IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA

October 21, 2004

PHILIP J. BERG, ESQ.
Attorney for Plaintiff
706 Ridge Pike
Lafayette Hill, Pennsylvania 19444-1711
Telephone (610) 825-3134

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WILLIAM RODRIGUEZ,
Plaintiff,

-against-

1. GEORGE HERBERT WALKER BUSH,
2. GEORGE WALKER BUSH,
3. JOHN “JEB” BUSH,
4. NEIL MALLON BUSH,
5. MARVIN BUSH,
6. RICHARD CHENEY,
7. DONALD H. RUMSFELD,
8. DOV ZAKHEIM,
9. COLIN POWELL,
10. RICHARD ARMITAGE,
11. CONDOLEEZA RICE,
12. JOHN ASHCROFT,
13. ROBERT S. MUELLER III,
14. DAVID FRASCA,
15. GEORGE J. TENET,
16. PORTER GOSS,
17. NORMAN Y. MINETA,
18. LARRY K. ARNOLD,
19. TOM RIDGE,
20. MARK RACICOT,
21. THE REPUBLICAN NATIONAL COMMITTEE, INC.,
22. ALAN GREENSPAN,
23. THOMAS A. KEAN,
24. JAMIE S. GORELICK,
25. PHILLIP D. ZELIKOW,
26. JOHN F. LEHMAN,
27. FRED F. FIELDING,
28. KARL ROVE,
29. THOMAS DeLAY,
30. RICHARD PERLE,
31. PAUL WOLFOWITZ
32. RICHARD MYERS,
33. RALPH E. EBERHART,
34. KENNETH R. FEINBERG,
35. HALLIBURTON COMPANY,
36. KELLOG BROWN & ROOT SERVICES,
37. THE PROJECT FOR THE NEW AMERICAN CENTURY, INC.,
38. ELECTION SYSTEMS & SOFTWARE,
39. DIEBOLD VOTING SYSTEMS, INC.,
40. WALDEN O’DELL,
41. SEQUOIA VOTING SYSTEMS, INC.
42. CHUCK HAGEL,
43. SAXBY CHAMBLISS,
44. NEW BRIDGE STRATEGIES, LLC
45. JOE M. ALLBAUGH,
46. JAMES A. BAKER III,
47. JOHN SWEENEY,
48. MATTHEW SCHLAPP,
49. THOMAS PYLE,
50. MICHAEL MURPHY,
51. GARRY MALPHRUS,
52. CHARLES ROYAL,
53. KEVIN SMITH,
54. THE UNITED STATES OF AMERICA,
55. THE UNITED STATES. DEPARTMENT OF
HOMELAND SECURITY,
56. THE FEDERAL EMERGENCY MANAGEMENT AGENCY; and
57. DOE #1 Through DOE #100,

Defendants.

No. ____________

COMPLAINT IN CIVIL ACTION

TRIAL BY JURY DEMANDED

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TABLE OF CONTENTS

I. INTRODUCTION
II. PARTIES, JURISDICTION, AND VENUE
III. FACTS ON WHICH CLAIMS FOR RELIEF ARE PREDICATED
A. THE WTC TWIN TOWERS, AS WELL AS WTC BUILDING #7, WERE DESTROYED BY CONTROLLED DEMOLITION, AS CLEARLY PROVEN BY THE LAWS OF PHYSICS; THIS DEMOLITION COULD ONLY HAVE BEEN AN "INSIDE JOB."
B. FEMA, WHICH REMOVED THE EVIDENCE BEFORE IT COULD BE INDEPENDENTLY EXAMINED, MAINTAINS A BLACK-OP SHADOW GOVERNMENT DESIGNED TO REPLACE THE ELECTED GOVERNMENT OF THE UNITED STATES
C. DEFENDANTS DELIBERATELY CONCEALED THE FACT THAT THEY HAD AMPLE WARNINGS OF TERRORIST ATTACKS AND FAILED TO ACT ON THEM, A WAR ON TERRORISM BEING NECESSARY TO JUSTIFY THEIR POLITICAL AGENDA
D. DEFENDANTS CONSPIRED TO AND DID ALLOW THE ATTACKS TO HAPPEN BY DELAYING MILITARY INTERCEPTION OF THE HIJACKED PLANES
1. FLIGHT 11 (NORTH TOWER WTC) COULD HAVE BEEN BUT WAS NOT INTERCEPTED
2. FLIGHT 175 COULD HAVE BEEN BUT WAS NOT INTERCEPTED
3. FLIGHT 77 NOT ONLY COULD HAVE BEEN INTERCEPTED BUT WAS ALLOWED TO FLY UNCONTESTED A FULL 50 MINUTES BEFORE STRIKING THE PENTAGON
4. AN UNPRECEDENTED NATIONWIDE "GROUND STOP" ORDER, WHICH MUST HAVE HAD WHITE HOUSE APPROVAL, PREVENTED EVEN THE MILITARY FROM FLYING AND ALLOWED THE ATTACKS TO PROCEED
5. THE CRASH OF FLIGHT 93 IN SOMERSET COUNTY, PENNSYLVANIA, RAISES SERIOUS ADDITIONAL UNANSWERED QUESTIONS
6. SOME ADDITIONAL REASONS TO DOUBT THE OFFICIAL STORY OF 9-11
E. THE ENTERPRISE HAS ENGAGED IN A CONSPIRACY TO COMMIT ELECTION FRAUD
F. ENTERPRISE'S FLORIDA RECOUNT RIOT: ADDITIONAL PREDICATE ACTS UNDER RICO
G. ADDITIONAL ALLEGATIONS AS TO INDIVIDUAL DEFENDANTS, PREDICATE ACTS OF RACKETEERING COMMITTED BY THEM, AND THEIR ROLES IN THE RICO ENTERPRISE
H. THE FOREGOING FACTS SUPPORT CLAIMS AGAINST THE DEFENDANTS FOR MULTIPLE ACTS OF CONSPIRACY, RACKETEERING, DOMESTIC TERRORISM AND OTHER CRIMES
IV. COUNTS
1. MISPRISION OF A FELONY (18 U.S.C. Section 4)
2. MISPRISION OF TREASON (18 U.S.C. Section 2382)
3. PATTERN OF RACKETEERING ACTIVITY (18 U.S.C. Section 1962c)
4. RACKETEERING ACTIVITY (18 U.S.C. Section 1961(1))
5. CONSPIRACY TO COMMIT RICO VIOLATIONS\(18 U.S.C. Section 1962 (b, c))
6. INJUNCTIVE AND DECLARATORY RELIEF (18 U.S.C. Section 1964c)
7. INJUNCTIVE RELIEF (18 U.S.C. Section 1964c)
8. COMMON LAW INJUNCTIVE RELIEF
9. DECLARATORY JUDGMENT (28 U.S.C. Section 2201 et seq.)
10. INJUNCTIVE RELIEF
11. RELIEF UNDER ANTI-TERRORISM ACT (18 U.S.C. Section 2333)
12. RELIEF FOR AND FROM CRIMES AGAINST HUMANITY
13. RELIEF UNDER WAR CRIMES ACT (18 U.S.C. Section 2441)
V. PRAYER FOR RELIEF
VI. EXHIBITS…

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