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PLAINTIFF'S AMENDED COMPLAINT FOR INJUNCTIVE RELIEF
1. This is an action under the Freedom of Information Act, 5 U.S.C. § 552, to order the production of agency records, concerning documentation revealing the process by which wreckage recovered by defendant, from the aircraft used during the terrorist attacks of September 11, 2001, was positively identified by defendant (with the aid of the National Transportation Safety Board), as belonging to the said aircraft, presumably through the use of unique serial number identifying information contained by the said aircraft's wreckage, that was collected by defendant and which defendant has improperly withheld from plaintiff.
The data sought by plaintiff is the basis for the F.B.I's. current public position, that the following 4 flights were those that were involved in the terrorist attacks of September 11, 2001:
- American Airlines flight 11, United Airlines flight 175, American Airlines flight 77 and United Airlines flight 93.
The data sought by plaintiff was obtain
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Respectfully submitted,
Aidan Monaghan
Dated: 2/1/2008
DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO AMENDED COMPLAINT
Pursuant to Fed. R. Civ. P. 6(b)(1) and LR 6-1, Federal Defendant respectfully requests that the Court provide Defendant with a thirty-day enlargement of time, to April 14, 2007, within which to file a response to Plaintiff’s Amended Complaint for Injunctive Relief (#15). This motion is based on the Memorandum of Points and Authorities below and all papers and pleadings on file.
DATED: March 14, 2008.
Respectfully submitted,
GREGORY A. BROWER
United States Attorney
P A/TRs/I CKP AAT.R ICRKO SAE. ROSE
Assistant United States Attorney
MEMORANDUM OF POINTS AND AUTHORITIES
This is an action under the Freedom of Information Act (the “FOIA”), 5 U.S.C. § 552, et seq. Plaintiff seeks records “revealing the process by which wreckage recovered by defendant, from aircraft used during the terrorist attacks of September 11, 2001, was positively identified by defendant . . . as belonging to said aircraft . . .” (Amend Compl. Inj. Relief #15 at 1.) Under the FOIA, the defendant has thirty days to respond to a complaint unless the Court directs otherwise for good cause shown. See 5 U.S.C. § 552(a)(4)(C). The Federal Defendant was served with the Summons and Amended Complaint on February 13, 2008, which would correspond to a responsive date of March 14, 2008. However, the Summons (#17) served on Federal Defendant by Plaintiff states that a response to the Amended Complaint is due in sixty days of service, which would correspond to a responsive date of April 14, 2008. With this motion, Federal Defendant seeks merely to establish a clear responsive deadline of April 14, 2008. To the extent an enlargement of time from March 14 to April 14, 2008 is necessary, Federal Defendant requests such enlargement pursuant to Fed. R. Civ. P. 6 and LR 6-1.
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Originally posted by trueforger
If you don't see the bomb crater that I do,we procure an accurate ruler,square and protractor and eliminate the impossibilities.And what remains,no matter how improbable,must be the correct answer.
There would have been a hole of at least an acre with a dump pile even bigger as sifting for evidence was carried out.
Conclusion? We're practicing on these guys who are acting so obtuse,which is well and good,but soon we need to recognize that there are a few who will not admit doubt and move on.Consensus minus one,we called it.We need pictures.
....concerning documentation revealing the process by which wreckage recovered by defendant, from the aircraft used during the terrorist attacks of September 11, 2001, was positively identified by defendant (with the aid of the National Transportation Safety Board), as belonging to the said aircraft, presumably through the use of unique serial number identifying information contained by the said aircraft's wreckage, that was collected by defendant and which defendant has improperly withheld from plaintiff.
This is regarding the collection-identification process. I will concede that the serial numbers were not collected.
I believe there have been several plane crashes that did not record the serial numbers. (I could be mistaken)
Originally posted by impressme
Don’t you find that very strange in “all” airplane crashes in the United States airplanes time change out parts are, always found, and are used to properly identify the crashed airplane. For the first time in US history only on 911, the airplane crash debris was not recorded as proof, to prove they belong to said airplanes.
I believe there have been several plane crashes that did not record the serial numbers. (I could be mistaken)
Are you stating this as a fact, or an opinion?
Originally posted by CameronFox
reply to post by impressme
THe FBI was there to determine if there was a bomb on the plane. On or around September 25th, they determined this not to be a factor.
Nothing I see screams cover up.
Originally posted by thedman
reply to post by impressme
Been to crash of Lear 35 in my town. Also certified in heavy rescue - which entails training from Port Authority of NY aircraft crash/Fire fighters
on aircraft crash fires.
Thus have ability to relate what see in photos to actual experience.
So how many plane crashes you been to? Guess dont have many in
mommy's basement.....
Thanks Cameron Fox - unlike youtube commandos have to go to work
posted by CameronFox
reply to post by impressme
Please read what this FOIA is regarding:
....concerning documentation revealing the process by which wreckage recovered by defendant, from the aircraft used during the terrorist attacks of September 11, 2001, was positively identified by defendant (with the aid of the National Transportation Safety Board), as belonging to the said aircraft, presumably through the use of unique serial number identifying information contained by the said aircraft's wreckage, that was collected by defendant and which defendant has improperly withheld from plaintiff.
This is regarding the collection-identification process. I will concede that the serial numbers were not collected.
I believe there have been several plane crashes that did not record the serial numbers. (I could be mistaken)
Of all major U.S. airline crashes within the U.S. investigated and published by the National Transportation Safety Board during the past 20 years, the 9/11 ‘black boxes’ are virtually the only ones without listed serial numbers.
The following e-mail was provided by a Susan Stevenson of the NTSB on 12/26/2007, in response to a 12/16/2007 public correspondence e-mail inquiry:
“Yes. NTSB investigators rarely encounter a scenario when the identification of an accident aircraft is not apparent. But during those occasions, investigators will record serial numbers of major components, and then contact the manufacturer of those components in an attempt to determine what aircraft the component was installed upon.”
visibility911.com...
Defendants motion reads in part:
“Since being served with the Summons and Amended Complaint, Federal Defendant, with assistance of its attorneys, has analyzed Plaintiff’s request and conducted a search for responsive records. Federal Defendant has determined that there are no responsive records. The identities of the airplanes hijacked in the September 11 attacks was never in question, and, therefore, there were no records generated “revealing the process by which wreckage recovered by defendant, from aircraft used during the terrorist attacks of September 11, 2001, was positively identified by defendant . . . as belonging to said aircraft . . .” (Amend Compl. Inj. Relief #15 at 1.)”
However, this claim is directly contradicted by public comments offered by Carol Carmody, Vice-Chairman National Transportation Safety Board and Marion C. Blakey, Chairman National Transportation Safety Board, who both indicated in 2002 that FBI director Robert Mueller requested NTSB assistance with 9/11 aircraft wreckage identification and that the NTSB did perform 9/11 aircraft wreckage identification analysis.
“I … assured FBI Director Mueller that we would assist in any way we could … he called and said, “Could you send us some people to help find the black boxes and help identify aircraft parts.”
www.ntsb.gov...
Originally posted by trueforger
Don't really need more practice debating you,thanx.
Likewise talking by phone to some person you refer to,again no thanks.We all need pictures.
As for Evidence,it,the evidence has been kept from us.Or,in this instance no one bothered to take pictures.
An airplane,such as 93,can not be in the hole
in United's custody,
shot down
and non present
.I can't say what happened,but I can point out what did not happen.That would be your conspiracy fable.The one about Al-Ciada.
I may be wrong but I am not defending traitors.That would make me complicit.Eh Fox?
Originally posted by SPreston
An amazing admission on your part CF.
Been to crash of Lear 35 in my town. Also certified in heavy rescue - which entails training from Port Authority of NY aircraft crash/Fire fighters
on aircraft crash fires.
So how many plane crashes you been to? Guess dont have many in
mommy's basement.....
Why do you all stop at the internet? When will you make calls? When will print and mail a letter? When will you visit Shanksville? Give Domenick some credit, at least he got off his butt and spoke to people. You don't have serial numbers.... think for a second. Of all the MASSIVE cover ups going on during 9/11...how simple would it have been to make up a few silly numbers?
Originally posted by impressme
This thread is not about your credentials, or what’s in mommy’s basement.
This thread is about (KT Challenge@Shanksville) so please stay on topic.
Do you have anything you would like to discuss about the Shanksville crash site, and the evidences
Originally posted by impressme
CF, if the NTBS, and the Airline Co are not going to cooperate with real investigators with information concerning the plane crashes. What makes you think filing for a Freedom of information Act, or making ridiculous phone calls, as if they are going to give up their information to us? lol (I don’t think so)
You know, criminals are always over looking something, I bet they didn’t think about the serial numbers until it was to late.
There is no such thing as a perfect crime is there CF.
posted by SPreston
An amazing admission on your part CF.
posted by CameronFox
You threw away the phone calls that were made scripted and FAKED
You threw away the FDR report No serial # and FAKED
You threw away the CVR no serial # and FAKED
You threw away the personal belongings. Paper Passports? FAKED
You threw away the eye witnesses the 104 that nobody can find? Not even with government loyalists looking for them?
You threw away the DNA evidence Heat resistant DNA? and FAKED
You threw away the hundreds of volunteers. the hundreds that nobody can find? Not even with government loyalists looking for them?
You threw away the hijacker video's. With the stolen IDs? and FAKED