PLAINTIFF’S AMENDED COMPLAINT6
NOW COMES the Plaintiff, Ellen Mariani, on information, belief and established facts,
by and through her counsel of record, Philip J. Berg, Esquire, and for her causes of action against
all named and unnamed Defendants states the following:
STATEMENT OF THE CASE
1. Plaintiff commenced this civil action on September 12, 2003, by filing of
Complaint with this Honorable Court. Since Plaintiff’s initial filing and the ‘firestorm”
surrounding Defendant GWB’s refusal to comply with the “911 Commission7,” this Amended
Complaint provides newly discovered substantial additional facts, evidence and voluntary
support from former federal employees and other concerned American Citizens who all seek
justice and the truth as to how and why the events of September 11, 2001, (hereinafter “911”),
occurred. Plaintiff hereby asserts Defendants, officially and individually are exclusively liable to
answer the Counts in this Complaint under the United States Constitution and provisions of the
18 U.S.C. § 1964(a) and (c), Racketeer Influenced and Corrupt Organizations Act (hereinafter
“RICO Act”) for “failing to act and prevent” the murder of Plaintiff’s husband, Louis Neil
Mariani, for financial and political reasons and have “obstructed justice” in the aftermath of said
criminal acts and omissions.8
2. On “911,” Plaintiff’s husband, Louis Neil Mariani, an American Citizen and
paying passenger on United Airlines Flight 175, was murdered by unidentified perpetrators,
(hereinafter “terrorists”) according to Defendant GWB.
continued...