11 Citizens' Watch: "Questions to the Kean Commission, Mar 2003"

6. "A Brief History of the Kean Commission"

7. "The 9/11 Omissions Hearings" (Index)

8. "Certain States' Interests in 9/11"

Appendices to Part II:

Lists bodies of evidence giving rise to suspicions

Leading lines of inquiry (included herein):

A1. Air defense on 9/11

A2. Chain of command

A3. Pakistani ISI

A4. Indicators of international insider trading based on foreknowledge

A5. Collapse of Seven World Trade Center

A6. Anthrax attacks

B. Categories of inquiry that may yield useful investigational information

(Submitted online only as growing dossiers at Justicefor911.org)

B1. Hijacker oddities

B2. Obstruction of investigations prior to 9/11

B3. Indicators of foreknowledge

B4. Obstruction of investigations after 9/11

B5. Context of war planning prior to 9/11

B6. Taxonomy of potential beneficiaries from 9/11 events

B7. Context: History of U.S. policy and covert networks

B8. Context: Precedents for facilitated terror and false-flag operations internationally


Also submitted in support of this Complaint:

"The 9/11 Omissions Dossier - Online Edition," a compendium of studies on some of the subjects covered herein (www.911Truth.org/dossier).

Books and reports:

The Terror Timeline (Paul Thompson and the Center for Cooperative Research, 2004)

The New Pearl Harbor (David Ray Griffin, 2004)

Crossing the Rubicon (Michael Ruppert, 2004)

"The 9/11 Omission Report" (9/11 Citizens Watch, 2004)

The 9/11 Commission Report: Omissions and Distortions (David Ray Griffin, 2004, publisher's draft)

Film documents:

The 9/11 Omissions Hearings, New York City, September 9, 2004 (9/11 Citizens Commission)

The Great Conspiracy: The 9/11 News Special You Never Saw (Barrie Zwicker, 2004)

Hijacking Catastrophe: 9/11, Fear, and the Selling of American Empire (The Media Education Foundation, 2004)

Additional websites submitted in evidence:

"The Complete 9/11 Timeline" ed. Paul Thompson


wtc7.net (Specifically the sections on the collapse of Seven World Trade Center)

"September 11th and the New World We Live In" ed. Michael Ruppert (www.fromthewilderness.com/free/ww3/index.shtml)

"Crimes Against Humanity" ed. David Ratcliffe (www.ratical.org/ratville/CAH)





A. The 9/11 attacks caused unprecedented damage to the lives, property and livelihoods of New York residents. According to the most recent database at www.september11victims.com, used as a source by the government-appointed National Commission on Terrorist Attacks Upon the United States (known variously as the "9/11 Commission" or "Kean Commission"), there were 2,996 confirmed or reported decedents as the result of the September 11 attacks - 2,626 dead or missing at the World Trade Center, 125 at the Pentagon and 245 on the four flights. Risk and security analysts estimate life insurance, worker's compensation, property damage and business/rental interruption costs at $55-70 billion, including $32 billion in documented insurance losses alone. In addition, the airline "bailout" package by the federal government is estimated at $2 to 5 billion. This is in addition to vast economic damages following from the attacks (see Appendix 1: "Taxonomy of Damages Resulting From September 11" and Appendix 2: New York State Assembly Economic Report, "New York City and September 11").


B. The people of New York are deeply dissatisfied with official investigations to date, including the Kean Commission report. The Zogby poll (see, Appendix 3, "Zogby International 9/11 Poll and New York Legislator Survey -- Results") found that only 36% of New York State residents believe the Kean Commission answered "all of the important questions about what happened on September 11, 2001." An ongoing survey of New York city, state and federal legislators by radio station WBAI has so far found that 14 members of the State Senate, State Assembly and New York City Council and two members of the New York Congressional delegation support the popular call for reopening the investigation, nine of whom selected the Office of the State Attorney General as the most effective venue today for getting to the truth of 9/11.

C. Reasons for filing a complaint demanding that an independent, in-depth investigation and/or grand jury be convened:

1. No serious official investigation, independent or otherwise, has yet been convened in connection with the murder in New York City of 2,772 citizens of the United States and more than seventy other nations. The majority of the nearly 400 questions submitted for investigation to the Kean Commission by the September 11 victims' families who lobbied the inquiry into existence were not even addressed in "The 9/11 Commission Report," the panel's final and "definitive" account. (See Appendix 4, Family Steering Committee for the 9/11 Independent Commission: "FSC Questions to the 9/11 Commission, with ratings of its performance in providing answers.") Of the 9/11 Family Steering Committee ("FSC") questions the Kean Commission did address, most were answered only partially or cursorily without touching the deeper issues they were meant to explore. This was despite assurances from Commissioner Jamie Gorelick at the opening hearing that the families' questions would serve as the "road map" for the investigation to come. A large majority of the "unanswered questions" from the 9/11 Citizens' Watch website, submitted to the Kean Commission during the same hearings in March 2003, was similarly ignored (see, Appendix 5, 9/11 Citizens' Watch: "Questions to the Kean Commission, Mar 2003"; for point-by-point analysis of evidence addressed and not addressed by the Kean Commission; see also, Griffin, 9/11 Commission: Omissions and Distortions, publisher's manuscript).

2. With the exception of two early hearings (on terrorist financing and building collapses), Congressional hearings were limited to the Joint Inquiry of the Congressional Committees on Intelligence, ("Congressional Joint Inquiry") convened in the summer and fall of 2002. After an agreement with then Senate Majority Leader Tom Daschle, the subject matter of this inquiry was limited to intelligence "failures." During the Congressional Joint Inquiry, the FBI, a subject of the inquiry, initiated an investigation of Senate committee members for an alleged security leak and made an unprecedented demand that members of Congress submit to lie-detector tests. Senator John McCain said, "What you have here is an organization compiling dossiers on people who are investigating the same organization." Another senator told the Associated Press that the FBI is "trying to put a damper on our activities and I think they will be successful" (The Washington Post, 8/3/02 and 8/24/02; Associated Press, 8/29/02). About one-quarter of the "Report of the Joint Inquiry Into the Terrorist Attacks of September 11, 2001" was redacted by the Administration and CIA on National Security Act grounds -- including an entire 28-page chapter and eight glossary items, implicating unnamed organizations or government agencies. If criminal laws were violated by officials or other private interests and such actions suppressed evidence of the violations, the actions could constitute obstruction of justice.

3. The mission of the Kean Commission, which was created only after 14 months of pressure from September 11 victim families, was strictly limited to exclude allegations of official criminality. (Vice Chair Lee Hamilton said, "The focus of the Commission will be on the future. We're not interested in trying to assess blame. We do not consider that part of the Commission's responsibility.") Many of its members and staff, including Executive Director Philip Zelikow, have striking conflicts of interest (see, Appendix 6, "A Brief History of the Kean Commission"). Its resources were limited; only $3 million was allocated initially, increased, against White House resistance, to just $15 million (compared to the immediate $30 million appropriation for the Challenger crash investigation and the $60 million allocated for the Clinton Whitewater inquiry). According to numerous complaints from commissioners, including but not limited to Sen. Max Cleland (who ultimately resigned and was appointed to the Ex-Im Bank board), the Administration and its subordinate agencies repeatedly obstructed, stalled, and restricted their investigations, opposed a two-month time extension, and demanded ultimate content approval of the final report -- which was published without the redactions normally used to show suppressed content. Such actions may constitute violations of New York State and federal laws.

4. The National Transportation and Safety Board ("NTSB"), required by Congressional mandate to investigate airline disasters, was preempted by the FBI, leaving NTSB as a mere "technical advisor" due to the fact that a crime was deemed to have been committed. No public reports on the aviation disasters of September 11 have been released by either the NTSB or the FBI and there appear to be no efforts underway to reconstruct the destroyed airplanes, as is the usual practice in airline crash investigations conducted by the NTSB. To the contrary, reports from residents of the Shanksville, Pennsylvania area indicate that disaster debris is still being found at this writing.

5. All official investigations assumed these basic premises, which are in doubt in the minds of many familiar with the official story and conflicting or additional evidentiary materials:

a. The 9/11 plot intended the hijacking of no more than four planes, which were commandeered and flown by 19 Middle Eastern hijackers. Their identities were resolved conclusively in the hours and days after the attacks, and have never since been in doubt.

b. The 9/11 plot was set into motion and financed by a network surrounding Osama bin Ladin, without direct financial backing from his wealthy family or other Saudi agents, and without the participation, involvement, accessorial conduct or knowledge of any states or state agents, either foreign or domestic, prior to or during the plot's execution.

c. No U.S. officials could possibly have had actionable foreknowledge of the plot, for if they did they would not have consciously failed to intervene.

d. Investigation into the actions and behavior of U.S. government agents and Administration officials could not possibly uncover any greater level of culpability than unintentional failures of intelligence, communication or surveillance; or at worst individual incompetence or negligence. Since questions of foreknowledge, acquiescence or accessorial criminality were never to be contemplated by the Kean Commission, its investigations could be supervised notwithstanding the conflicts of interest by Executive Director Philip Zelikow, a former high-level adviser to the present Bush Administration and virtually every other member of the Kean Commission (see, Appendix 6).

e. Suppression of relevant facts regarding 9/11 has been an undeniable necessity of national security; no elements within the U.S. government or Administration would exercise pressure or influence to avoid certain avenues of investigation or bodies of evidence in the probes carried out by the Justice Department, Congress, the National Institute for Standards and Technology (NIST), The Federal Emergency Management Agency (FEMA), and the Kean Commission.

f. No reports from foreign governments, agencies or news services alleging facts directly contradicting those set forth by official U.S. sources need be examined or explored.

g. The catastrophic collapses of the World Trade Center's North and South Towers were entirely due to the plane strikes and fire.

h. WTC Building 7 was the first steel-beam skyscraper in history to collapse solely from the effects of fire.

i. The anthrax poisonings and attempted poisonings of elected representatives and media figures were carried out by an as-yet unidentified lone scientist without the knowledge or support of any state agency or agents. Moreover, these rogue attacks had no coordination or connection to the 9/11 plot, did not influence any 9/11 inquiries, and did not appreciably affect the post-9/11 balance of domestic political power.

6. The FEMA investigation of the building collapses drew no meaningful conclusions. The subsequent investigation by NIST began with an open call for video and photographic evidence, because the relevant physical evidence (e.g., steel beams from the collapse zones) had already been scrapped.

7. All formal investigations have started with the premise that the "official story" presents an accurate, objective outline of relevant occurrences on and preceding 9/11, despite the rapid accumulation of evidence that the official accounts (some of which contradict each other) cannot possibly explain the events as they transpired. The effect of this unwarranted presumption has been to exclude critical lines of inquiry and bodies of evidence from the outset.

8. Extensive and crucial sections of the Kean Commission's findings and consequent conclusions are based on uncorroborated interrogation reports channeled from captive government suspects such as Khalid Sheikh Mohammeed, Ramzi Binalshibh and Abu Zubaydah, who were never made available for questioning by the Commissioners, staff or any Kean Commission representative.

9. A variety of citizens' groups, researchers and journalists have attempted to conduct what investigations they can and have demanded reevaluation of questionable evidence:

a. Website-based and ad-hoc citizens' efforts such as 911Truth.org, 9/11 Citizens Watch, the international citizens' inquiries held in Germany, San Francisco, Toronto, etc. (all accessible from www.911Truth.org).

b. September 11 victims' family groups such as the Family Steering Committee for the Independent 9/11 Commission, Peaceful Tomorrows (www.voicesofsept11.org), the Skyscraper Safety Committee (www.skyscrapersafety.org) and others.

c. A veteran officials' group involving FBI whistleblower Sibel Edmonds, retired CIA analyst Ray McGovern, and 25 former intelligence and law enforcement employees, facilitated by Daniel Ellsberg's Truth-Telling Project (www.thetruthtellingproject.org) and the Project on Government Oversight (www.pogo.org).

d. Writers and journalists devoted to research, too numerous to list comprehensively but including Michael Ruppert (www.fromthewilderness.com), author of Crossing the Rubicon (2004); David Ray Griffin, author of The New Pearl Harbor (which has been translated into multiple languages) and the soon-to-be released manuscript The 9/11 Commission Report: Omissions and Distortions, provided with this complaint; The Center for Cooperative Research (www.cooperativeresearch.org), home of the "The Complete 9/11 Timeline" by Paul Thompson, now in book form as The Terror Timeline (Harper-Collins, 2004); The Center for Research on Globalization (www.globalresearch.ca), publisher of War and Globalisation: The Truth Behind September 11 by Michel Chossudovsky; and the website of Jim Hoffman (www.wtc7.net).

e. A Citizens' 9/11 Commission was convened in New York on September 9, 2004 to hear certain testimony not heard or considered by the Kean Commission. Chaired by former Georgia Rep. Cynthia McKinney, these hearings are referred to in this Complaint and Petition as "The 9/11 Omissions Hearings" (see, Appendix 7 for transcripts). As the result of evidence heard at the hearings, the Citizens' 9/11 Commission recommended the filing of this or a similar complaint.

10. Private lawsuits have thus far made little progress in uncovering the truth of the events surrounding September 11, largely due to judicial resistance, government obstruction of access to evidence and witnesses and inadequate investigative funds (but partly due to the limited ability of any private lawsuit to resolve issues of this magnitude in a timely manner). A principal condition for the 9/11 victim family members to apply to the unprecedented Victims Compensation Fund for partial redress was formal renunciation of their right to pursue damages or discovery of truth through litigation against U.S. companies or government agencies.

  1. Sibel Edmonds filed a suit against the Department of Justice to challenge excessive classification of a Department of Justice Inspector General's report known to establish she was fired, at least "in part," for her whistleblowing activities (filed with U.S. District Court for the District of Columbia under the Freedom of Information and Privacy Acts, Mark Zaid, Esq., 9/22/04).
  2. The Project on Government Oversight ("POGO") filed a second lawsuit connected with the Sibel Edmonds requesting declaratory and injunctive relief and challenging the reclassification of the information she had provided to Congress.

c. The "Saudi Class Action Suit" (see, www.september11classaction.com) has been similarly impeded. In particular, plaintiffs' attorneys have been denied access to the critical testimony of former FBI translator Sibel Edmonds, who has been effectively silenced after the Justice Department quashed her subpoena, a federal judge postponed the trial on the appeal of her own lawsuit (referred to in the previous paragraph above) and the Justice Department issued an unprecedented "retroactive classification order" covering information she had already released to the Congress (see, stories in Boston Globe, 7/5/04; New York Times, 7/29/04).

d. The 9/11 RICO suit: In November of 2003, former Deputy Attorney General of Pennsylvania Phil Berg filed an amended RICO (Racketeer Influenced and Corrupt Organizations Act) complaint against top members of the Bush Administration for wrongful death, criminal conspiracy and obstruction of justice on behalf of 9/11 widow Ellen Mariani. The case was refiled as Rodriguez v. Bush et al. in the U.S. District Court for the Eastern District of Pennsylvania as of October 21, 2004.

e. Since 2002, FBI special agent Robert Wright has pursued a suit under the Whistleblower Protection Act to allow publication of information alleging high-level obstruction of counterterrorism investigations; the case remains bogged down. His counsel, David Schippers, former lead attorney for the House impeachment trial of William J. Clinton, has stated he saw evidence that the "dates and targets" as well as the funding sources of the 9/11 attacks were known in advance to unnamed FBI agents, whom he represents.

f. Judicial Watch and Sierra Club sued Vice-President Cheney for the release of documents from his Energy Task Force meetings in 2001, which are reported to have discussed military action to secure foreign supplies of oil; the case remains tied up in the courts after a Supreme Court decision in June 2004 not to force a release.

g. Also languishing is a Judicial Watch suit demanding the White House clarify the rationale for placing some of its staff on the antibiotic Cipro immediately after the 9/11 attacks.

h. Environmental Protection Agency suit: On March 10, 2004 a coalition of New York City residents, office workers, parents, and students filed a class action lawsuit against the EPA for deliberately deceiving the public about the highly hazardous dust and air around Ground Zero in the months following the attacks; endangering in particular first responders, clean-up crews, neighboring children and seniors; and failing to comply with its federally mandated responsibility to clean contaminated buildings after terrorist incidents. The case is factually supported by EPA internal memos and third party scientific reviews like the Sierra Club's September 18, 2004 report "Air Pollution and Deception at Ground Zero," as well as by a report by EPA's own Inspector General which found that the White House Council on Environmental Quality changed EPA's press releases in order to reassure the public and re-open Wall Street. An investigation is needed to determine who in the White House was ultimately responsible for these changes.

i. WTC insurance suits: The welter of insurance claims and litigation relating to the WTC destruction has focused almost entirely upon policy language, precedents and contractual process, and thus devoted little if any useful attention to exploring the actual facts and circumstances of the attacks.

  1. Some alleged perpetrators and critical witnesses have been fired or held without charges by a Justice Department that has prioritized official secrecy over defendants' normal Constitutional rights. The Moussaoui case, for example, is currently bogged down due to the government's refusal to allow Moussaoui or his attorneys access to potential defense witnesses such as the captured alleged 9/11 plotters Khalid Sheikh Mohamed, Ramzi Binalshibh and Abu Zubaydah. Further, members of the Bin Ladin family, members of the royal family of Saudi Arabia and many other prominent Saudis who might have provided key information as to the whereabouts of Osama Bin Ladin, terrorist financing and other matters directly related to an investigation of the hijackings on September 11 reportedly were transported within the US on privately chartered jets shortly after the attacks on White House sanctioned flights and allowed to leave the country shortly after the national air traffic ban was lifted. Only a few of these witnesses were interviewed by the FBI, and then, only cursorily, before their departure (see, for example, www.snopes.com/rumors/flight.htm).

12. Tools available to citizens have not worked:

a. Citizens lack subpoena enforcement power.

b. The Administration generally is not honoring Freedom of Information Act requests. For example, the Justice Department chose to go to court rather than honor Sibel Edmonds' successful FOIA request.

c. The Justice Department and FBI contend that most key evidence sought by plaintiffs is either covered by the National Security Act and constitutes a related body of state secrets or must remain confidential due to ongoing cases and investigations. In the case of Sibel Edmonds, they have engaged in highly unusual after-the-fact classification of public testimony.

d. Critical evidence has been destroyed. Recordings of Federal Aviation Administration ("FAA") controllers' accounts of September 11 events taped immediately after attacks were later meticulously cut to shreds and thrown away, despite orders to save them for investigative reference (New York Times, 5/6/04). CIA and Congressional staff complained that the National Security Agency was needlessly destroying evidence related to US companies and citizens that could "perhaps redirect" the investigation (Boston Globe, 10/27/01). The editor of the nation's oldest firefighting magazine, Bill Manning, objected to the accelerated scrapping of World Trade Center rubble before investigators could determine the actual mechanics of the building collapse (Fire Engineering, 1/02).

e. Many of the aforementioned acts, coupled with the rapid confiscation and top-secret classification of other important evidence, suggest at best a blatant contempt for the normal prerequisites for a truthful and confidence-inspiring inquiry and at worst obstruction of justice. Such behavior inevitably undermines trust in government in related matters, such as the veracity of uncorroborated "confessions" from foreign prisoners held at undisclosed locations or the claim that none of the four "indestructible" black boxes from the aircraft at Ground Zero was ever found, as once again reiterated in the 9/11 Commission Report (Ch. 1, fn 76, p. 468).

f. Whistleblowers and elected officials who have called attention to these matters have been ignored, ridiculed, fired, threatened, subjected to gag orders and harassed. We draw your attention in particular to the cases of Sibel Edmonds, Sarshar Behrouz, Robert Wright, Indira Singh, U.S. Air Force Col. Steve Butler and former Rep. Cynthia McKinney. Such examples, coinciding with legal changes under the USA PATRIOT Act and other statutes and regulations, excessive classification orders and constant invocation of a state of threat in the homeland, have a powerful silencing effect on others who would come forward.

g. Officials and military officers associated with the "failures" of investigation and defense response have not been held accountable; on the contrary, several of them have been confirmed in elevated positions, given awards or promoted following September 11. We draw your attention in particular to the cases of Chairman of the Joint Chiefs of Staff Gen. Richard Myers, Gen. Ralph Eberhart (Commander of NORAD on 9/11/01), FBI officials David Frasca, Marion Bowman, Michael Maltbie and an unnamed FBI official alleged to have tolerated penetration by foreign agents at the Bureau's translations department (CBS News, 8/8/04).

h. In the Swiss Re suit against Larry Silverstein, the owner of WTC 7 and of a 99-year lease on the entire WTC complex, the insurance company's motions for access to foreign conspirators' statements (obtained by the Kean Commission) were denied.

i. The major media clearly have been afraid and/or loath to examine the contradictions and anomalies implicit in the Administration's official 9/11 story. Sensational, simplistic and relentless coverage of the attacks and ensuing wars based on the official narrative also proved so profitable for media news divisions that we may never see any serious skeptical investigation into its truth or legitimacy. Media gatekeepers have certainly failed to note ample evidence of cover-ups relating to September 11, question official accounts such as the 9/11 Commission Report despite its obvious omissions and inconsistencies, pursue the unanswered questions and bodies of evidence cited in Part II of this complaint, or even report on the stunning findings of the Zogby 9/11 poll.

j. Congress also has abdicated its responsibility to provide full oversight, conduct exhaustive investigations, provide a credible accounting or even hold in-depth hearings into the most important lines of inquiry put forward by the Family Steering Committee.

k. An independent criminal investigation or impartial grand jury is therefore the only discernible source of redress remaining to the People.

13. Democracy itself is endangered when:

a. The culture of a government refuses to assign responsibility, promote transparency or demand accountability.

b. Government encourages a stifling environment that suppresses dissent, persecutes whistleblowers, spurns the Freedom of Information Act, weakens personal privacy protections, inflates public fear and extols "patriotic" obedience and militarization, etc.

c. States are excluded from matters impacting their citizens by federal preemption, intervention and "state secrets" arguments.

  1. Potential suspects/defendants control investigative and public access to evidence that may tend to incriminate them.

e. A majority of citizens come to suspect high crimes and treachery within their own government, but cannot find officials with enough courage, power or independence to thoroughly investigate their concerns and restore the public trust.










Vast bodies of historical research, editorial content, scientific and statistical studies and public policy statements and analyses have been generated by the September 11 attacks and events leading up to and following the attacks, in the form of newspaper and magazine articles, web-based reports, books, Internet blogs and reports by various official and citizen-based expert groups. Because the mass media have largely ignored work that gives due consideration to hypotheses in conflict with the official story, the dialogues in the field have fermented mainly on the Internet, before a more recent blossoming of publications and films. Both professional and amateur researchers and writers have entered into debates about the ultimate origins of the attacks, preparedness and the adequacy of national intelligence and defense systems to protect citizens against terrorist attacks, the underlying motives for the actions taken and omitted in response to the attacks, unanswered questions presented by official accounts and other issues.

The tragedy has been exploited for political gain and cited as a justification for preemptive attacks on foreign countries, an ongoing war, radical changes in public policy, a break with allies and the United Nations, the enactment of statutes that limit civil liberties of citizens, visitors and immigrants alike, the detainment and even torture of foreign nationals without benefit of due process and guarantees assured under the Geneva Convention, the creation of a new cabinet agency and the expenditure of billions of dollars to increase police-like activity across the nation.

As with treatments of any complex issue, the available sources vary in intent, focus, quality and accuracy and, therefore, in value. Here we provide, based upon our best assessment of the reliability of the available research, a condensed and by no means exhaustive summary of possible avenues for investigation. Credible and promising leads may yet prove baseless, while speculations that at first seem wild to many may turn out to be true. Although far from exhaustive, the appendices, books, films and websites supplied with this Complaint and Petition provide a broad and current introduction to the best investigative work within the 9/11 research field.

The summaries in Appendices suggests avenues for investigation indicating wider circles of criminal complicity than allowed for in the official story. We believe a subpoena-empowered investigation of these avenues, in combination, will uncover indictable crimes under bh New York and federal laws.

A. Taxonomy of Evidence:

1. The complex anomalies and demonstrably false statements about U.S. air defense response on September 11, including evidence suggesting that failures in response cannot be explained by mere incompetence. This is an enormously complex issue, and therefore requires the longest treatment. While your office may choose not to find grounds for direct jurisdiction in these matters, their importance to a potential criminal investigation will become clear in combination with the other subjects treated below. (Appendix A-1)

2. The failure to exercise authority among top officials in the U.S. military chain of command during the actual attacks, so consistent that it suggests an intentional abdication of responsibility and potential criminal facilitation. (Appendix A-2)

3. The alleged Pakistani ISI connection to financing of the 9/11 plot, with its implications leading back to possible American connections. (Appendix A-3)

4. Reports from around the world of financial trading based on foreknowledge of attack details, far from resolved by the SECís and the 9/11 Commission report's untenable dismissal of the "put option" evidence, which itself is only part of the allegations. (Appendix A-4)

5. The unexplained and little-reported collapse of Seven World Trade Center, which raises the possibility of an intentional demolition. (Appendix A-5)

6. The as-yet unsolved anthrax attacks of October 2001 and their impact on domestic politics and the 9/11 investigations. (Appendix A-6)

B. These are the tip of a largely unexplored iceberg. We therefore provide online at justicefor911.org a sampling of other relevant bodies of evidence, pointing to:

1. Oddities and contradictions in reports about the alleged hijackers, suggesting that their identities, associations with other parties, and/or actual roles in the crime have not been conclusively resolved by official investigations. (Appendix B-1)

2. The consistent high-level obstruction of a number of U.S. counterterrorism investigations prior to September 11, one or several of which might have uncovered the plot before its execution. (Appendix B-2)

3. Other indicators of advance preparation for the 9/11 scenario and circulation of attack details in advance among circles beyond the purported Bin Ladin network. (Appendix B-3)

4. Destruction of evidence, use of false evidence, and obstruction of investigations after the fact. (Appendix B-4)

5. The context and timing of the attacks, coming amid the Administration's advance preparations before September 11 to invade both Afghanistan and Iraq. (Appendix B-5)

6. A taxonomy of potential beneficiaries from the 9/11 attacks: We recall that an exploration of which parties may be complicit in a political crime - such as 9/11 surely was, on a vast scale - must always include due consideration for the question of "Cui Bono?": Who are the beneficiaries of given events? Benefits may accrue incidentally, unwanted or unforeseen by the beneficiaries, and therefore benefit is insufficient in establishing culpability; but an impartial investigation necessarily will include considerations of possible culpability among beneficiary groups. Given the disturbing inconsistencies in the official story, such an investigation must ask: "Who would have had motive to allow or to facilitate the attacks?"" "Who has displayed a willingness to exploit the events of 9/11 and their predictable consequences in the political, financial, and psychological realms?" "Are there indications that any of these beneficiaries may have been aware of the attacks in advance?" (Appendix B-6)

C. Finally, we can only briefly touch upon historical subjects that are academic to a criminal investigation and prosecution of the 9/11 crimes, but which should surely inform any such venture. The described materials will be provided online at justicefor911.org. Among these are:

1. The history of the U.S. government's covert operations and policies, in parallel with the actions of covert associations that are partly based in U.S. government agencies, but which pursue their own agendas. Both have often countenanced deliberate support for the rise of later enemies of the United States. Examples include decades of US support for radical Islamism in general and specific participation in creating the network around Osama bin Ladin, and the exploitation of that network both on behalf of covert policy goals and as an overt enemy of convenience. (Appendix B-7)

2. Precedents for state-sponsored "false-flag" domestic terrorism: The many past cases when states (including the U.S. government), state agents or related elites pursuing their own agendas have accommodated attacks on their own nationals; fabricated non-existent attacks; or even engineered real attacks, and blamed such attacks on an enemy of convenience (a "false flag"), the motive being to rule by fear, provide pretext for war, silence dissent, or achieve other political and economic goals. (Appendix B-8)



Proceeding from the information set forth herein, we hereby request the Attorney General to appoint an independent, impartial, randomly selected grand jury to:

A. Answer the unanswered questions, those posed to the Kean Commission by the relatives of September 11 victims and those posed in the published materials provided herewith.

B. Identify those responsible (including, if appropriate, those in government and government contractors) for murder, monetary damages to NY public authorities, property damages, damage to health of New York residents, business owners and employees, etc.

C. Identify government contractors, if any, responsible for failure of nationís air defenses.

D. Identify those who authorized departure from US jurisdiction of potential individual co-conspirators, facilitators or aiders and abettors, and of funds linked to financing of 9/11.

E. Hold responsible persons accountable under state law, both personally and through their employers or principals, or charge federal government with pursuing federal remedies.

F. Identify sources of financial redress from:

1. Responsible federal government officials

2.  Complicit local officials

3. Government contractors and private individuals and corporate officials (and those in control of corportations) who aided and abetted, criminally facilitated or conspired or breached contracts

G. If the federal government refuses to enforce federal laws: Use state power to enforce state laws, challenge federal authority to supersede or preempt state and local authorities; challenge state secrets invocation to examine whether it is genuinely invoked for security or abused to cover-up wrongdoing and work with international banking and other authorities to investigate and follow money trails.

H. Find law firms, accounting firms and banks that aided and abetted the September 11 crimes, their financiand and activities in furtherance thereof.

I. If necessary, keep culpable businesses out of the State of New York, where they:

1. Have stock traded on New York-based exchanges.

2. Have headquarters and U.S. offices of foreign corps (especially money center banks).

3.  Qualify to do business in the state only through state grant, which can be withdrawn for illegal conduct.

4. Have submitted to jurisdiction of the State of New York by reason of admission to transact business in New York.

5. Have New York bank accounts that can be attached.

J. Address military failures and/or crimes to the extent possible, including actions of or effects on civilian military employees.

K. 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 8)

  1. Use whatever legal recourse is available to recover on behalf of the people of New York from perpetrators, conspirators and other liable individuals and corporations damages to the city and state of New York and disgorge, levy the maximum penalties available at law for illegal profits, contractual payments for incomplete, incompetent, faulty or otherwise wrongfully compensated work under breached contracts and other illegal activities contributing to, exacerbating or covering up the crimes committed on or in connection with "9/11" and related activities thereafter.

M. Protect "whistleblowers" and other sources of information with respect to this investigation from retaliatory action by perpetrators and those attempting to cover up the truth.


"Justice for 9/11"
Steering Committee

Sponsoring organizations:


9/11 CitizensWatch

WTC Environmental Organization

Complainants in Support

Endorsements from celebrities and Sept. 11 families:
The 911 Truth Statement

"Justice for 9/11"
endorses the

Unanswered Questions
initiative of the
Family Steering Committee 
for the Independent 
9/11 Commission





Dr. Faiz Kahn

911 Triage Doctor, First Responder


Robert McIlvaine

Father of Robert McIlvaine, Lost at Ground Zero


Jenna Orkin, Chairwoman

World Trade Center Environmental Organization


Megan Bartlett

9/11 EMT and Founder of Ground Zero for Peace

Victim of Toxic Dust Exposure


William Rodriguez

World Trade Center employee and Survivor

[Additional Complainants to Be Added]



and print


(Oct. 28)




of all
On November 19, 2004, the "Justice for 9/11" Steering Committee submitted a Citizens' Complaint and Petition to the offices of the Attorney General of New York State, Eliot Spitzer, citing probable cause for an independent grand jury investigation to examine unsolved crimes committed in connection with the events of September 11, 2001. We are publishing the complete Complaint and Petition online in this space as a living, growing document. 

Nine members of September 11 families, Ground Zero first responders, and citizens of New York have signed on as the first complainants. We call on citizens to support this action, to initiate similar actions in other states, and to sign the online petition of solidarity.
Campaign Contact
To discuss joining the coalition, filing support briefs and initiating actions in other states and jurisdictions, please contact:

David Kubiak
Exec. Director
Media Contact 
Kyle Hence
9/11 CitizensWatch 

Please donate to one of the sponsoring groups in the "Justice for 9/11" Steering Committee

Copyright (c) 2004 The "Justice for 9/11" Steering Committee. 
Materials that may be under other copyrights are used here under fair-use provisions for non-commercial information purposes only.