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 Obtain any as-yet unpublished or classified investigatory analyses, reports, or physical or other evidence from law enforcement authorities, government agencies and courts of New York City,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