Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 1 of 30

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
X
KATHLEEN ASHTON, Individually, as surviving Spouse, 03 MDL 1570 (GBD)(SN)
and Personal Representative of the Estate of THOMAS
ASHTON; Civil Case No.
JOHN ASHTON, as surviving parent of THOMAS ASHTON,
Deceased;
MARY BUCKLEY, as surviving Sibling of THOMAS
ASHTON, Deceased; CONSOLIDATED COMPLAINT
COLLEEN AMATO, as surviving Sibling of THOMAS
ASHTON, Deceased;
Kreindler & Kreindler LLP
LORRAINE ABAD, Individually, as surviving Spouse,
and Personal Representative of the Estate of EDELMIRO McGarry Salzman Penson & Lim
ABAD, Deceased;

GWYNETTA HURST ROSSI, Individually, as surviving

Parent, and Personal Representative of the Estate of
SHANNON L. ADAMS, Deceased;
KYLE ADAMS-FLOYD, as surviving Sibling of
SHANNON L. ADAMS, Deceased;
MICHAEL J. ADAMS, as surviving Sibling of
SHANNON L. ADAMS, Deceased;

MARY E. ADDERLEY, Individually, as surviving

Parent, and Personal Representative of the Estate of
TERENCE ADDERLEY, JR., Deceased;

CARMEN AGNES, Individually, as surviving Parent,

and Personal Representative of the Estate of DAVID
AGNES, Deceased;

MILTIADIS AHLADIOTIS, Individually, as surviving

Parent, and Personal Representative of the Estate of
JOANNE AHLADIOTIS, Deceased;
EFFIE AHLADIOTIS-SALLOUM, as surviving Sibling
of JOANNE AHLADIOTIS, Deceased;

KIM TRIMINGHAM-AIKEN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
TERRANCE AIKEN, Deceased;

DONNA L. ALBERT, Individually, as surviving Spouse,

and Personal Representative of the Estate of JON L.
ALBERT, Deceased;
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 2 of 30

JOSEPHINE ALGER, Individually, as surviving Spouse,

and Personal Representative of the Estate of DAVID D.
ALGER, Deceased;

ANGELICA ALLEN, Individually, as surviving Spouse,

and Personal Representative of the Estate of ERIC
ALLEN, Deceased;

EMILY YAREMBINSKY, Individually, as surviving

Child, and Personal Representative of the Estate of
ANGELO AMARANTO, Deceased;

DEBORAH AMATO, Individually, as surviving Spouse,

and Personal Representative of the Estate of JAMES M.
AMATO, Deceased;

GEORGE ANDRUCKI, Individually, as surviving

Parent, and Personal Representative of the Estate of
JEAN ANDRUCKI, Deceased;

ANNE ANGELINI, Individually, as surviving Spouse,

and Personal Representative of the Estate of JOSEPH J.
ANGELINI, SR., Deceased;

PERRY ORETZKY, as Personal Representative of the

Estate of DAVID L. ANGELL, Deceased;

PERRY ORETZKY, as Personal Representative of the

Estate of MARY LYNN EDWARDS ANGELL,
Deceased;

KATHLEEN APOSTOL, Individually, as surviving

Spouse, and Personal Representative of the Estate of
FAUSTINO APOSTOL, JR., Deceased;

ALEXANDER ARANYOS, Individually, as surviving

Spouse, and Personal Representative of the Estate of
PATRICK ARANYOS, Deceased;

MARGARET ARCE, Individually, as surviving Parent,

and Personal Representative of the Estate of DAVID
ARCE, Deceased;

VICKIE ARESTEGUI, Individually, as surviving

Sibling, and Personal Representative of the Estate of
BARBARA ARESTEGUI, Deceased;

2
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 3 of 30

MARGIT ARIAS, Individually, as surviving Spouse, and

Personal Representative of the Estate of ADAM P.
ARIAS, Deceased;

EVELYN ARON, Individually, as surviving Spouse, and

Personal Representative of the Estate of JACK C.
ARON, Deceased;

LORI ANN ARCZYNSKI, Individually, as surviving

Spouse, and Personal Representative of the Estate of
MICHAEL G. ARCZYNSKI, Deceased;

JOANN ATLAS, Individually, as surviving Spouse, and

Personal Representative of the Estate of GREGG A.
ATLAS, Deceased;

NANCY BADAGLIACCA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOHN BADAGLIACCA, Deceased;

CHRISTINA BAKSH, Individually, as surviving

Spouse, and Personal Representative of the Estate of
MICHAEL BAKSH, Deceased;

JOANNE BARBARA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
GERARD BARBARA, Deceased;
PAUL BARBARA, as surviving Child of GERARD
BARBARA, Deceased;
CAREN VILLARREAL, as surviving Child of
GERARD BARBARA, Deceased;

MONICA BARBELLA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JAMES W. BARBELLA, Deceased;

DIANNE M. WALSH, Individually, as surviving

Sibling, and Personal Representative of the Estate of
CHRISTINE BARBUTO, Deceased;

DANIEL F. BARKOW, Individually, as surviving

Spouse, and Personal Representative of the Estate of
COLLEEN BARKOW, Deceased;

3
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 4 of 30

JEANNINE P. BARON, Individually, as surviving

Spouse, and Personal Representative of the Estate of
EVAN J. BARON, Deceased;
ETHAN BARON, as surviving Child of EVAN J.
BARON, Deceased;
JEANNINE P. BARON on behalf of JULIA BARON,
minor, as surviving Child of EVAN J. BARON,
Deceased;

JANE BARTELS, Individually, as surviving Spouse, and

Personal Representative of the Estate of CARLTON
BARTELS, Deceased;

VLADIMIR BASIN, Individually, as surviving Spouse,

and Personal Representative of the Estate of INNA
BASINA, Deceased;

ELAINE LEINUNG, Individually, as surviving Parent,

and Personal Representative of the Estate of PAUL
BATTAGLIA, Deceased;

KIMBERLY K. BEAVEN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ALAN BEAVEN, Deceased;

MICHELLE LAVARONE, Individually, as surviving

Spouse, and Personal Representative of the Estate of
CARL BEDIGIAN, Deceased;

LOWELL BELL, Individually, as surviving Parent, and

Personal Representative of the Estate of NINA P. BELL,
Deceased;
PATRICIA BELL, as surviving Parent of NINA P.
BELL, Deceased;
LOWELL F. BELL, as surviving Sibling of NINA P.
BELL, Deceased;
DEBORAH HARRISON, as surviving Sibling of NINA
P. BELL, Deceased;

JOSEPH BERARDI, Individually, as surviving Parent,

and Personal Representative of the Estate of DOMINICK
J. BERARDI, Deceased;

SUSAN BERGER, Individually, as surviving Spouse,

and Personal Representative of the Estate of STEVEN H.
BERGER, Deceased;

4
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 5 of 30

MELISSA BERGER, as surviving Child of STEVEN H.

BERGER, Deceased;

MADELINE BERGIN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOHN BERGIN, Deceased;
KATIE BERGIN, as surviving Child of JOHN BERGIN,
Deceased;
SHANNON BERGIN, as surviving Child of JOHN
BERGIN, Deceased;
JOHN BERGIN, as surviving Child of JOHN BERGIN,
Deceased;

LOURDES PEREZ-BERKELEY, Individually, as

surviving Spouse, and Personal Representative of the
Estate of MICHAEL J. BERKELEY, Deceased;

CHARLES BERKELEY, Individually, as surviving

Parent, and Co-Personal Representative of the Estate of
GRAHAM A. BERKELEY, Deceased;
PAULINE BERKELEY, Individually, as surviving
Parent, and Co-Personal Representative of the Estate of
GRAHAM A. BERKELEY, Deceased;

PAULA BERRY, Individually, as surviving Spouse, and

Personal Representative of the Estate of DAVID S.
BERRY, Deceased;

VALERIE BETHKE, Individually, as surviving Spouse,

and Personal Representative of the Estate of WILLIAM
R. BETHKE, Deceased;

SIRAK BETRU, Individually, as surviving Sibling, and

Personal Representative of the Estate of YENENEH
BETRU, Deceased;

THERESA CLARNER, Individually, as surviving

Parent, and Personal Representative of the Estate of
PETER BEIFELD, Deceased;

ARLENE BEYER, Individually, and as Estate

Representative of the Estate of Arlene Beyer, Deceased
and on behalf of all survivors of Arlene Beyer;

5
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 6 of 30

MIRIAM BIEGELEISEN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
SHIMMY D. BIEGELEISEN, Deceased;

CHRISTINE BINI, Individually, as surviving Spouse,

and Personal Representative of the Estate of CARL
BINI, Deceased;
STEFANIE PARISH, as surviving Child of CARL BINI,
Deceased;
DESIREE DIDONNA, as surviving Child of CARL
BINI, Deceased;

MARCEL BIRNBAUM, Individually, as surviving

Parent, and Personal Representative of the Estate of
JOSHUA BIRNBAUM, Deceased;

DEBORAH BLANDING, Individually, as surviving

Spouse, and Personal Representative of the Estate of
HARRY A. BLANDING, JR., Deceased;
BENJAMIN BLANDING, as surviving Child of
HARRY A. BLANDING, JR., Deceased;

KRIS BLOOD, Individually, as surviving Spouse, and

Personal Representative of the Estate of RICHARD M.
BLOOD, JR., Deceased;
MICHAEL BLOOD, as surviving Child of RICHARD
M. BLOOD, JR., Deceased;
MADELINE BLOOD, as surviving Child of RICHARD
M. BLOOD, JR. Deceased;

DOROTHY A. BOGDAN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
NICHOLAS BOGDAN, Deceased;
DOROTHY A. BOGDAN on behalf of EMILY
BOGDAN, minor, as surviving Child of NICHOLAS
BOGDAN, Deceased;

MARIA BOISSEAU, Individually, as surviving Spouse,

and Personal Representative of the Estate of
LAWRENCE BOISSEAU, Deceased;

CYNTHIA LEWIS, Individually, as surviving Sibling,

and Personal Representative of the Estate of SHERRY
ANN BORDEAUX, Deceased;

6
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 7 of 30

TRACI BOSCO-MYHAL, Individually, as surviving

Spouse, and Personal Representative of the Estate of
RICHARD EDWARD BOSCO, Deceased;

FREDERICK BOWERS, JR., Individually, as surviving

Parent, and Personal Representative of the Estate of
KIMBERLY S. BOWERS, Deceased;

LINDA BOWMAN, Individually, as surviving Spouse,

and Personal Representative of the Estate of LARRY
BOWMAN, Deceased;

KATHLEEN BOX, Individually, as surviving Spouse,

and Personal Representative of the Estate of GARY
BOX, Deceased;

JOLANTA BOYARSKY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
GENNADY BOYARSKY, Deceased;
MICHAEL BOYARSKY, as surviving Child of
GENNADY BOYARSKY, Deceased;
BEATA BOYARSKY, as surviving Sibling of
GENNADY BOYARSKY, Deceased;

JAMES BOYLE, Individually, as surviving Parent, and

Personal Representative of the Estate of MICHAEL
BOYLE, Deceased;

JEAN BRACA, Individually, as surviving Spouse, and

Personal Representative of the Estate of ALFRED
BRACA, Deceased;

DAVID E. BRACE, Individually, as surviving Spouse,

and Personal Representative of the Estate of SANDRA J.
CONATY-BRACE, Deceased;

PHILLIP G. BRADSHAW, Individually, as surviving

Spouse, and Personal Representative of the Estate of
SANDRA W. BRADSHAW, Deceased;

JENNIFER E. BRADY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DAVID B. BRADY, Deceased;

7
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 8 of 30

RANULFO GAMBOA, as Co-Personal Representative

of the Estate of DAVID REED GAMBOA-
BRANDHORST, Deceased;
RENEE GAMBOA, as Co-Personal Representative of
the Estate of DAVID REED GAMBOA-
BRANDHORST, Deceased;

MIA GONZALEZ, Individually, as surviving Child, and

Personal Representative of the Estate of
LYDIA E. BRAVO, Deceased;

EDWARD BRENNAN, Individually, as surviving

Parent, and Personal Representative of the Estate of
EDWARD A. BRENNAN, III, Deceased;

HILLARY A. BRILEY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JONATHAN E. BRILEY, Deceased;

URSULA BROGHAMMER, Individually, as surviving

Spouse, and Personal Representative of the Estate of
HERMAN C. BROGHAMMER, Deceased;

EDWARD RADBURN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
BETTINA BROWNE-RADBURN, Deceased;

DAWN BRYFOGLE, Individually, as surviving Spouse,

and Personal Representative of the Estate of MARK
BRUCE, Deceased;
DIANE BRUCE, as surviving Parent of MARK BRUCE,
Deceased;
STEPHEN BRUCE, as surviving Sibling of MARK
BRUCE, Deceased;
DAVID BRUCE, as surviving Sibling of MARK
BRUCE, Deceased;
DAVID BRUCE, as Personal Representative of the
Estate of HAROLD TRUMAN BRUCE, Deceased,
surviving Parent of MARK BRUCE;

JO ANNE BRUEHERT, Individually, as surviving

Spouse, and Personal Representative of the Estate of
RICHARD BRUEHERT, Deceased;
CHRISTINA BRUEHERT, as surviving Child of
RICHARD BRUEHERT, Deceased;

8
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 9 of 30

JO ANNE BRUEHERT on behalf of DANIELLE

BRUEHERT, minor, as surviving Child of RICHARD
BRUEHERT, Deceased;
JOHN BRUEHERT, as surviving Sibling of RICHARD
BRUEHERT, Deceased;

SUSAN E. WHELAN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
PATRICK BUHSE, Deceased;
SLOAN BUHSE, as surviving Child of PATRICK
BUHSE, Deceased;
WILLIAM F. BUHSE, as surviving Child of PATRICK
BUHSE, Deceased;
WILLIAM BUHSE, as surviving Sibling of PATRICK
BUHSE, Deceased;
THOMAS BUHSE, as surviving Sibling of PATRICK
BUHSE, Deceased;
SUANNE KAZANECKI, as surviving Sibling of
PATRICK BUHSE, Deceased;
MICHAEL BUHSE, as surviving Sibling of PATRICK
BUHSE, Deceased;

DAVID BURFORD, Individually, as surviving Parent,

and Personal Representative of the Estate of
CHRISTOPHER BURFORD, Deceased;

JULIE BURKE, Individually, as surviving Spouse, and

Personal Representative of the Estate of THOMAS
DANIEL BURKE, Deceased;

ELIZABETH BURNS, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DONALD J. BURNS, Deceased;

SANDRA BURNSIDE, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOHN P. BURNSIDE, Deceased;

NGORAN DJE, Individually, as surviving Spouse, and

Personal Representative of the Estate of IRINA BUSLO,
Deceased;

MARTHA BUTLER, Individually, as surviving Spouse,

and Personal Representative of the Estate of THOMAS
M. BUTLER, Deceased;

9
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 10 of 30

JAMES C. CAHILL, Individually, as surviving Parent,

and Personal Representative of the Estate of SCOTT W.
CAHILL, Deceased;
LINDA CAHILL, as surviving Parent of SCOTT W.
CAHILL, Deceased;
PATRICK CAHILL, as surviving Sibling of SCOTT W.
CAHILL, Deceased;

JAMES W. CAHILL, Individually, as surviving Parent,

and Personal Representative of the Estate of THOMAS J.
CAHILL, Deceased;
KATHLEEN CAHILL, as surviving Parent of THOMAS
J. CAHILL, Deceased;
JAMES CAHILL, as surviving Sibling of THOMAS J.
CAHILL, Deceased;
KATHLEEN PSIROGIANES, as surviving Sibling of
THOMAS J. CAHILL, Deceased;
KERRY KERIN, as surviving Sibling of THOMAS J.
CAHILL, Deceased;
CHRISTOPHER CAHILL, as surviving Sibling of
THOMAS J. CAHILL, Deceased;

SUSAN CALCAGNO, Individually, as surviving

Spouse, and Personal Representative of the Estate of
PHILIP CALCAGNO, Deceased;

DEBORAH CALDERON, Individually, as surviving

Spouse, and Personal Representative of the Estate of
EDWARD CALDERON, Deceased;
IDA BRUNO, as surviving Parent of EDWARD
CALDERON, Deceased;
VICENTE CALDERON, as surviving Parent of
EDWARD CALDERON, Deceased;
CAROLINE OTERO, as surviving Sibling of EDWARD
CALDERON, Deceased;
VINCENT CALDERON, JR., as surviving Sibling of
EDWARD CALDERON, Deceased;
CATHY CALDERON, as surviving Sibling of
EDWARD CALDERON, Deceased;
MARIZA CALDERON, as surviving Sibling of
EDWARD CALDERON, Deceased;
ANTHONY CALDERON, as surviving Sibling of
EDWARD CALDERON, Deceased;

10
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 11 of 30

JANET CALIA-DONOHUE, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DOMINICK CALIA, Deceased;

VINCENT CANGELOSI, Individually, as surviving

Parent, and Personal Representative of the Estate of
VINCENT A. CANGELOSI, Deceased;
MICHELLE CANGELOSI, as surviving Parent of
VINCENT A. CANGELOSI, Deceased;

JACKIE CANNIZZARO, Individually, as surviving

Spouse, and Personal Representative of the Estate of
BRIAN CANNIZZARO, Deceased;

LORI CAPORICCI, Individually, as surviving Spouse,

and Personal Representative of the Estate of LOUIS
CAPORICCI, Deceased;

RICHARD PETER CARNEY, Individually, as surviving

Sibling, and Personal Representative of the Estate of
MARK CARNEY, Deceased;

PATRICIA CARRINGTON, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JEREMY CARRINGTON, Deceased;

TONI ANN CARROLL, Individually, as surviving

Spouse, and Personal Representative of the Estate of
PETER J. CARROLL, Deceased;

NANCY CARROLL, Individually, as surviving Spouse,

and Personal Representative of the Estate of MICHAEL
T. CARROLL, Deceased;
BRENDAN CARROLL, as surviving Child of
MICHAEL T. CARROLL, Deceased;
OLIVIA CARROLL, as surviving Child of MICHAEL
T. CARROLL, Deceased;
ELEANOR CARROLL, as surviving Parent of
MICHAEL T. CARROLL, Deceased;
NANCY AMIGRON, as surviving Sibling of MICHAEL
T. CARROLL, Deceased;

CARLOS CASORIA, Individually, as surviving Parent,

and Co-Personal Representative of the Estate of
THOMAS CASORIA, Deceased;

11
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 12 of 30

JUDITH CASORIA, Individually, as surviving Parent,

and Co-Personal Representative of the Estate of
THOMAS CASORIA, Deceased;

LEONARD A. CASTRIANNO, SR., Individually, as

surviving Parent, and Personal Representative of the
Estate of LEONARD M. CASTRIANNO, JR., Deceased;

SANTA CATARELLI, Individually, as surviving

Spouse, and Personal Representative of the Estate of
RICHARD G. CATARELLI, Deceased;
SANTA CATARELLI, on behalf of ANAMARIE
CATARELLI, minor, as surviving Child of RICHARD
G. CATARELLI, Deceased;

GINA CAYNE, Individually, as surviving Spouse, and

Personal Representative of the Estate of JASON
CAYNE, Deceased;
MARISSA CAYNE, as surviving Child of JASON
CAYNE, Deceased;
GINA CAYNE on behalf of RAQUEL CAYNE, minor,
as surviving Child of JASON CAYNE, Deceased;
SUZANN CAYNE, as surviving Child of JASON
CAYNE, Deceased;

GERALDINE CEFALU, Individually, as surviving

Parent, and Personal Representative of the Estate of
JASON CEFALU, Deceased;

BOB CHEATHAM, Individually, as surviving Spouse,

and Personal Representative of the Estate of DELROSE
FORBES CHEATHAM, Deceased;

SUK TAN CHIN, Individually, as surviving Sibling, and

Personal Representative of the Estate of ROBERT
CHIN, Deceased;
PAK HO CHIN, as surviving Parent of ROBERT CHIN,
Deceased;
YUET LING CHIN, as surviving Parent of ROBERT
CHIN, Deceased;

EDWARD CIAFARDINI, Individually, as surviving

Parent, and Personal Representative of the Estate of
CHRISTOPHER CIAFARDINI, Deceased;
MAGGIE CIAFARDINI, as surviving Parent of
CHRISTOPHER CIAFARDINI, Deceased;

12
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 13 of 30

DOMINIC CIAFARDINI, as surviving Sibling of

CHRISTOPHER CIAFARDINI, Deceased;

LISA DILALLO CLARK, Individually, as surviving

Spouse, and Personal Representative of the Estate of
THOMAS R. CLARK, Deceased;

YUKO CLARK, Individually, as surviving Spouse, and

Personal Representative of the Estate of GREGORY A.
CLARK, Deceased;

TANYA KIM DAVIS, Individually, as surviving Child,

and Personal Representative of the Estate of MANNIE L.
CLARK, Deceased;

ROBERT CLARK, Individually, as surviving Sibling,

and Personal Representative of the Estate of EUGENE
CLARK, Deceased;

CHARLES CLYNE, Individually, as surviving Spouse,

and Personal Representative of the Estate of SUSAN M.
CLYNE, Deceased;
MICHAEL CLYNE, as surviving Child of SUSAN M.
CLYNE, Deceased;
MARIE S. CLYNE, as surviving Child of SUSAN M.
CLYNE, Deceased;
KEVIN P. CLYNE, as surviving Child of SUSAN M.
CLYNE, Deceased;
TIMOTHY D. CLYNE, as surviving Child of SUSAN
M. CLYNE, Deceased;
GRACE DIETRICH, as surviving Parent of SUSAN M.
CLYNE, Deceased;
KURT H. DIETRICH, as surviving Sibling of SUSAN
M. CLYNE, Deceased;
LINDA G. CREAMER, as surviving Sibling of SUSAN
M. CLYNE, Deceased;

VINCENT COAKLEY, Individually, as surviving

Parent, and Personal Representative of the Estate of
STEVEN COAKLEY, Deceased;

SUSAN HUTCHINS, Individually, as surviving Parent,

and Personal Representative of the Estate of KEVIN
COLBERT, Deceased;
ANDREW COLBERT, as surviving Sibling of KEVIN
COLBERT, Deceased;

13
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 14 of 30

MATTHEW CARROLL, as surviving Sibling of KEVIN

COLBERT, Deceased;
ALEXANDER CARROLL, as surviving Sibling of
KEVIN COLBERT, Deceased;

MARYANN COLIN, Individually, as surviving Spouse,

and Personal Representative of the Estate of ROBERT D.
COLIN, Deceased;

JULIA COLLINS, Individually, as surviving Spouse, and

Personal Representative of the Estate of THOMAS J.
COLLINS, Deceased;

WARREN COLODNER, Individually, as surviving

Spouse, and Personal Representative of the Estate of
PATRICIA COLODNER, Deceased;

BENITO COLON, Individually, as surviving Spouse,

and Personal Representative of the Estate of SOL E.
COLON, Deceased;

PATRICIA COPPO, Individually, as surviving Spouse,

and Personal Representative of the Estate of JOSEPH J.
COPPO, JR., Deceased;

FELICIA JONES, Individually, as surviving Spouse, and

Personal Representative of the Estate of JOSEPH
CORBETT, Deceased;

SUSAN CORREA, Individually, and as Estate

Representative of the Estate of Ruben Correa, Deceased
and on behalf of all survivors of Ruben Correa;

LAURIE S. LAUTERBACH, Individually, as surviving

Spouse, and Personal Representative of the Estate of
CARLOS CORTES-RODRIGUEZ, Deceased;

PAULA HAYES, Individually, as surviving Spouse, and

Personal Representative of the Estate of CONROD
COTTOY, Deceased;

PATRICIA COUGHLIN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOHN G. COUGHLIN, Deceased;
ERIN COUGHLIN, as surviving Child of JOHN G.
COUGHLIN, Deceased;

14
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 15 of 30

TARA COUGHLIN, as surviving Child of JOHN G.

COUGHLIN, Deceased;
KAYLE COUGHLIN, as surviving Child of JOHN G.
COUGHLIN, Deceased;

DENNIS EULAU, Individually, as surviving Spouse,

and Personal Representative of the Estate of MICHELE
COYLE-EULAU, Deceased;
MATTHEW EULAU, as surviving Child of MICHELE
COYLE-EULAU, Deceased;
MARK EULAU, as surviving Child of MICHELE
COYLE-EULAU, Deceased;
DENNIS EULAU on behalf of ERIC EULAU, minor, as
surviving Child of MICHELE COYLE-EULAU,
Deceased;

JOHN T. CRANT, Individually, as surviving Spouse,

and Personal Representative of the Estate of DENISE
CRANT, Deceased;

LISA B. CRAWFORD, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JAMES L. CRAWFORD, JR., Deceased;
LISA B. CRAWFORD on behalf of ISABELLE
CRAWFORD, minor, as surviving Child of JAMES L.
CRAWFORD, JR., Deceased;

BERNARD PHAIR, Individually, as surviving Estate

Rep, and Personal Representative of the Estate of
JOANNE CREGAN, Deceased;

JOANN CROSS, Individually, as surviving Spouse, and

Personal Representative of the Estate of DENNIS A.
CROSS, Deceased;

MARIANNE CRUIKSHANK, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ROBERT CRUIKSHANK, Deceased;

ILDEFONSO A. CUA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
GRACE CUA, Deceased;

LINDA CURIA, Individually, as surviving Spouse, and

Personal Representative of the Estate of LAURENCE
CURIA, Deceased;

15
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 16 of 30

FREDERICK CURRY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
BEVERLY CURRY, Deceased;

DAVID E. CUSHING, Individually, as surviving

Spouse, and Personal Representative of the Estate of
PATRICIA CUSHING, Deceased;

LOUANNE BAILY, Individually, as surviving Spouse,

and Personal Representative of the Estate of BRIAN P.
DALE, Deceased;

LOUISA D'ANTONIO, Individually, as surviving Child,

and Personal Representative of the Estate of MARY
D'ANTONIO, Deceased;

ANGELA DANZ-DONOHUE, Individually, as

surviving Spouse, and Personal Representative of the
Estate of VINCENT DANZ, Deceased;
ANGELA DANZ-DONOHUE on behalf of ABIGAIL
DANZ, minor, as surviving Child of VINCENT DANZ,
Deceased;

LIDIA HERNANDEZ, Individually, as surviving Parent,

and Personal Representative of the Estate of MIRNA A.
DUARTE, Deceased;

PATRICIA DEAN, Individually, as surviving Spouse,

and Personal Representative of the Estate of WILLIAM
DEAN, Deceased;

PATRICIA J. DEANGELIS, Individually, as surviving

Spouse, and Personal Representative of the Estate of
THOMAS P. DEANGELIS, Deceased;

ERNESTO BARRERA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ANA DEBARRERA, Deceased;

MARION DEBLASE, Individually, as surviving Spouse,

and Personal Representative of the Estate of JAMES V.
DEBLASE, Deceased;

16
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 17 of 30

SOFIE CIRINELLI, Individually, as surviving Spouse,

and Personal Representative of the Estate of DAVID
DEFEO, Deceased;

WANDA HERNANDEZ, Individually, as surviving

Parent, and Personal Representative of the Estate of
MONIQUE E. DEJESUS, Deceased;

JAMES DELLA BELLA, Individually, as surviving

Child, and Personal Representative of the Estate of
ANDREA DELLA BELLA, Deceased;

CHRISTOPHER PIETRA, Individually, as surviving

Sibling, and Personal Representative of the Estate of
JOSEPH DELLA PIETRA, Deceased;

MICHAEL DELOUGHERY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
COLLEEN ANN DELOUGHERY, Deceased;
MICHAEL DELOUGHERY, as surviving Child of
COLLEEN ANN DELOUGHERY, Deceased;
AMANDA DELOUGHERY, as surviving Child of
COLLEEN ANN DELOUGHERY, Deceased;
PATRICIA MARRESE, as surviving Sibling of
COLLEEN ANN DELOUGHERY, Deceased;

VIVI DEMAS, Individually, as surviving Spouse, and

Personal Representative of the Estate of ANTHONY
DEMAS, Deceased;

BROOKE DEMING, Individually, as surviving Spouse,

and Personal Representative of the Estate of FRANCIS
DEMING, Deceased;

CURTIS F. BREWER, Individually, as surviving

Spouse, and Personal Representative of the Estate of
CAROL K. DEMITZ, Deceased;
ANNE K. BREWER, as surviving Child of CAROL K.
DEMITZ, Deceased;
CHARLES DEMITZ, as surviving Sibling of CAROL K.
DEMITZ, Deceased;
WOODY DEMITZ, as surviving Sibling of CAROL K.
DEMITZ, Deceased;
MICHAEL DEMITZ, as surviving Sibling of CAROL K.
DEMITZ, Deceased;

17
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 18 of 30

SUSAN DEMITZ, as surviving Sibling of CAROL K.

DEMITZ, Deceased;

CHRISTEL DESIMONE, Individually, as surviving

Parent, and Personal Representative of the Estate of
CHRISTIAN DESIMONE, Deceased;
MARTIN DESIMONE-CALISO, as surviving Sibling of
CHRISTIAN DESIMONE, Deceased;
TODD DEVITO, Individually, as surviving Child, and
Personal Representative of the Estate of JERRY
DEVITO, Deceased;

JOYCE DEVITT, Individually, as surviving Parent, and

Personal Representative of the Estate of ROBERT
DEVITT, JR., Deceased;

DONNA DI AGOSTINO, Individually, as surviving

Spouse, and Personal Representative of the Estate of
MICHAEL DI AGOSTINO, Deceased;
DONNA DI AGOSTINO on behalf of CHRISTINA DI
AGOSTINO, minor, as surviving Child of MICHAEL DI
AGOSTINO, Deceased;

LEONEL DIAZ, Individually, as surviving Sibling, and

Personal Representative of the Estate of NANCY DIAZ,
Deceased;

MARIA DI PILATO, Individually, as surviving Spouse,

and Personal Representative of the Estate of JOSEPH DI
PILATO, Deceased;
LEO DI PILATO, as surviving Child of JOSEPH DI
PILATO, Deceased;
JOSEPH DI PILATO, as surviving Child of JOSEPH DI
PILATO, Deceased;

JEFFREY SCHORPP, Individually, as surviving Spouse,

and Personal Representative of the Estate of MARISA
DINARDO SCHORPP, Deceased;

JOAN DINCUFF, Individually, as surviving Parent, and

Personal Representative of the Estate of CHRISTOPHER
DINCUFF, Deceased;
FRANK DINCUFF, as surviving Parent of
CHRISTOPHER DINCUFF, Deceased;
BETH DINCUFF, as surviving Sibling of
CHRISTOPHER DINCUFF, Deceased;

18
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 19 of 30

AMY DINCUFF, as surviving Sibling of

CHRISTOPHER DINCUFF, Deceased;

ANDY DINNOO, Individually, as surviving Spouse, and

Personal Representative of the Estate of RENA
DINNOO, Deceased;
DHANMATEE SAM, as surviving Parent of RENA
DINNOO, Deceased;
CLARENCE SAM, as surviving Sibling of RENA
DINNOO, Deceased;
LISA SAM, as surviving Sibling of RENA DINNOO,
Deceased;
GINA SAM, as surviving Sibling of RENA DINNOO,
Deceased;

DAVID DISTEFANO, Individually, as surviving

Sibling, and Personal Representative of the Estate of
DOUGLAS DISTEFANO, Deceased;

STACEY DOLAN, Individually, as surviving Spouse,

and Personal Representative of the Estate of BRENDAN
DOLAN, Deceased;

ROSALIE B. DOWNEY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
RAYMOND M. DOWNEY, Deceased;

MARY DUNNE, Individually, as surviving Parent, and

Personal Representative of the Estate of CHRISTOPHER
J. DUNNE, Deceased;
JAY DUNNE, as surviving Parent of CHRISTOPHER J.
DUNNE, Deceased;
COURTNEY DUNNE-KEENAN, as surviving Sibling
of CHRISTOPHER J. DUNNE, Deceased;
CYNTHIA DUNNE-WELCH, as surviving Sibling of
CHRISTOPHER J. DUNNE, Deceased;

GAIL EAGLESON, Individually, as surviving Spouse,

and Personal Representative of the Estate of JOHN B.
EAGLESON, Deceased;
BRETT EAGLESON, as surviving Child of JOHN B.
EAGLESON, Deceased;
KYLE EAGLESON, as surviving Child of JOHN B.
EAGLESON, Deceased;
TIMOTHY EAGLESON, as surviving Child of JOHN B.
EAGLESON, Deceased;

19
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 20 of 30

WILLIAM EAGLESON, as surviving Sibling of JOHN

B. EAGLESON, Deceased;

STANLEY ECKNA, Individually, as surviving Parent,

and Personal Representative of the Estate of PAUL
ECKNA, Deceased;

DAVID EGAN, Individually, as surviving Parent, and

Personal Representative of the Estate of LISA E. EGAN,
Deceased;

DAVID EGAN, Individually, as surviving Parent, and

Personal Representative of the Estate of SAMANTHA
M. EGAN, Deceased;

SAM ELLIS, Individually, as surviving Spouse, and

Personal Representative of the Estate of VALERIE S.
ELLIS, Deceased;

EILEEN ERWIN-MICHAEL, Individually, as surviving

Spouse, and Personal Representative of the Estate of
WILLIAM ERWIN, Deceased;

LUIS ESPINOZA, Individually, as surviving Spouse,

and Personal Representative of the Estate of FANNY
ESPINOZA, Deceased;
CHRISTIAN ESPINOZA, as surviving Child of FANNY
ESPINOZA, Deceased;
STEPHANIE ESPINOZA, as surviving Child of
FANNY ESPINOZA, Deceased;

JEANNE M. EVANS, Individually, as surviving Sibling,

and Personal Representative of the Estate of ROBERT
EVANS, Deceased;

LAURA FALLON, Individually, as surviving Spouse,

and Personal Representative of the Estate of WILLIAM
FALLON, JR., Deceased;

PATRICIA FALLONE, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ANTHONY FALLONE, Deceased;

MAUREEN FANNING, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOHN FANNING, Deceased;

20
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 21 of 30

AMY POLMAR, Individually, as surviving Spouse, and

Personal Representative of the Estate of DOUGLAS
FARNUM, Deceased;

MARYANNE FARRELL, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOHN FARRELL, Deceased;

MELISSA VAN NESS FATHA, Individually, as

surviving Spouse, and Personal Representative of the
Estate of SYED ABDUL FATHA, Deceased;

STEVEN FEIDELBERG, Individually, as surviving

Sibling, and Personal Representative of the Estate of
PETER FEIDELBERG, Deceased;

WENDY S. FEINBERG, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ALAN FEINBERG, Deceased;
MICHAEL FEINBERG, as surviving Child of ALAN
FEINBERG, Deceased;
TARA FEINBERG EDGETTE, as surviving Child of
ALAN FEINBERG, Deceased;

MARY L. FERGUSON, Individually, as surviving

Spouse, and Personal Representative of the Estate of
GEORGE J. FERGUSON, III, Deceased;
MATTHEW FERGUSON, as surviving Child of
GEORGE J. FERGUSON, III, Deceased;

JULIO C. FERNANDEZ, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JULIO FERNANDEZ, Deceased;

CHARLENE FIORE, Individually, as surviving Spouse,

and Personal Representative of the Estate of MICHAEL
FIORE, Deceased;
JESSICA FIORE LACASSE, as surviving Child of
MICHAEL FIORE, Deceased;
CRISTEN FIORE STAIANO, as surviving Child of
MICHAEL FIORE, Deceased;
MICHAEL FIORE, as surviving Child of MICHAEL
FIORE, Deceased;

21
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 22 of 30

BRIAN FLANNERY, Individually, as surviving Spouse,

and Personal Representative of the Estate of
CHRISTINA FLANNERY, Deceased;

LORI FLETCHER, Individually, as surviving Spouse,

and Personal Representative of the Estate of ANDRE
FLETCHER, Deceased;

NANCY WALSH, Individually, as surviving Partner,

and Co-Personal Representative of the Estate of CAROL
FLYZIK, Deceased;

CLAUDIA FLYZIK, Individually, as surviving Sibling,

and Co-Personal Representative of the Estate of CAROL
FLYZIK, Deceased;

JOANNE GROSS, Individually, as surviving Sibling,

and Personal Representative of the Estate of THOMAS
FOLEY, Deceased;

ROBERT T. FOLGER, Individually, as surviving Child,

and Personal Representative of the Estate of JANE
FOLGER, Deceased;
KATHLEEN KULIK, as surviving Child of JANE
FOLGER, Deceased;
THOMAS FOLGER, as surviving Child of JANE
FOLGER, Deceased;
MICHAEL FOLGER, as surviving Child of JANE
FOLGER, Deceased;

MARIAN FONTANA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DAVID J. FONTANA, Deceased;

KURT FOSTER, Individually, as surviving Spouse, and

Personal Representative of the Estate of CLAUDIA
FOSTER, Deceased;

TIERNEY TRAMONTOZZI, Individually, as surviving

Spouse, and Personal Representative of the Estate of
KEVIN FRAWLEY, Deceased;

JEANINE L. FRAZIER, Individually, as surviving

Spouse, and Personal Representative of the Estate of
CLYDE FRAZIER, JR., Deceased;

22
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 23 of 30

MICHELLE FREDERICKS, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ANDREW FREDERICKS, Deceased;
ANDREW J, FREDERICKS, as surviving Child of
ANDREW FREDERICKS, Deceased;
HAYLEY FREDERICKS, as surviving Child of
ANDREW FREDERICKS, Deceased;

ROBIN A. FREUND, Individually, as surviving Spouse,

and Personal Representative of the Estate of PETER L.
FREUND, Deceased;
JULIE A. FREUND, as surviving Child of PETER L.
FREUND, Deceased;

KENNETH FRIED, Individually, as surviving Spouse,

and Personal Representative of the Estate of ARLENE
FRIED, Deceased;

HELEN FRIEDLANDER DEL SINDACO, Individually,

as surviving Spouse, and Personal Representative of the
Estate of ALAN W. FRIEDLANDER, Deceased;

LISA FRIEDMAN-CLARK, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ANDREW FRIEDMAN, Deceased;
MIKE FRIEDMAN, as surviving Child of ANDREW
FRIEDMAN, Deceased;
DAN FRIEDMAN, as surviving Child of ANDREW
FRIEDMAN, Deceased;

MEREDITH FRY, Individually, as surviving Spouse,

and Personal Representative of the Estate of PETER
FRY, Deceased;
TAYLOR MCCLINTOCK FRY, as surviving Child of
PETER FRY, Deceased;
CALEY LOOMIS FRY, as surviving Child of PETER
FRY, Deceased;
CHARLES GORDON FRY, as surviving Parent of
PETER FRY, Deceased;

ANNE GABRIEL, Individually, as surviving Spouse,

and Personal Representative of the Estate of RICHARD
P. GABRIEL, Deceased;
ROBERT CALLANAN, as surviving Stepchild of
RICHARD P. GABRIEL, Deceased;

23
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 24 of 30

MONICA GABRIELLE, Individually, as surviving

Spouse, and Personal Representative of the Estate of
RICHARD S. GABRIELLE, Deceased;

FRANCINE GALLAGHER, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOHN P. GALLAGHER, Deceased;

MILAGROS DIAZ, Individually, as surviving Parent,

and Personal Representative of the Estate of LOURDES
JANET GALLETTI, Deceased;

MANUELA NITA-VAZQUEZ, Individually, as

surviving Spouse, and Personal Representative of the
Estate of CONO GALLO, Deceased;
RAFFAELA GALLO, as surviving Parent of CONO
GALLO, Deceased;
EMILIO GALLO, as surviving Parent of CONO
GALLO, Deceased;
LISA GALLO, as surviving Sibling of CONO GALLO,
Deceased;
JOHN GALLO, as surviving Sibling of CONO GALLO,
Deceased;

KATHLEEN GANCI, Individually, as surviving Spouse,

and Personal Representative of the Estate of PETER J.
GANCI, Deceased;

DOROTHY GARCIA-BACHLER, Individually, as

surviving Spouse, and Personal Representative of the
Estate of ANDREW GARCIA, Deceased;

HECTOR & CARMEN GARCIA, Individually, as

surviving Parent, and Personal Representative of the
Estate of MARLYN C. GARCIA, Deceased;

ELIZABETH GARDNER, Individually, as surviving

Spouse, and Personal Representative of the Estate of
THOMAS GARDNER, Deceased;

ELISABET GARDNER, Individually, as surviving

Spouse, and Personal Representative of the Estate of
WILLIAM GARDNER, Deceased;

24
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 25 of 30

ANTONIA GARGANO, Individually, as surviving

Parent, and Personal Representative of the Estate of
ROCCO N. GARGANO, Deceased;

JILL A. GARTENBERG PILA, Individually, as

surviving Spouse, and Personal Representative of the
Estate of JAMES GARTENBERG, Deceased;
JILL A. GARTENBERG PILA on behalf of NICOLE
HOLLY GARTENBERG PILA, minor, as surviving
Child of JAMES GARTENBERG, Deceased;
JILL A. GARTENBERG PILA on behalf of JAMIE
MICHELLE GARTENBERG PILA, minor, as surviving
Child of JAMES GARTENBERG, Deceased;

MICHELLE GELINAS, Individually, as surviving

Spouse, and Personal Representative of the Estate of
PETER GELINAS, Deceased;
JACK G. GELINAS, as surviving Child of PETER
GELINAS, Deceased;
GRIFFIN C. GELINAS, as surviving Child of PETER
GELINAS, Deceased;

DEBRA GELLER, Individually, as surviving Spouse,

and Personal Representative of the Estate of STEVEN
GELLER, Deceased;

DIANE GENCO, Individually, as surviving Spouse, and

Personal Representative of the Estate of PETER V.
GENCO, JR., Deceased;

EILEEN GERATY, Individually, and as Estate

Administrator of the Estate of Suzanne Geraty, Deceased
and on behalf of all survivors of Suzanne Geraty;

PHILIP GERMAIN, Individually, as surviving Parent,

and Personal Representative of the Estate of DENIS
GERMAIN, Deceased;
MICHAEL GERMAIN, as surviving Sibling of DENIS
GERMAIN, Deceased;
BRIAN GERMAIN, as surviving Sibling of DENIS
GERMAIN, Deceased;
PEGGY DOBRINSKI, as surviving Sibling of DENIS
GERMAIN, Deceased;
THERESA RUTHER, as surviving Sibling of DENIS
GERMAIN, Deceased;

25
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 26 of 30

SONDRA GIACCONE, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOSEPH GIACCONE, Deceased;
ALEXANDRA GIACCONE, as surviving Child of
JOSEPH GIACCONE, Deceased;
MAX GIACCONE, as surviving Child of JOSEPH
GIACCONE, Deceased;
JAMES GIACCONE, as Personal Representative of the
Estate of ELIZABETH GIACCONE, Deceased,
surviving parent of JOSEPH GIACCONE;
JAMES GIACCONE, as Personal Representative of the
Estate of VINCENT GIACCONE, Deceased, surviving
parent of JOSEPH GIACCONE;
ELISABETH FELDON, as surviving Sibling of JOSEPH
GIACCONE, Deceased;
JAMES GIACCONE, as surviving Sibling of JOSEPH
GIACCONE, Deceased;
MICHAEL GIACCONE, as surviving Sibling of
JOSEPH GIACCONE, Deceased;

CAROL GIES, Individually, as surviving Spouse, and

Personal Representative of the Estate of RONNIE E.
GIES, Deceased;

LORRAINE MARCHESE, Individually, as surviving

Parent, and Personal Representative of the Estate of
LAURA A. MARCHESE GIGLIO, Deceased;

MARIANN COYLE, Individually, as surviving Spouse,

and Personal Representative of the Estate of ANDREW
GILBERT, Deceased;

JOHN J. GILL, JR., Individually, as surviving Parent,

and Personal Representative of the Estate of PAUL J.
GILL, Deceased;

SERINA GILLIS, Individually, as surviving Ex-Spouse

of / Not Solatium, and Personal Representative of the
Estate of RODNEY C. GILLIS, Deceased;
JONIQUE C. GILLIS, as surviving Child of RODNEY
C. GILLIS, Deceased;
ALEESIA C. GILLIS, as surviving Child of RODNEY
C. GILLIS, Deceased;
RODNEY C. GILLIS, II, as surviving Child of
RODNEY C. GILLIS, Deceased;

26
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 27 of 30

ROXANN GIORDANO, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOHN GIORDANO, Deceased;

ARMINE GIORGETTI, Individually, as surviving

Spouse, and Personal Representative of the Estate of
STEVEN A. GIORGETTI, Deceased;
PAUL GIORGETTI, as surviving Child of STEVEN A.
GIORGETTI, Deceased;
ALEXA GIORGETTI, as surviving Child of STEVEN
A. GIORGETTI, Deceased;

ANGELA GITTO, Individually, as surviving Spouse,

and Personal Representative of the Estate of
SALVATORE GITTO, Deceased;
GREGORY GITTO, as surviving Child of
SALVATORE GITTO, Deceased;
STEPHEN GITTO, as surviving Child of SALVATORE
GITTO, Deceased;

LAWRENCE GIUGLIANO, Individually, as surviving

Spouse, and Personal Representative of the Estate of
CYNTHIA GIUGLIANO, Deceased;

MEG BLOOM GLASSER, Individually, as surviving

Spouse, and Personal Representative of the Estate of
THOMAS GLASSER, Deceased;

CANDY GLAZER, Individually, as surviving Spouse,

and Personal Representative of the Estate of EDMUND
GLAZER, Deceased;

SHARON COBB-GLENN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
HARRY GLENN, Deceased;

HELENE GNAZZO, Individually, as surviving Spouse,

and Personal Representative of the Estate of JOHN T.
GNAZZO, Deceased;
JULE GNAZZO, as surviving Child of JOHN T.
GNAZZO, Deceased;
JOHN GNAZZO, as surviving Child of JOHN T.
GNAZZO, Deceased;

27
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 28 of 30

JODIE GOLDBERG SHERER, Individually, as

surviving Spouse, and Personal Representative of the
Estate of BRIAN GOLDBERG, Deceased;

LACHANZE GOODING, Individually, as surviving

Spouse, and Personal Representative of the Estate of
CALVIN J. GOODING, Deceased;

RACHEL W. GOODRICH, Individually, as surviving

Spouse, and Personal Representative of the Estate of
PETER GOODRICH, Deceased;

DAVID DWIGHT NELSON, Individually, as surviving

Child, and Personal Representative of the Estate of
KERENE GORDON, Deceased;

LLOYD C. MAIR, Individually, as surviving Sibling,

and Personal Representative of the Estate of LINDA C.
MAIR GRAYLING, Deceased;
ISA S. MARTIN, as surviving Child of LINDA C.
MAIR GRAYLING, Deceased;
YVONNE D. RAMIREZ, as surviving Sibling of
LINDA C. MAIR GRAYLING, Deceased;
ROGER B. MAIR, as surviving Sibling of LINDA C.
MAIR GRAYLING, Deceased;
ANNETTE MAIR, as surviving Sibling of LINDA C.
MAIR GRAYLING, Deceased;
IRENE L. MAIR, as surviving Sibling of LINDA C.
MAIR GRAYLING, Deceased;

CLAUDETTE B. GREENE, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DONALD GREENE, Deceased;
CHARLES GREENE, as surviving Child of DONALD
GREENE, Deceased;
JODY GREENE, as surviving Child of DONALD
GREENE, Deceased;

PETER GREENLEAF, Individually, as surviving

Sibling, and Personal Representative of the Estate of
JAMES GREENLEAF, Deceased;
PATRICIA GREENLEAF, as surviving Parent of
JAMES GREENLEAF, Deceased;

28
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 29 of 30

JOHN F. GREGORY, Individually, as surviving Parent,

and Personal Representative of the Estate of FLORENCE
M. GREGORY, Deceased;

BOBBY GRIFFIN, Individually, as surviving Spouse,

and Personal Representative of the Estate of TAWANNA
GRIFFIN, Deceased;

MARY JO GRILLO, Individually, as surviving Spouse,

and Personal Representative of the Estate of JOSEPH
GRILLO, Deceased;
MATTHEW GRILLO, as surviving Child of JOSEPH
GRILLO, Deceased;
TIMOTHY GRILLO, as surviving Child of JOSEPH
GRILLO, Deceased;
JOSEPH GRILLO, as surviving Parent of JOSEPH
GRILLO, Deceased;
STEVEN GRILLO, as surviving Sibling of JOSEPH
GRILLO, Deceased;

SUSAN MALLERY GURIAN, Individually, as

surviving Spouse, and Personal Representative of the
Estate of DOUGLAS B. GURIAN, Deceased;
MARY HAAG, Individually, as surviving Spouse, and
Personal Representative of the Estate of GARY HAAG,
Deceased;
MICHAEL P. HAAG, as surviving Child of GARY
HAAG, Deceased;
KEVIN T. HAAG, as surviving Child of GARY HAAG,
Deceased;
MARY HAAG on behalf of MOLLY M. HAAG, minor,
as surviving Child of GARY HAAG, Deceased;

GORDON HABERMAN, Individually, as surviving

Parent, and Personal Representative of the Estate of
ANDREA L. HABERMAN, Deceased;
KATHLEEN HABERMAN, as surviving Parent of
ANDREA L. HABERMAN, Deceased;
JULIE ANN HABERMAN OSMUS, as surviving
Sibling of ANDREA L. HABERMAN, Deceased;

LENA WHITTAKER, Individually, as surviving Parent,

and Personal Representative of the Estate of KAREN E.
HAGERTY, Deceased;

29
 Case 1:17-cv-02003 Document 1 Filed 03/20/17 Page 30 of 30

PATRICIA HAN, Individually, as surviving Spouse, and

Personal Representative of the Estate of FREDERICK K.
HAN, Deceased;
ERIC JAY HAN, as surviving Child of FREDERICK K.
HAN, Deceased;
PATRICIA HAN, as Personal Representative of the
Estate of, KIM HAN, Deceased, surviving Parent of
FREDERICK K. HAN;

RENE B. HANNAFIN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
THOMAS HANNAFIN, Deceased;

CAROL HARAN, Individually, as surviving Spouse, and

Personal Representative of the Estate of JAMES
HARAN, Deceased;

MARGARET HARRELL, Individually, as surviving

Spouse, and Personal Representative of the Estate of
STEPHEN G. HARRELL, Deceased;

RACHEL R. HARRELL, Individually, as surviving

Spouse, and Personal Representative of the Estate of
HARVEY L. HARRELL, Deceased;

SHEILA HARRIS, Individually, as surviving Spouse,

and Personal Representative of the Estate of STEWART
D. HARRIS, Deceased;
ELISSA HARRIS, as surviving Child of STEWART D.
HARRIS, Deceased;
CRAIG HARRIS, as surviving Child of STEWART D.
HARRIS, Deceased;

ELINORE HARTZ, Individually, as surviving Spouse,

and Personal Representative of the Estate of JOHN C.
HARTZ, Deceased;

JENNIFER HARVEY-TRAINOR, Individually, as

surviving Spouse, and Personal Representative of the
Estate of EMERIC J. HARVEY, Deceased;
MARIE HARVEY RYAN, as surviving Sibling of
EMERIC J. HARVEY, Deceased;

JOANNE HATTON, Individually, as surviving Spouse,

and Personal Representative of the Estate of LEONARD
HATTON, Deceased;

30
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 1 of 29

DLORES LEGREE, Individually, as surviving Parent,

and Personal Representative of the Estate of ANTHONY
HAWKINS, Deceased;

VIRGINIA HAYES, Individually, as surviving Spouse,

and Personal Representative of the Estate of PHILLIP T.
HAYES, Deceased;

ANN R. HAYNES, Individually, as surviving Spouse,

and Personal Representative of the Estate of WILLIAM
W. HAYNES, Deceased;

THERESA HEALEY, Individually, as surviving Spouse,

and Personal Representative of the Estate of MICHAEL
HEALEY, Deceased;

SHIRLEY HENDERSON, Individually, as surviving

Spouse, and Personal Representative of the Estate of
RONNIE LEE HENDERSON, Deceased;

DIGNA HERNANDEZ, Individually, as surviving

Spouse, and Personal Representative of the Estate of
RAUL HERNANDEZ, Deceased;

LIDIA HERNANDEZ, Individually, as surviving Parent,

and Personal Representative of the Estate of MIRNA A.
DUARTE, Deceased;

DONNA HICKEY, Individually, and as Estate

Representative of the Estate of Brian Hickey, Deceased
and on behalf of all survivors of Brian Hickey;

VICTORIA PRATT, Individually, as surviving Spouse,

and Personal Representative of the Estate of ROBERT
HIGLEY, Deceased;

KAREN HINDS, Individually, as surviving Spouse, and

Personal Representative of the Estate of NEIL HINDS,
Deceased;
KAREN HINDS, on behalf of JAMEER HINDS, minor,
as surviving Child of NEIL HINDS, Deceased;
KAREN GREENE, as surviving Sibling of NEIL
HINDS, Deceased;
COLEEN HINDS, as surviving Sibling of NEIL HINDS,
Deceased;

31
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 2 of 29

ETHLYN HINDS, as surviving Parent of NEIL HINDS,

Deceased;
WADE-ROY HINDS, as surviving Sibling of NEIL
HINDS, Deceased;
KAREN GREENE as Personal Representative of the
Estate of COLLIN HINDS, Deceased, surviving Parent
of NEIL HINDS;

DIXIE HOBBS, Individually, as surviving Parent, and

Personal Representative of the Estate of TARA HOBBS,
Deceased;
DENNIS HOBBS, as surviving Parent of TARA Y.
HOBBS, Deceased;
TAMMY HOBBS GINSBERG, as surviving Sibling of
TARA Y. HOBBS, Deceased;
SONYA HOBBS CUFFEE, as surviving Sibling of
TARA Y. HOBBS, Deceased;
REGINALD HOBBS, as surviving Sibling of TARA Y.
HOBBS, Deceased;
SHERIAN HOBBS LIGHTFOOT, as surviving Sibling
of TARA Y. HOBBS, Deceased;

ALLISON HOBBS, Individually, as surviving Spouse,

and Personal Representative of the Estate of THOMAS
A. HOBBS, Deceased;

JAMES S. HOFFMAN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
MARCIA HOFFMAN, Deceased;

PAMELA HOHLWECK, Individually, as surviving

Spouse, and Personal Representative of the Estate of
THOMAS W. HOHLWECK, JR., Deceased;

ROSEMARIE HOHMANN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOHNATHAN HOHMANN, Deceased;

KATHLEEN HOLLAND, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOSEPH HOLLAND, Deceased;

COLLEEN M. HOLOHAN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
THOMAS P. HOLOHAN, Deceased;

32
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 3 of 29

KATHERINE HOORN, Individually, as surviving

Parent, and Personal Representative of the Estate of
BRADLEY HOORN, Deceased;
DENNIS HOORN, as surviving Parent of BRADLEY
HOORN, Deceased;
KARA HOORN, as surviving Sibling of BRADLEY
HOORN, Deceased;

CHRISTOPHER HOWARD, Individually, as surviving

Child, and Personal Representative of the Estate of
GEORGE G, HOWARD, Deceased;

JOANN T. HOWARD, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOSEPH L. HOWARD, Deceased;
JOSEPH HOWARD, as surviving Child of JOSEPH L.
HOWARD, Deceased;
JANICE HOWARD-BATTAGLIA, as surviving Child
of JOSEPH L. HOWARD, Deceased;
ANNE GALIZIA, as surviving Sibling of JOSEPH L.
HOWARD, Deceased;
SUSAN REIDLINGER, as surviving Sibling of JOSEPH
L. HOWARD, Deceased;

JOSEPH HROMADA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
MILAGROS HROMADA, Deceased;

KAREN HUGHES, Individually, as surviving Spouse,

and Personal Representative of the Estate of TIMOTHY
F. HUGHES, Deceased;

BRIDGET HUNTER, Individually, as surviving Parent,

and Personal Representative of the Estate of JOSEPH G.
HUNTER, Deceased;
BRIDGET HUNTER, as Personal Representative of the
Estate of JOSEPH HUNTER, Deceased, surviving Parent
of JOSEPH G. HUNTER;
SEAN HUNTER, as surviving Sibling of JOSEPH G.
HUNTER, Deceased;
TERESA LABO, as surviving Sibling of JOSEPH G.
HUNTER, Deceased;

KATHRYN J. HUSSA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ROBERT R. HUSSA, Deceased;

33
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 4 of 29

ROBERT HUSSA, as surviving Child of ROBERT R.

HUSSA, Deceased;
THOMAS HUSSA, as surviving Child of ROBERT R.
HUSSA, Deceased;

YESENIA IELPI, Individually, as surviving Spouse, and

Personal Representative of the Estate of JONATHAN
IELPI, Deceased;

YELENA ROMANOFF, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DANIEL ILKANAYEV, Deceased;

MARY ILL, Individually, and as Estate

Representative of the Estate of Frederick J. Ill, Jr., Deceased
and on behalf of all survivors of Frederick J. Ill, Jr.;

KENNETH IRBY, Individually, as surviving Sibling,

and Personal Representative of the Estate of
STEPHANIE IRBY, Deceased;
KENNETH IRBY as Personal Representative of the
Estate of FREDERICK IRBY, Deceased, surviving
Parent of STEPHANIE IRBY, Deceased;
KENNETH IRBY as Personal Representative of the
Estate of AGNES IRBY, Deceased, surviving Parent of
STEPHANIE IRBY, Deceased;

MARGARET ISKYAN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOHN ISKYAN, Deceased;
PAUL ISKYAN, as surviving Sibling of JOHN
ISKYAN, Deceased;
LAURA ISKYAN, as surviving Sibling of JOHN
ISKYAN, Deceased;
JOAN O'BRIEN, as surviving Sibling of JOHN
ISKYAN, Deceased;

BARBARA JACKMAN, Individually, as surviving

Parent, and Personal Representative of the Estate of
BROOKE A. JACKMAN, Deceased;
ERIN JACKMAN, as surviving Sibling of BROOKE A.
JACKMAN, Deceased;
ROSS JACKMAN, as surviving Sibling of BROOKE A.
JACKMAN, Deceased;
BARBARA JACKMAN, as Personal Representative of
the Estate of ROBERT JACKMAN, Deceased, surviving
Parent of BROOKE A. JACKMAN;

34
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 5 of 29

JENNIFER JACOBS, Individually, as surviving Spouse,

and Personal Representative of the Estate of ARIEL L.
JACOBS, Deceased;

KAZIMIERZ JAKUBIAK, Individually, as surviving

Spouse, and Personal Representative of the Estate of
MARIA JAKUBIAK, Deceased;

JU-HSIU JIAN, Individually, as surviving Spouse, and

Personal Representative of the Estate of HWEIDAR
JIAN, Deceased;
WILLIAM JIAN, as surviving Child of HWEIDAR
JIAN, Deceased;
KEVIN JIAN, as surviving Child of HWEIDAR JIAN,
Deceased;

JOY & WILLIAM JOHNSON, Individually, and as Parents

and Estate Representatives of the Estate of William Johnson,
Jr., Deceased and on behalf of all survivors of William
Johnson, Jr.;

CAROL FRANCOLINI, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ARTHUR J. JONES III, Deceased;

LEILA M. JOSEPH, Individually, as surviving Sibling,

and Personal Representative of the Estate of KARL H.
JOSEPH, Deceased;

AMBER MILLER, Individually, as surviving Child, and

Co-Personal Representative of the Estate of KAREN
JUDAY, Deceased;
JAMIE MILLER, Individually, as surviving Child, and
Co-Personal Representative of the Estate of KAREN
JUDAY, Deceased;

JAN KANDELL, Individually, as surviving Child, and

Personal Representative of the Estate of SHARI
KANDELL, Deceased;

EMILY TERRY, Individually, as surviving Spouse, and

Personal Representative of the Estate of ANDREW
KATES, Deceased;
EMILY TERRY on behalf of DANIEL HENRY
KATES, minor, as surviving Child of ANDREW
KATES, Deceased;

35
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 6 of 29

GEORGE KATSIMATIDES, Individually, as surviving

Sibling, and Personal Representative of the Estate of
JOHN KATSIMATIDES, Deceased;

ELIZABETH H. KELLER-BAKER, Individually, as

surviving Spouse, and Personal Representative of the
Estate of CHANDLER KELLER, Deceased;

ROBERTA KELLERMAN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
PETER R. KELLERMAN, Deceased;

PATRICIA KELLETT, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOSEPH P. KELLETT, Deceased;
JULIE ANNE KELLETT, as surviving Child of JOSEPH
P. KELLETT, Deceased;
CAMERON KELLETT, as surviving Child of JOSEPH
P. KELLETT, Deceased;
JOSEPH CALLAHAN, Esq. as Personal Representative
of the Estate of ANN SULLIVAN, Deceased, surviving
Parent of JOSEPH P. KELLETT;

JEAN FARRELL, Individually, as surviving Sibling, and

Personal Representative of the Estate of THOMAS R.
KELLY, Deceased;

SUSAN KELLY, Individually, as surviving Spouse, and

Personal Representative of the Estate of JOSEPH A.
KELLY, Deceased;
CHRISTOPHER KELLY, as surviving Child of JOSEPH
A. KELLY, Deceased;
THOMAS KELLY, as surviving Child of JOSEPH A.
KELLY, Deceased;
CAROLINE KELLY, as surviving Child of JOSEPH A.
KELLY, Deceased;
CATHERINE KELLY, as surviving Child of JOSEPH
A. KELLY, Deceased;
TIMOTHY KELLY, as surviving Child of JOSEPH A.
KELLY, Deceased;

MAUREEN KENNEDY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ROBERT C, KENNEDY, Deceased;

36
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 7 of 29

LEIGH KENNEDY, Individually, as surviving Child,

and Personal Representative of the Estate of YVONNE
KENNEDY, Deceased;
SIMON KENNEDY, as surviving Child of YVONNE
KENNEDY, Deceased;

ELLA KHALIF, Individually, as surviving Spouse, and

Personal Representative of the Estate of BORIS
KHALIF, Deceased;
STEVEN KHALIF, as surviving Child of BORIS
KHALIF, Deceased;

PAUL KIM, Individually, as surviving Parent, and

Personal Representative of the Estate of ANDREW KIM,
Deceased;

THERESA KING, Individually, as surviving Spouse, and

Personal Representative of the Estate of ROBERT
KING, Deceased;
STEPHEN J. KING, as surviving Child of ROBERT
KING, Deceased;

VERONICA KLARES, Individually, as surviving

Spouse, and Personal Representative of the Estate of
RICHARD J. KLARES, Deceased;

DONNA KLITZMAN, Individually, as surviving

Sibling, and Co-Personal Representative of the Estate of
KAREN KLITZMAN, Deceased;
SUSAN KLITZMAN, Individually, as surviving Sibling,
and Co-Personal Representative of the Estate of KAREN
KLITZMAN, Deceased;

IRINA DUBENSKAYA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
EUGUENI KNIAZEV, Deceased;

MARION KNOX, Individually, as surviving Spouse, and

Personal Representative of the Estate of ANDREW
KNOX, Deceased;

ARSEN KOLPAKOV, Individually, as surviving Child,

and Personal Representative of the Estate of IRINA
KOLPAKOVA, Deceased;

37
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 8 of 29

YUN YU ZHENG, Individually, as surviving Spouse,

and Personal Representative of the Estate of RAYMOND
KUI FAI KWOK, Deceased;

MARIE HUNCHAK, Individually, as surviving Sibling,

and Personal Representative of the Estate of ANDREW
LA CORTE, Deceased;

SHERI ANNE LADLEY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JAMES P. LADLEY, Deceased;

FRANCES A. LAFORTE, Individually, as surviving

Spouse, and Personal Representative of the Estate of
MICHAEL P. LAFORTE, Deceased;
ANDREA LAFORTE, as surviving Child of MICHAEL
P. LAFORTE, Deceased;
RAYMOND M. LAFORTE, as surviving Child of
MICHAEL P. LAFORTE, Deceased;
FRANCES A. LAFORTE on behalf of MICHAEL
LAFORTE, as surviving Child of MICHAEL P.
LAFORTE, Deceased;

EDLENE C. LAFRANCE, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ALAN LAFRANCE, Deceased;

COLETTE M. LAFUENTE, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JUAN LAFUENTE, Deceased;

CAROL LAIETA, Individually, as surviving Spouse, and

Personal Representative of the Estate of VINCENT
LAIETA, Deceased;

KIMBERLY S. LAMANTIA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
STEPHEN LAMANTIA, Deceased;

MORRIS D. LAMONSOFF, Individually, as surviving

Parent, and Personal Representative of the Estate of
AMY LAMONSOFF, Deceased;
WENDY MCENEANY, as surviving Sibling of AMY
LAMONSOFF, Deceased;
STEVEN LAMONSOFF, as surviving Sibling of AMY
LAMONSOFF, Deceased;

38
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 9 of 29

DAVID J. CHAZIN, Individually, as surviving Spouse,

and Personal Representative of the Estate of RUTH
LAPIN, Deceased;

HARLENE LARRY, Individually, as surviving Spouse,

and Personal Representative of the Estate of HAMIDOU
S. LARRY, Deceased;

KIM L. LASKO, Individually, as surviving Spouse, and

Personal Representative of the Estate of GARY E.
LASKO, Deceased;

LAURA J. LASSMAN, Individually, as surviving

Parent, and Personal Representative of the Estate of
NICHOLAS LASSMAN, Deceased;

MARCELLA LEAHY, Individually, and as Estate

Representative of the Estate of James P. Leahy, Deceased
and on behalf of all survivors of James P. Leahy;

ANDREA N. LEBLANC, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ROBERT LEBLANC, Deceased;
PAUL LEBLANC, as surviving Child of ROBERT
LEBLANC, Deceased;
NISSA YOUNGREN, as surviving Stepchild of
ROBERT LEBLANC, Deceased;

NANCY LYNN ZUCKERMAN, Individually, as

surviving Spouse, and Personal Representative of the
Estate of ALAN J. LEDERMAN, Deceased;

KAREN LEE, Individually, as surviving Spouse, and

Personal Representative of the Estate of RICHARD Y.C.
LEE, Deceased;

MEI JY LEE, Individually, as surviving Child, and

Personal Co-Representative of the Estate of YANG DER
LEE, Deceased;
PHILIP LEE, Individually, as surviving Child, and
Personal Co-Representative of the Estate of YANG DER
LEE, Deceased;

JIN HEE KIM, Individually, as surviving Spouse, and

Personal Representative of the Estate of HYUN JOON
LEE, Deceased;

39
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 10 of 29

MARIA LEGRO, Individually, as surviving Sibling, and

Personal Representative of the Estate of ADRIANA
LEGRO, Deceased;
JEANETTE LEGRO, as surviving Sibling of ADRIANA
LEGRO, Deceased;
JUAN LEGRO, as surviving Sibling of ADRIANA
LEGRO, Deceased;

DONALD LEISTMAN, as Personal Representative of

the Estate of DAVID R. LEISTMAN, Deceased;
MARYCLAIR LEISTMAN, as surviving Spouse, and
Personal Representative of the Estate of DAVID R.
LEISTMAN, Deceased;

INGRID LENIHAN, Individually, as surviving Spouse,

and Personal Representative of the Estate of JOSEPH A.
LENIHAN, Deceased;

SUSAN LENOIR, Individually, as surviving Spouse, and

Personal Representative of the Estate of JOHN
ROBINSON LENOIR, Deceased;

CHRISTINE LEVEEN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JEFFERY E. LEVEEN, Deceased;

CHRISTY FERER, Individually, as surviving Spouse,

and Personal Representative of the Estate of NEIL D.
LEVIN, Deceased;

ROBERTA J. LEVINE, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ROBERT M. LEVINE, Deceased;

MELVIN LEWIS, Individually, as surviving Child, and

Personal Representative of the Estate of MARGARET
LEWIS, Deceased;

HAYDEE C. LILLO, Individually, as surviving Spouse,

and Personal Representative of the Estate of CARLOS
LILLO, Deceased;

THOMAS E. TIGHE, Individually, as surviving Spouse,

and Personal Representative of the Estate of DIANE T.
LIPARI, Deceased;

40
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 11 of 29

ENRICA NACCARATO, Individually, as surviving

Sibling, and Personal Representative of the Estate of
LORRAINE LISI, Deceased;

EMILY LIZCANO, Individually, as surviving Spouse,

and Personal Representative of the Estate of HAROLD
LIZCANO, Deceased;

KATHLEEN KEELER LOZIER, Individually, as

surviving Spouse, and Personal Representative of the
Estate of GARY W. LOZIER, Deceased;

MAUREEN KELLY, Individually, as surviving Spouse,

and Personal Representative of the Estate of MARK
LUDVIGSEN, Deceased;

MARIE LUKAS, Individually, as surviving Parent, and

Personal Representative of the Estate of MARIE
LUKAS, Deceased;

MICHELLE PEGNO, Individually, as surviving Spouse,

and Personal Representative of the Estate of MICHAEL
P. LUNDEN, Deceased;
MICHELLE PEGNO on behalf of MATTHEW PEGNO,
minor as surviving Child of MICHAEL P. LUNDEN,
Deceased;

ANNE MACFARLANE, Individually, as surviving

Parent, and Personal Representative of the Estate of
MARIANNE MACFARLANE, Deceased;
GEORGE MACFARLANE, as surviving Sibling of
MARIANNE MACFARLANE, Deceased;
JOSEPH MACFARLANE, as surviving Sibling of
MARIANNE MACFARLANE, Deceased;

ANDREA MAFFEO, Individually, as surviving Sibling,

and Personal Representative of the Estate of
JENNIEANN MAFFEO, Deceased;
SAM MAFFEO, as surviving Parent of JENNIEANN
MAFFEO, Deceased;
ANDREA MAFFEO, as Personal Representative of the
Estate of FRANCES MAFFEO, Deceased, surviving
Parent, of JENNIEANN MAFFEO;
JOSEPH MAFFEO, as surviving Sibling of
JENNIEANN MAFFEO, Deceased;

41
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 12 of 29

PAMELA ANN MAGGITTI, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOSEPH MAGGITTI, Deceased;

SHARI MAIO, Individually, as surviving Spouse, and

Personal Representative of the Estate of JOSEPH MAIO,
Deceased;

REBECCA L MARCHAND, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ALFRED MARCHAND, Deceased;

JOHN MARTIN, Individually, as surviving Sibling, and

Personal Representative of the Estate of KAREN A.
MARTIN, Deceased;

BETTYANN MARTINEAU, Individually, as surviving

Spouse, and Personal Representative of the Estate of
BRIAN E. MARTINEAU, Deceased;

JUAN MARTINEZ, JR., Individually, as surviving

Sibling, and Personal Representative of the Estate of
WALESKA MARTINEZ, Deceased;

LORI MASCALI, Individually, as surviving Spouse, and

Personal Representative of the Estate of JOSEPH
MASCALI, Deceased;

RAYNETTE MASCARENHAS, Individually, as

surviving Spouse, and Personal Representative of the
Estate of BERNARD MASCARENHAS, Deceased;

DOROTHY MAURO-JASTREMSKI, Individually, as

surviving Spouse, and Personal Representative of the
Estate of CHARLES A. MAURO, Deceased;

PEARL MAYNARD, Individually, as surviving Parent,

and Personal Representative of the Estate of KEITHROY
MAYNARD, Deceased;

MERYL MAYO, Individually, as surviving Spouse, and

Personal Representative of the Estate of ROBERT
MAYO, Deceased;
MERYL MAYO on behalf of CORBIN MAYO, minor,
as surviving Child of ROBERT MAYO, Deceased;

42
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 13 of 29

JEANNE MCALARY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JAMES MCALARY, Deceased;
JILLIAN MCALARY, as surviving Child of JAMES
MCALARY, Deceased;
JAMES MCALARY, as surviving Child of JAMES
MCALARY, Deceased;
JOSEPH MCALARY, as surviving Child of JAMES
MCALARY, Deceased;
KAREN HIGDON, as surviving Sibling of JAMES
MCALARY, Deceased;
BRYAN MCALARY, as surviving Sibling of JAMES
MCALARY, Deceased;

ANN MCCARTHY, Individually, as surviving Spouse,

and Personal Representative of the Estate of ROBERT G.
MCCARTHY, Deceased;
ANN MCCARTHY on behalf of SHANE MCCARTHY,
minor as surviving Child of ROBERT G. MCCARTHY,
Deceased;

WILLIAM MCCARTHY, Individually, as surviving

Parent, and Personal Representative of the Estate of
MICHAEL MCCARTHY, Deceased;

BETTY ANN MCCARTHY, Individually, as surviving

Parent, and Personal Representative of the Estate of
JUSTIN MCCARTHY, Deceased;

MICHELLE MCCRANN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
CHARLES A. MCCRANN, Deceased;

SUSAN MCDERMOTT, Individually, as surviving

Spouse, and Personal Representative of the Estate of
MATTHEW MCDERMOTT, Deceased;

JOHN MCDOWELL, Individually, as surviving Parent,

and Personal Representative of the Estate of JOHN F.
MCDOWELL, JR., Deceased;

MARY BETH MCERLEAN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOHN T. MCERLEAN, JR., Deceased;

43
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 14 of 29

MARGARET MCGINLEY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DANIEL MCGINLEY, Deceased;

ILIANA MCGINNIS-GUIBERT, Individually, as

surviving Spouse, and Personal Representative of the
Estate of THOMAS MCGINNIS, Deceased;

CYNTHIA MCGINTY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
MICHAEL MCGINTY, Deceased;

JILL MCGOVERN, Individually, as surviving Spouse,

and Personal Representative of the Estate of SCOTT M.
MCGOVERN, Deceased;
ALANA MCGOVERN, as surviving Child of SCOTT
M. MCGOVERN, Deceased;
JILL MCGOVERN on behalf of NICOLE
MCGOVERN, minor, as surviving Child of SCOTT M.
MCGOVERN, Deceased;
TARA BAYER, as surviving Sibling of SCOTT M.
MCGOVERN, Deceased;

THERESA MCGOVERN, Individually, as surviving

Child, and Personal Representative of the Estate of ANN
W. MCGOVERN, Deceased;

VIRGINIA MCKEON, Individually, as surviving

Spouse, and Personal Representative of the Estate of
BARRY MCKEON, Deceased;

RUBINA COX-HOLLOWAY, Individually, as surviving

Parent, and Personal Representative of the Estate of
DARRYL L. MCKINNEY, Deceased;

GEORGE MCLAUGHLIN, Individually, as surviving

Parent, and Personal Representative of the Estate of
GEORGE P. MCLAUGHLIN, JR., Deceased;

DEBRA MCSWEENEY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
TIMOTHY MCSWEENEY, Deceased;

JOANN MEEHAN, Individually, as surviving Spouse,

and Personal Representative of the Estate of DAMIAN
MEEHAN, Deceased;

44
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 15 of 29

JOANN MEEHAN on behalf of DAMIAN MEEHAN,

JR., minor, as surviving Child of DAMIAN MEEHAN,
Deceased;
JOANN MEEHAN on behalf of MADISON MEEHAN,
minor, as surviving Child of DAMIAN MEEHAN,
Deceased;

JOVIANA MERCADO, Individually, as surviving

Spouse, and Personal Representative of the Estate of
STEVE MERCADO, Deceased;

OLGA MERINO, Individually, as surviving Spouse, and

Personal Representative of the Estate of GEORGE L.
MERINO, Deceased;

KOULA MERKOURIS, Individually, as surviving

Spouse, and Personal Representative of the Estate of
GEORGE MERKOURIS, Deceased;

ANNE MCNEIL, Individually, as surviving Spouse, and

Personal Representative of the Estate of MARTIN
MICHELSTEIN, Deceased;

FREDERYK MILEWSKI, Individually, as surviving

Parent, and Personal Representative of the Estate of
LUKASZ MILEWSKI, Deceased;

JENNIFER MINGIONE, Individually, and as Estate

Representative of the Estate of Thomas Mingione, Deceased
and on behalf of all survivors of Thomas Mingione;

RICHARD VILLA, Individually, as surviving Sibling,

and Personal Representative of the Estate of SHARON
CHRISTINA MILLAN, Deceased;
MAURICIO MILLAN, as surviving Parent of SHARON
CHRISTINA MILLAN, Deceased;
CHRISTINA MILLAN, as surviving Parent of SHARON
CHRISTINA MILLAN, Deceased;
PATRICIA MARZOCCHI, as surviving Sibling of
SHARON CHRISTINA MILLAN, Deceased;
CARLOS VILLA, as surviving Sibling of SHARON
CHRISTINA MILLAN, Deceased;

FAITH MILLER, Individually, as surviving Spouse, and

Personal Representative of the Estate of ROBERT
ALAN MILLER, Deceased;

45
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 16 of 29

DINA MILLER, as surviving Child of ROBERT ALAN

MILLER, Deceased;
MELANIE PAVELIS, as surviving Child of ROBERT
ALAN MILLER, Deceased;
EDWARD MILLER, as surviving Sibling of ROBERT
ALAN MILLER, Deceased;
STEVEN MILLER, Individually, as surviving Sibling,
and Personal Representative of the Estate of ROBERT
ALAN MILLER, Deceased;

DIANE MILLER, Individually, as surviving Spouse, and

Personal Representative of the Estate of HENRY A.
MILLER, JR. Deceased;

MARJORIE MILLER, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOEL MILLER, Deceased;

RICHARD A. PITINO, Individually, as surviving Estate

Rep, and Personal Representative of the Estate of
WILLIAM G. MINARDI, Deceased;

BARBARA MINERVINO, Individually, as surviving

Spouse, and Personal Representative of the Estate of
LOUIS J. MINERVINO, Deceased;
LAINA MINERVINO, as surviving Child of LOUIS J.
MINERVINO, Deceased;
MARISA MINERVINO, as surviving Child of LOUIS J.
MINERVINO, Deceased;

JOANNE MODAFFERI, Individually, as surviving

Spouse, and Personal Representative of the Estate of
LOUIS MODAFFERI, Deceased;

ANNA MOJICA, Individually, as surviving Spouse, and

Personal Representative of the Estate of MANUEL
MOJICA, JR., Deceased;

DIANE MONAHAN, Individually, as surviving Spouse,

and Personal Representative of the Estate of JOHN G.
MONAHAN, Deceased;

SARADHA MOORTHY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
KRISHNA MOORTHY, Deceased;

46
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 17 of 29

ROBERTA MORELL, Individually, as surviving

Spouse, and Personal Representative of the Estate of
GEORGE MORELL, Deceased;

SURI MORGENSTERN, Individually, as surviving

Parent, and Personal Representative of the Estate of
NANCY MORGENSTERN, Deceased;

NANCY MORONEY, Individually, as surviving Spouse,

and Personal Representative of the Estate of DENNIS
MORONEY, Deceased;

KIMBERLY MARTONE, Individually, as surviving

Spouse, and Personal Representative of the Estate of
CHRISTOPHER M. MORRISON, Deceased;

EMILY VELEZ MOTRONI, Individually, as surviving

Spouse, and Personal Representative of the Estate of
MARCO MOTRONI, Deceased;

CHRIS MOTRONI, as surviving Child of MARCO

MOTRONI, Deceased;

PATRICK J. MULLAN, Individually, and as Estate

Representative of the Estate of Michael Mullan, Deceased
and on behalf of all survivors of Patrick J. Mullan;

CATHY LYNN BIRCH, Individually, as surviving

Sibling, and Personal Representative of the Estate of
MARC A. MUROLO, Deceased;

ELVIRA MURPHY, Individually, as surviving Spouse,

and Personal Representative of the Estate of PATRICK
MURPHY, Deceased;

JUDITH BRAM MURPHY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
BRIAN J. MURPHY, Deceased;

ELIZABETH MURPHY, Individually, as surviving

Parent, and Personal Representative of the Estate of
CHARLES A. MURPHY, Deceased;

GAIL S. CLARK, Individually, as surviving Spouse, and

Personal Representative of the Estate of RICHARD T.
MYHRE, Deceased;

47
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 18 of 29

RICHARD B. NAIMAN, Individually, as surviving

Child, and Personal Representative of the Estate of
MILDRED R. NAIMAN, Deceased;

EDWARD NAVARRO, Individually, as surviving

Parent, and Personal Representative of the Estate of
KAREN S. NAVARRO, Deceased;

WILLIAM NELSON, Individually, as surviving Spouse,

and Personal Representative of the Estate of THERESA
GINGER NELSON-RISCO, Deceased;

EVELYN TEPEDINO, Individually, as surviving Parent,

and Personal Representative of the Estate of JODY
TEPEDINO NICHOLO, Deceased;

GEORGE NICOSIA, Individually, as surviving Spouse,

and Personal Representative of the Estate of
KATHLEEN A. NICOSIA, Deceased;
PHYLLIS HAWK, as surviving Mother of KATHLEEN
A. NICOSIA, Deceased;
KIMBERLY MEYER, as surviving Sibling of
KATHLEEN A. NICOSIA, Deceased;

MERRILLY E. NOETH, Individually, as surviving

Parent, and Personal Representative of the Estate of
MICHAEL NOETH, Deceased;

DANA MCGOWAN NOONAN, Individually, as

surviving Spouse, and Personal Representative of the
Estate of ROBERT W. NOONAN, Deceased;
CHARLES NOONAN, as surviving Child of ROBERT
W. NOONAN, Deceased;
ANNE C. NOONAN, as surviving Parent of ROBERT
W. NOONAN, Deceased;
WALTER P. NOONAN, as surviving Parent of
ROBERT W. NOONAN, Deceased;
ASHLEY NOONAN, as surviving Sibling of ROBERT
W. NOONAN, Deceased;
ANNE WELLINGTON NOONAN ROBERTSON, as
surviving Sibling of ROBERT W. NOONAN, Deceased;
KELLY NOONAN, as surviving Sibling of ROBERT W.
NOONAN, Deceased;

JEFFREY LOVIT, ESQ., as Personal Representative of

the Estate of JACQUELINE NORTON, Deceased;

48
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 19 of 29

JASON SEYMOUR, as surviving Child of

JACQUELINE NORTON, Deceased;
JOHN SEYMOUR, as surviving Child of JACQUELINE
NORTON, Deceased;
JAMES SEYMOUR, as surviving Child of
JACQUELINE NORTON, Deceased;

JEFFREY LOVIT, ESQ., Individually, as Personal

Representative of the Estate of ROBERT G. NORTON,
Deceased;

WILLIAM B. NOVOTNY, Individually, as surviving

Sibling, and Co-Personal Representative of the Estate of
BRIAN C. NOVOTNY, Deceased;
MICHAEL C. NOVOTNY, Individually, as surviving
Sibling, and Co-Personal Representative of the Estate of
BRIAN C. NOVOTNY, Deceased;
DANIEL NOVOTNY, as surviving Sibling of BRIAN C.
NOVOTNY, Deceased;
MICHAEL C. NOVOTNY, as Co-Personal
Representative of the Estate of JOHN B. NOVOTNY,
Deceased, surviving Sibling of BRIAN C. NOVOTNY;
WILLIAM B. NOVOTNY, as Co-Personal
Representative of the Estate of JOHN B. NOVOTNY,
Deceased, surviving Sibling of BRIAN C. NOVOTNY;

ARLENE NUSSBAUM, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JEFFERY NUSSBAUM, Deceased;
CRAIG NUSSBAUM, as surviving Child of JEFFERY
NUSSBAUM, Deceased;
MELISA BRUNSCHWIG, as surviving Child of
JEFFERY NUSSBAUM, Deceased;

LISANNE MACKENZIE, Individually, as surviving

Parent, and Personal Representative of the Estate of
JAMES P. O'BRIEN, JR., Deceased;

KELLY HAYES, Individually, as surviving Spouse, and

Personal Representative of the Estate of SCOTT J.
O'BRIEN, Deceased;

WILLIAM O'CONNOR, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DIANA J. O'CONNOR, Deceased;

49
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 20 of 29

LYNNE O'CONNOR, Individually, as surviving Spouse,

and Personal Representative of the Estate of RICHARD
J. O'CONNOR, Deceased;

DENNIS O'CONNOR, SR., Individually, as surviving

Parent, and Personal Representative of the Estate of
DENNIS J. O'CONNOR, JR., Deceased;

GERALDINE DAVIE, Individually, as surviving

Sibling, and Personal Representative of the Estate of
AMY O'DOHERTY, Deceased;
MAURA O'DOHERTY LEE, as surviving Sibling of
AMY O'DOHERTY, Deceased;
JAMES WALLACE O'GRADY, Individually, as
surviving Parent, and Personal Representative of the
Estate of JAMES A. O'GRADY, Deceased;
SARA O'GRADY, as surviving Parent of JAMES A.
O'GRADY, Deceased;
KRISTIN O'GRADY EVANS, as surviving Sibling of
JAMES A. O'GRADY, Deceased;

ANDREA O'HAGAN, Individually, as surviving Spouse,

and Personal Representative of the Estate of THOMAS
G. O'HAGAN, Deceased;
ANDREA O'HAGAN on behalf of PATRICK
O'HAGAN, minor as surviving Child of THOMAS G.
O'HAGAN, Deceased;
ANDREA O'HAGAN on behalf of PIERCE O'HAGAN,
minor, as surviving Child of THOMAS G. O'HAGAN,
Deceased;

MARY JEAN MCCARTHY O'LEARY, Individually, as

surviving Spouse, and Personal Representative of the
Estate of GERALD THOMAS O'LEARY, Deceased;
MICHAEL PATRICK O'LEARY, as surviving Child of
GERALD THOMAS O'LEARY, Deceased;

OLIVA TONY, Individually, as surviving Sibling, and

Personal Representative of the Estate of LINDA OLIVA,
Deceased;

SHERYL JANE OLIVER, Individually, as surviving

Spouse, and Personal Representative of the Estate of
EDWARD K. OLIVER, Deceased;
EMILY OLIVER, as surviving Child of EDWARD K.
OLIVER, Deceased;

50
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 21 of 29

EDWARD OLIVER, as surviving Child of EDWARD K.

OLIVER, Deceased;
BARBARA OLIVER, as surviving Parent of EDWARD
K. OLIVER, Deceased;
DONALD OLIVER, as surviving Parent of EDWARD
K. OLIVER, Deceased;
DONALD OLIVER, as surviving Sibling of EDWARD
K. OLIVER, Deceased;
BARBARA SMITH, as surviving Sibling of EDWARD
K. OLIVER, Deceased;
JAMES OLIVER, as surviving Sibling of EDWARD K.
OLIVER, Deceased;

ELIZABETH REGO, Individually, as surviving Parent,

and Personal Representative of the Estate of LEAH E.
OLIVER, Deceased;

JOHN ERIC OLSON, Individually, as surviving Spouse,

and Personal Representative of the Estate of MAUREEN
L. OLSON, Deceased;

LAUREN MURPHY LEWIS, Individually, as surviving

Spouse, and Personal Representative of the Estate of
MATTHEW T. O'MAHONY, Deceased;

HOLLY O'NEILL, Individually, as surviving Spouse,

and Personal Representative of the Estate of SEAN G. C.
O'NEILL, Deceased;

HARRY ONG, JR., Individually, as surviving Sibling,

and Personal Representative of the Estate of BETTY
ANN ONG, Deceased;

DEBORAH OPPERMAN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
MICHAEL OPPERMAN, Deceased;
ELIZABETH CAGGIANO, as surviving Child of
MICHAEL OPPERMAN, Deceased;
MICHAEL OPPERMAN, JR., as surviving Child of
MICHAEL OPPERMAN, Deceased;

STANLEY WEINSTEIN, Individually, as surviving

Parent, and Personal Representative of the Estate of
LISA CAREN ORFI-EHRLICH, Deceased;

51
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 22 of 29

SHEILA ORNEDO, Individually, as surviving Spouse,

and Personal Representative of the Estate of RUBEN
ORNEDO, Deceased;

ALFREDO F. ORTIZ, Individually, as surviving Parent,

and Personal Representative of the Estate of
ALEXANDER ORTIZ, Deceased;

BARBARA LYNCH, Individually, as surviving Spouse,

and Personal Representative of the Estate of ROBERT
W. O'SHEA, Deceased;

FELICIANA UMANZOR, Individually, as surviving

Parent, and Personal Representative of the Estate of
ELSY C. OSORIO, Deceased;

JOANNA OSTROWSKI, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JAMES OSTROWSKI, Deceased;

KENNETH OSWALD, Individually, as surviving Parent,

and Personal Representative of the Estate of JASON
OSWALD, Deceased;

SUSAN OU, Individually, as surviving Spouse, and

Personal Representative of the Estate of MICHAEL C.
OU, Deceased;

KATHLEEN OWENS, Individually, as surviving

Spouse, and Personal Representative of the Estate of
PETER OWENS, JR., Deceased;
JOSEPH OWENS, as surviving Child of PETER
OWENS, JR., Deceased;
THOMAS OWENS, as surviving Child of PETER
OWENS, JR., Deceased;
MARYELLEN OWENS, as surviving Child of PETER
OWENS, JR., Deceased;

YVETTE PABON, Individually, as surviving Spouse,

and Personal Representative of the Estate of ANGEL
PABON, Deceased;

SAMPATH PAKKALA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DEEPA PAKKALA, Deceased;

52
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 23 of 29

LISA PALAZZO, Individually, as surviving Spouse, and

Personal Representative of the Estate of JEFFERY M.
PALAZZO, Deceased;
LISA PALAZZO on behalf of SAMANTHA PALAZZO,
minor, as surviving Child of JEFFERY M. PALAZZO,
Deceased;

LISA PALAZZO, Individually, as surviving Spouse, and

Personal Representative of the Estate of THOMAS
PALAZZO, Deceased;

DONNA PAOLILLO, Individually, as surviving Spouse,

and Personal Representative of the Estate of JOHN
PAOLILLO, Deceased;

LINDA PASCUMA, Individually, as surviving Spouse,

and Personal Representative of the Estate of MICHAEL
J. PASCUMA, JR., Deceased;

SEAN PASSANANTI, Individually, as surviving Child,

and Personal Representative of the Estate of HORACE
PASSANANTI, Deceased;

IRENE DURBIN, Individually, as surviving Sibling, and

Personal Representative of the Estate of SUZANNE H.
PASSARO, Deceased;
IRENE DURBIN, as Personal Representative of the
Estate of HELENE S. PASSARO, Deceased, surviving
Parent of SUZANNE H. PASSARO;
IRENE DURBIN, as Personal Representative of the
Estate of ANTHONY F. PASSARO, Deceased,
surviving Parent of SUZANNE H. PASSARO;

KANTILAL PATEL, Individually, as surviving Parent,

and Personal Representative of the Estate of MANISH
PATEL, Deceased;

BLANCA GUTIERREZ DE PAZ, Individually, as

surviving Parent, and Personal Representative of the
Estate of VICTOR HUGO GUTIERREZ PAZ,
Deceased;

NINA BARNES, as Personal Representative of the

Estate of DURRELL PEARSALL, JR., Deceased;

53
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 24 of 29

SOPHIE PELLETIER-MARTINELLI, Individually, as

surviving Spouse, and Personal Representative of the
Estate of MIKE PELLETIER, Deceased;

MARY GOLA PEREZ, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ANTHONY PEREZ, Deceased;
ANTHONY PEREZ, as surviving Child of ANTHONY
PEREZ, Deceased;
ALEXIS PEREZ, as surviving Child of ANTHONY
PEREZ, Deceased;

PATRICIA PERRONCINO, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOSEPH PERRONCINO, Deceased;

JOSEPHINE PERROTTA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
EDWARD PERROTTA, Deceased;

FRANK K. PEZZUTI, Individually, as surviving Parent,

and Personal Representative of the Estate of KALEEN E.
PEZZUTI, Deceased;

HELEN PFEIFER, Individually, as surviving Parent, and

Co-Personal Representative of the Estate of KEVIN
PFEIFER, Deceased;
WILLIAM PFEIFER, Individually, as surviving Parent,
and Co-Personal Representative of the Estate of KEVIN
PFEIFER, Deceased;

LINDA PICKFORD, Individually, as surviving Parent,

and Personal Representative of the Estate of
CHRISTOPHER PICKFORD, Deceased;

DANIEL POLATSCH, Individually, as surviving

Sibling, and Personal Representative of the Estate of
LAURENCE POLATSCH, Deceased;
LINDA BODIAN, as surviving Parent of LAURENCE
POLATSCH, Deceased;
BERNARD POLATSCH, as surviving Parent of
LAURENCE POLATSCH, Deceased;

JEAN OSLYN POWELL, Individually, as surviving

Spouse, and Personal Representative of the Estate of
SHAWN POWELL, Deceased;

54
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 25 of 29

KAREN PRINCIOTTA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
VINCENT PRINCIOTTA, Deceased;
CHRISTINA M. PRINCIOTTA, as surviving Child of
VINCENT PRINCIOTTA, Deceased;

SUSAN PRUNTY, Individually, as surviving Spouse,

and Personal Representative of the Estate of RICHARD
PRUNTY, Deceased;

MICHAEL PUCKETT, Individually, as surviving Child,

and Personal Representative of the Estate of JOHN F.
PUCKETT, Deceased;
DOMINIC J. PUOPOLO, SR., Individually, as surviving
Spouse, and Personal Representative of the Estate of
SONIA M. PUOPOLO, Deceased;

PATRICIA QUIGLEY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
PATRICK QUIGLEY, Deceased;
RACHEL QUIGLEY, as surviving Child of Patrick
Quigley, Deceased;
PATRICIA QUIGLEY on behalf of LEAH QUIGLEY,
minor, as surviving Child of PATRICK J. QUIGLEY,
Deceased;

FRANCINE RAGGIO, Individually, as surviving

Spouse, and Personal Representative of the Estate of
EUGENE J. RAGGIO, Deceased;

MICHAEL RAMBOUSEK, Individually, as surviving

Parent, and Personal Representative of the Estate of
LUKAS RAMBOUSEK, Deceased;

DEBORAH BASHAM, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ALFRED TODD RANCKE, Deceased;

MARY ANN RAND, Individually, as surviving Parent,

and Personal Representative of the Estate of ADAM D.
RAND, Deceased;
MARY ANN RAND, as Personal Representative of the
Estate of JAMES RAND, Deceased, surviving Parent of
ADAM D. RAND, Deceased;

55
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 26 of 29

SADIQ RASOOL, Individually, as surviving Spouse,

and Personal Representative of the Estate of AMENIA
RASOOL, Deceased;
FARHAAD N. RASOOL, as surviving Child of
AMENIA RASOOL, Deceased;
ANEESA RASOOL, as surviving Child of AMENIA
RASOOL, Deceased;
ASEEFA RASOOL, as surviving Child of AMENIA
RASOOL, Deceased;
SAEED N. RASOOL, as surviving Child of AMENIA
RASOOL, Deceased;

SUSAN BAUER, Individually, as surviving Spouse, and

Personal Representative of the Estate of ROGER MARK
RASWEILER, Deceased;

NATALYA LOGINOVA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ALEXEY RAZUVAEV, Deceased;

NICOLE REDA, Individually, as surviving Spouse, and

Personal Representative of the Estate of GREGORY
REDA, Deceased;
NICOLE REDA on behalf of MATTHEW A. REDA,
minor, as surviving Child of GREGORY REDA,
Deceased;
CHRISTOPHER REDA, as surviving Sibling of
GREGORY REDA, Deceased;

SHARLENE BECKWITH, Individually, as surviving

Parent, and Personal Representative of the Estate of
MICHELE REED, Deceased;

THERESA REGAN, Individually, as surviving Parent,

and Personal Representative of the Estate of DONALD J.
REGAN, Deceased;

CATHERINE REGENHARD, Individually, as surviving

Parent, and Personal Representative of the Estate of
CHRISTIAN M.O. REGENHARD, Deceased;

WILLIAM F. REILLY, Individually, as surviving

Parent, and Personal Representative of the Estate of
JAMES B. REILLY, Deceased;

JENNIFER REILLY, Individually, and as Estate

Representative of the Estate of Kevin Reilly, Deceased

56
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 27 of 29

and on behalf of all survivors of Kevin Reilly;

ARMAND REO, Individually, as surviving Parent, and

Personal Representative of the Estate of JOHN A. REO,
Deceased;

VIVIAN REUBEN, Individually, as surviving Spouse,

and Personal Representative of the Estate of TODD
REUBEN, Deceased;

MARIA CRUZ, Individually, as surviving Sibling, and

Personal Representative of the Estate of EDUVIGIS
REYES, JR., Deceased;
KIMBERLY REYES, as surviving Child of EDUVIGIS
REYES, JR., Deceased;
TIFFANY REYES, as surviving Child of EDUVIGIS
REYES, JR., Deceased;
STEPHANIE VILLARIN, as surviving Child of
EDUVIGIS REYES, JR., Deceased;
NEMESIO REYES, as surviving Sibling of EDUVIGIS
REYES, JR., Deceased;
LUZ REYES, as surviving Sibling of EDUVIGIS
REYES, JR., Deceased;
AIDALINE REYES CONCEPCION, as surviving
Sibling of EDUVIGIS REYES, JR., Deceased;
NYDIA REYES RODRIGUEZ, as surviving Sibling of
EDUVIGIS REYES, JR., Deceased;
IDA HOLDER, as surviving Sibling of EDUVIGIS
REYES, JR., Deceased;
ENOEL REYES, as surviving Sibling of EDUVIGIS
REYES, JR., Deceased;
ISABELL REYES, as surviving Sibling of EDUVIGIS
REYES, JR., Deceased;

ERIN PITT RICHARDS, Individually, as surviving

Spouse, and Personal Representative of the Estate of
GREGORY D. RICHARDS, Deceased;

KIMBERLY TRUDEL, Individually, as surviving

Spouse, and Personal Representative of the Estate of
FREDERICK RIMMELE, III, Deceased;

NILSA RIVERA, Individually, as surviving Spouse, and

Personal Representative of the Estate of ISAIAS
RIVERA, Deceased;

57
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 28 of 29

RICKY VIDER, Individually, as surviving Spouse, and

Personal Representative of the Estate of DAVID E.
RIVERS, Deceased;

JODI RIVERSO, as Personal Representative of the

Estate of JOSEPH R. RIVERSO, Deceased;

PAULETTE ROBERTS and THOMAS ROBERTS,

Individually, and as Parents and Estate Co-Representatives
of the Estate of Michael E. Roberts, Deceased
and on behalf of all survivors of Michael E. Roberts;

RODNEY CALLUM, Individually, as surviving Sibling,

and Personal Representative of the Estate of MICHELL
L. ROBOTHAM, Deceased;

KATHERINE ROBSON, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DONALD ROBSON, Deceased;
GEOFFREY ROBSON, as surviving Child of DONALD
ROBSON, Deceased;
SCOTT ROBSON, as surviving Child of DONALD
ROBSON, Deceased;

MARYLYNN PADILLA, Individually, as surviving

Child, and Personal Representative of the Estate of
CARMEN M. RODRIGUEZ, Deceased;

EVELYN RODRIGUEZ, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ANTHONY RODRIGUEZ, Deceased;
LAUREN RODRIGUEZ, as surviving Child of
ANTHONY RODRIGUEZ, Deceased;
DEREK RODRIGUEZ, as surviving Child of
ANTHONY RODRIGUEZ, Deceased;
EVELYN RODRIGUEZ on behalf of MORGAN
RODRIGUEZ, minor, as surviving Child of ANTHONY
RODRIGUEZ, Deceased;
PEDRO RODRIGUEZ, as surviving Parent of
ANTHONY RODRIGUEZ, Deceased;
DESIREE OKSENIUK, as surviving Sibling of
ANTHONY RODRIGUEZ, Deceased;
ANGELIC SUAREZ, as surviving Sibling of
ANTHONY RODRIGUEZ, Deceased;

58
 Case 1:17-cv-02003 Document 1-1 Filed 03/20/17 Page 29 of 29

RONALD R. ROHNER, Individually, as surviving

Parent, and Personal Representative of the Estate of
SCOTT W. ROHNER, Deceased;

EDITH CRUZ, Individually, as surviving Parent, and

Personal Representative of the Estate of ANGELA
ROSARIO, Deceased;

MARTIN ROSENBAUM, Individually, as surviving

Parent, and Personal Representative of the Estate of
BROOKE D. ROSENBAUM, Deceased;
FERN ROSENBAUM, as surviving Stepparent of
BROOKE D. ROSENBAUM, Deceased;

GLENNA ROSENBERG, Individually, as surviving

Spouse, and Personal Representative of the Estate of
LLOYD ROSENBERG, Deceased;
GLENNA ROSENBERG on behalf of ALYSSA
ROSENBERG, minor, as surviving Child of LLOYD
ROSENBERG, Deceased;

JILL ROSENBLUM, Individually, as surviving Spouse,

and Personal Representative of the Estate of ANDREW
I. ROSENBLUM, Deceased;
JORDAN ROSENBLUM, as surviving Child of
ANDREW I. ROSENBLUM, Deceased;
KYLE ROSENBLUM, as surviving Child of ANDREW
I. ROSENBLUM, Deceased;
BARBARA ROSENBLUM, as surviving Parent of
ANDREW I. ROSENBLUM, Deceased;
SHEILA ORNSTEIN as Personal Representative of the
Estate of JASON ROSENBLUM, Deceased, surviving
Parent of ANDREW I. ROSENBLUM;
SHEILA ORNSTEIN, as surviving Sibling of ANDREW
I. ROSENBLUM, Deceased;
RICHARD ROSENBLUM, as surviving Sibling of
ANDREW I. ROSENBLUM, Deceased;
ADAM ROSENBLUM, as surviving Sibling of
ANDREW I. ROSENBLUM, Deceased;

LAUREN ROSENZWEIG, Individually, as surviving

Spouse, and Personal Representative of the Estate of
PHILLIP ROSENZWEIG, Deceased;

59
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 1 of 30

JUDI A. ROSS, Individually, as surviving Spouse, and

Personal Representative of the Estate of RICHARD
ROSS, Deceased;
IRENE ROSS, as surviving Sibling of RICHARD ROSS,
Deceased;
ROCHELLE GORDON, as surviving Sibling of
RICHARD ROSS, Deceased;

SUSAN ROSSINOW, Individually, as surviving Spouse,

and Personal Representative of the Estate of NORMAN
ROSSINOW, Deceased;

BARBARA SCARAMUZZINO, Individually, as

surviving Parent, and Personal Representative of the
Estate of NICHOLAS ROSSOMANDO, Deceased;

CLAUDIA RUGGIERE, Individually, as surviving

Spouse, and Personal Representative of the Estate of
BART RUGGIERE, Deceased;

GILBERT RUIZ, JR., Individually, as surviving Child,

and Personal Representative of the Estate of GILBERT
RUIZ, Deceased;

ANDREA RUSSIN, Individually, as surviving Spouse,

and Personal Representative of the Estate of STEVEN
RUSSIN, Deceased;

DIANE RYAN, Individually, as surviving Spouse, and

Personal Representative of the Estate of EDWARD
RYAN, Deceased;
MEGAN RYAN, as surviving Child of EDWARD
RYAN, Deceased;
DIANE RYAN on behalf of KELLY RYAN, minor, as
surviving Child of EDWARD RYAN, Deceased;
EDWARD RYAN, as surviving Child of EDWARD
RYAN, Deceased;
PATRICIA RYAN, as surviving Parent of EDWARD
RYAN, Deceased;
PATRICIA ANTONELLE, as surviving Sibling of
EDWARD RYAN, Deceased;
WILLIAM RYAN, as surviving Sibling of EDWARD
RYAN, Deceased;
PAUL RYAN, as surviving Sibling of EDWARD
RYAN, Deceased;

60
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 2 of 30

MARGARET RYAN, Individually, as surviving Spouse,

and Personal Representative of the Estate of MATTHEW
L. RYAN, Deceased;

MARIA L. RYAN BALDWIN, Individually, as

surviving Spouse, and Personal Representative of the
Estate of JONATHAN S. RYAN, Deceased;

VASILIY RIJOV, Individually, as surviving Spouse, and

Personal Representative of the Estate of TATIANA
RYJOVA, Deceased;

DAE JIN RYOOK, Individually, as surviving Parent, and

Personal Representative of the Estate of CHRISTINA S.
RYOOK, Deceased;

DELPHINE SAADA, Individually, as surviving Spouse,

and Personal Representative of the Estate of THIERRY
SAADA, Deceased;

MICHELE SAND, Individually, as surviving Spouse,

and Personal Representative of the Estate of ERIC
SAND, Deceased;

MICHAEL SANTO, Individually, as surviving Sibling,

and Personal Representative of the Estate of SUSAN
SANTO, Deceased;

ALEXANDER SANTORA, Individually, as surviving

Parent, and Personal Representative of the Estate of
CHRISTOPHER SANTORA, Deceased;

LINDA SARLE, Individually, as surviving Spouse, and

Personal Representative of the Estate of PAUL F.
SARLE, Deceased;

NARASIMHA SATTALURI, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DEEPIKA SATTALURI, Deceased;

STEPHEN SAUCEDO, Individually, and as Sibling and

Estate Representative of the Estate of Gregory Saucedo,
Deceased and on behalf of all survivors of Gregory Saucedo;

JANLYN SCAUSO, Individually, as surviving Spouse,

and Personal Representative of the Estate of DENNIS
SCAUSO, Deceased;

61
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 3 of 30

KENNETH SCHIELKE, Individually, as surviving

Parent, and Personal Representative of the Estate of
SEAN SCHIELKE, Deceased;

PHYLLIS SCHREIER, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JEFFERY SCHREIER, Deceased;
JANICE HART, as surviving Sibling of JEFFERY
SCHREIER, Deceased;
MARK SCHREIER, Individually, as surviving Parent,
and Personal Representative of the Estate of JEFFERY
SCHREIER, Deceased;
STEPHANIE SCHREIER, Individually, as surviving
Parent, and Personal Representative of the Estate of
JEFFERY SCHREIER, Deceased;

WILLIAM D. ROBBINS, Individually, as surviving

Attorney of, and Personal Representative of the Estate of
CLARIN S. SIEGEL-SCHWARTZ, Deceased;

CATHERINE SCULLIN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ARTHUR SCULLIN, Deceased;

NATALIE MAKSHANOV, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JASON M. SEKZER, Deceased;

NANCY PICONE, Individually, as surviving Parent, and

Personal Representative of the Estate of ARTURO
SERENO, Deceased;

JYOTHI SHAH, Individually, as surviving Spouse, and

Personal Representative of the Estate of JAYESH
SHAH, Deceased;

LEONOR SHAHID, Individually, as surviving Parent,

and Personal Representative of the Estate of KHALID
SHAHID, Deceased;
SYED SHAHID, as surviving Parent of KHALID
SHAHID, Deceased;

BENJAMIN SHAMAY, Individually, as surviving

Parent, and Personal Representative of the Estate of
GARY SHAMAY, Deceased;

62
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 4 of 30

GABRIEL SHAMAY, as surviving Sibling of GARY

SHAMAY, Deceased;

EILEEN A. SHANAHAN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
EARL SHANAHAN, Deceased;

NANCY SHEA, Individually, as surviving Spouse, and

Personal Representative of the Estate of JOSEPH P.
SHEA, Deceased;

ELLEN SHEA, Individually, as surviving Spouse, and

Personal Representative of the Estate of DANIEL J.
SHEA, Deceased;

MARY NICHOLSON, Individually, as surviving Child,

and Personal Representative of the Estate of
KATHLEEN SHEARER, Deceased;

MARY NICHOLSON, Individually, as surviving Child,

and Personal Representative of the Estate of ROBERT
SHEARER, Deceased;

LORI SHULMAN, Individually, as surviving Spouse,

and Personal Representative of the Estate of MARK
SHULMAN, Deceased;

HOLLI SILVER, Individually, as surviving Spouse, and

Personal Representative of the Estate of DAVID
SILVER, Deceased;

DHANRAJ SINGH, as surviving Parent of

KHAMLADAI SINGH
DHANRAJ SINGH, as surviving Parent of ROSHAN
SINGH

CATHY CARILLI-SINTON, Individually, as surviving

Spouse, and Personal Representative of the Estate of
THOMAS E. SINTON III, Deceased;
ALEXANDRA SINTON, as surviving Child of
THOMAS E. SINTON, III, Deceased;

LAURA MORRISON, Individually, as surviving Child,

and Personal Representative of the Estate of MURIEL
SISKOPOULOS, Deceased;

63
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 5 of 30

JASON SHERMAN, Individually, as surviving Partner,

and Personal Representative of the Estate of TOYENA
C. SKINNER, Deceased;
JASON SHERMAN on behalf of MATTHEW
SHERMAN, minor, as surviving Child of TOYENA C.
SKINNER, Deceased;

DENA SMAGALA, Individually, and as Estate

Representative of the Estate of Stanley Smagala, Deceased
and on behalf of all survivors of Stanley Smagala;

DONNA YULE, Individually, as surviving Spouse, and

Personal Representative of the Estate of JAMES G.
SMITH, Deceased;
WILLIAM SMITH, as surviving Child of JAMES G.
SMITH, Deceased;
ROBERT SMITH, as surviving Child of JAMES G.
SMITH, Deceased;
KRISTEN SMITH, as surviving Child of JAMES G.
SMITH, Deceased;
CAROLINE SMITH, as surviving Child of JAMES G.
SMITH, Deceased;

ROSEMARY KEMPTON, Individually, as surviving

Child, and Personal Representative of the Estate of
ROSEMARY A. SMITH, Deceased;

JERRI SMITH, Individually, as surviving Spouse, and

Personal Representative of the Estate of KEVIN J.
SMITH, Deceased;

JANINE SNYDER OLDENHAGE, Individually, as

surviving Spouse, and Personal Representative of the
Estate of LEONARD J. SNYDER, JR., Deceased;

BARBARA SOHAN, Individually, as surviving Parent,

and Personal Representative of the Estate of ASTRID
SOHAN, Deceased;
CLIVE SOHAN, as surviving Parent of ASTRID
SOHAN, Deceased;

LAURIE SPAMPINATO, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DONALD F. SPAMPINATO, JR., Deceased;

64
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 6 of 30

LAWAN SRINUAN, Individually, as surviving Parent,

and Personal Representative of the Estate of SARANYA
SRINUAN, Deceased;

THERESA STACK, Individually, as surviving Spouse,

and Personal Representative of the Estate of
LAURENCE T. STACK, Deceased;

DANIEL STAN, Individually, as surviving Parent, and

Personal Representative of the Estate of ALEXANDRU
STAN, Deceased;

DIANE STARITA, Individually, as surviving Spouse,

and Personal Representative of the Estate of ANTHONY
STARITA, Deceased;

KIM STATKEVICUS, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DAVID J. STATKEVICUS, Deceased;
TYLER STATKEVICUS, as surviving Child of DAVID
J. STATKEVICUS, Deceased;
DEREK C. STATKEVICUS, as surviving Child of
DAVID J. STATKEVICUS, Deceased;

TRACY O'KEEFE, Individually, as surviving Spouse,

and Personal Representative of the Estate of
ALEXANDER STEINMAN, Deceased;
IRWIN STEINMAN, as surviving Parent of
ALEXANDER STEINMAN, Deceased;

CARMEN SUAREZ, Individually, and as Estate

Representative of the Estate of Ramon Suarez, Deceased
and on behalf of all survivors of Ramon Suarez;

JESSICA SCHOENHOLTZ, as surviving Stepsibling of

ALEXANDER STEINMAN, Deceased;
KRISTIN GALUSHA-WILD, Individually, as surviving
Partner, and Personal Representative of the Estate of
MICHAEL J. STEWART, Deceased;
SUZANNE SWAINE, Individually, as surviving Spouse,
and Personal Representative of the Estate of JOHN F.
SWAINE, Deceased;

BARBARA ANN SWAT, Individually, and as Estate

Representative of the Estate of Gerald Thomas Atwood,
Deceased, and on behalf of all survivors of Gerald
Thomas Atwood;

65
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 7 of 30

EDWARD SWEENEY, Individually, as surviving

Parent, and Personal Representative of the Estate of
BRIAN SWEENEY, Deceased;
MARY ANN SWEENEY, as surviving Parent of BRIAN
SWEENEY, Deceased;

TRACY CATALANO, Individually, as surviving Child,

and Personal Representative of the Estate of HARRY
TABACK, Deceased;

MARY TADDEI, Individually, as surviving Child, and

Personal Representative of the Estate of NORMA
TADDEI, Deceased;
ANDREW TADDEI, as surviving Child of NORMA
TADDEI, Deceased;
LORETTA TADDEI, as surviving Child of NORMA
TADDEI, Deceased;
MARY TADDEI, as Personal Representative of the
Estate of FERMO TADDEI, Deceased, surviving Spouse
of NORMA TADDEI;
MARY TADDEI, as Personal Representative of the
Estate of ELVIRA CONTI, Deceased, surviving Parent
of NORMA TADDEI;

HARUMI TAKAHASHI, Individually, as surviving

Spouse, and Personal Representative of the Estate of
KEIICHIRO TAKAHASHI, Deceased;
HIROYUKI TAKAHASHI, as surviving Child of
KEIICHIRO TAKAHASHI, Deceased;
AKIKO TAKAHASHI, as surviving Child of
KEIICHIRO TAKAHASHI, Deceased;

MIDORI TAKAHASHI, Individually, as surviving

Spouse, and Personal Representative of the Estate of
KEIJI TAKAHASHI, Deceased;

EILEEN TALLON, Individually, as surviving Parent,

and Personal Representative of the Estate of SEAN
PATRICK TALLON, Deceased;

JUAN B. BRUNO, Individually, as surviving Spouse,

and Personal Representative of the Estate of RACHEL
TAMARES, Deceased;

66
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 8 of 30

PATRICIA TARASIEWICZ, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ALLAN TARASIEWICZ, Deceased;
ALAN TARASIEWICZ, as surviving Child of ALLAN
TARASIEWICZ, Deceased;
MELISSA TARASIEWICZ, as surviving Child of
ALLAN TARASIEWICZ, Deceased;

JILL TARROU, as Personal Representative of the Estate

of MICHAEL TARROU, Deceased;

SAMANTHA TAYLOR, Individually, as surviving

Child, and Personal Representative of the Estate of
SANDRA C. TAYLOR, Deceased;

FRANK TAYLOR, Individually, as surviving Spouse,

and Personal Representative of the Estate of LORISA C.
TAYLOR, Deceased;

LELAND DALE TERRY, Individually, as surviving

Sibling, and Personal Representative of the Estate of
LISA TERRY, Deceased;

RAJ THACKURDEEN, Individually, as surviving

Sibling, and Co-Personal Representative of the Estate of
GOUMATIE THACKURDEEN, Deceased;
SAT THACKURDEEN, Individually, as surviving
Sibling, and Co-Personal Representative of the Estate of
GOUMATIE THACKURDEEN, Deceased;
RAMBASCIA THACKURDEEN, as surviving Parent of
GOUMATIE THACKURDEEN, Deceased;

ROBIN THEURKAUF, Individually, as surviving

Spouse, and Personal Representative of the Estate of
THOMAS F. THEURKAUF, Jr., Deceased;

JOSEPH O'KEEFE, Individually, as surviving Spouse,

and Personal Representative of the Estate of LESLEY
THOMAS, Deceased;

ROSANA THOMPSON, Individually, as surviving

Spouse, and Personal Representative of the Estate of
NIGEL B. THOMPSON, Deceased;

67
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 9 of 30

JOSEPH A. TIESI, Individually, as surviving Sibling,

and Personal Representative of the Estate of MARY E.
TIESI, Deceased;

BARBARA TIRADO, Individually, as surviving Parent,

and Personal Representative of the Estate of DAVID
TIRADO, Deceased;
RAFAEL TIRADO, as surviving Parent of DAVID
TIRADO, Deceased;
RICHARD TIRADO, as surviving Sibling of DAVID
TIRADO, Deceased;

ALISSA ROSENBERG-TORRES, Individually, as

surviving Spouse, and Personal Representative of the
Estate of LUIS E. TORRES, Deceased;

KATHLEEN TRANT, Individually, as surviving Spouse,

and Personal Representative of the Estate of DANIEL
TRANT, Deceased;

ROB SPADAFORA, as Personal Representative of the

Estate of JAMES A. TRENTINI, Deceased;
PATTI J. TRENTINI, as surviving Child of JAMES A.
TRENTINI, Deceased;
THERESA MCDONALD, as Personal Representative of
the Estate of LORRAINE EGAN, Deceased, surviving
Sibling of JAMES A. TRENTINI;
BERNICE BARLETTA, as surviving Sibling of JAMES
A. TRENTINI, Deceased;

ROB SPADAFORA, as Personal Representative of the

Estate of MARY TRENTINI, Deceased;
PATTI J. TRENTINI, as surviving Child of MARY
TRENTINI, Deceased;
MARY P. VATALARO, as surviving Child of MARY
TRENTINI, Deceased;

MARY TSELEPIS, Individually, as surviving Spouse,

and Personal Representative of the Estate of WILLIAM
P. TSELEPIS, JR., Deceased;

DEBBY WILLIAMS, Individually, as surviving Child,

and Personal Representative of the Estate of PAULINE
TULL-FRANCIS, Deceased;

68
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 10 of 30

CYNTHIA TUMULTY, Individually, as surviving

Spouse, and Personal Representative of the Estate of
LANCE TUMULTY, Deceased;

MARIE HARVEY RYAN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ROBERT T. TWOMEY, Deceased;
EMERIC R. TWOMEY, as surviving Child of ROBERT
T. TWOMEY, Deceased;
ROBERT TWOMEY, as surviving Child of ROBERT T.
TWOMEY, Deceased;
HELEN ANN TWOMEY, as Personal Representative of
the Estate of JIMMY TWOMEY, Deceased, surviving
Sibling of ROBERT T. TWOMEY;
JOHN TWOMEY, as surviving Sibling of ROBERT T.
TWOMEY, Deceased;

VICTOR UGOLYN, Individually, as surviving Parent,

and Personal Representative of the Estate of TYLER
UGOLYN, Deceased;
DIANE UGOLYN, as surviving Parent of TYLER
UGOLYN, Deceased;
TREVOR UGOLYN, as surviving Sibling of TYLER
UGOLYN, Deceased;

JULIE UMAN, Individually, as surviving Spouse, and

Personal Representative of the Estate of JONATHAN
UMAN, Deceased;

VIRGINIA L. ROSSITER VALVO, Individually, as

surviving Spouse, and Personal Representative of the
Estate of CARLTON F. VALVO, II, Deceased;

NADADUR S. KUMAR, as Personal Representative of

the Estate of PENDYALA VAMSIKRISHNA,

ANNE VANDEVANDER, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JON VANDEVANDER, Deceased;

REGAN GRICE-VEGA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
PETER VEGA, Deceased;

69
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 11 of 30

CONSUELO VELAZQUEZ, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JORGE VELAZQUEZ, Deceased;

JASMINE VICTORIA, Individually, as surviving Child,

and Personal Representative of the Estate of CELESTE
TORRES VICTORIA, Deceased;

PATRICIA VILARDO, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOSEPH VILARDO, Deceased;

ANTHONY VINCELLI, Individually, as surviving

Sibling, and Personal Representative of the Estate of
CHANTAL VINCELLI, Deceased;

LUCY VIRGILIO, Individually, as surviving Parent, and

Personal Representative of the Estate of LAWRENCE J.
VIRGILIO, Deceased;

BENHARDT R. WAINIO, Individually, as surviving

Parent, and Personal Representative of the Estate of
HONOR ELIZABETH WAINO, Deceased;

DIANE WALL, Individually, as surviving Spouse, and

Personal Representative of the Estate of GLEN WALL,
Deceased;

PAUL KIEFER, as Personal Representative of the Estate

of BRIAN WARNER, Deceased;

EVELYN SIEW-SIM YEOW, Individually, as surviving

Spouse, and Personal Representative of the Estate of
MICHAEL H. WAYE, Deceased;

AMY L. WEAVER, Individually, as surviving Spouse,

and Personal Representative of the Estate of TODD C.
WEAVER, Deceased;

FLOYD WEIL, Individually, as surviving Parent, and

Personal Representative of the Estate of JOANNE F.
WEIL, Deceased;

LAURIE WEINBERG, Individually, as surviving

Spouse, and Personal Representative of the Estate of
STEVEN WEINBERG, Deceased;

70
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 12 of 30

LINDSAY WEINBERG, as surviving Child of STEVEN

WEINBERG, Deceased;
JASON WEINBERG, as surviving Child of STEVEN
WEINBERG, Deceased;
SAMUEL WEINBERG, as surviving Child of STEVEN
WEINBERG, Deceased;

LAURA WEINBERG, Individually, and as Estate

Representative of the Estate of Richard Aronow,
Deceased,

REMA WAISER, Individually, as surviving Spouse, and

Personal Representative of the Estate of SIMON V.
WEISER, Deceased;
ANATOLY S. WEISER, as surviving Child of SIMON
V. WEISER, Deceased;

DELIA WELTY, Individually, as surviving Spouse, and

Personal Representative of the Estate of TIMOTHY
WELTY, Deceased;

KATHLEEN WIK, Individually, as surviving Spouse,

and Personal Representative of the Estate of WILLIAM
J. WIK, Deceased;
PATRICIA WIK FARESE, as surviving Child of
WILLIAM J. WIK, Deceased;
KATHLEEN WIK, as surviving Child of WILLIAM J.
WIK, Deceased;
DANIEL WIK, as surviving Child of WILLIAM J. WIK,
Deceased;

JANICE WILLIAMS, Individually, as surviving Spouse,

and Personal Representative of the Estate of LOUIS C.
WILLIAMS, III, Deceased;

KENNETH WILLIAMS, Individually, as surviving

Parent, and Personal Representative of the Estate of
BRIAN P. WILLIAMS, Deceased;

DARREN WILLIAMS, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DEBBIE L. WILLIAMS, Deceased;

PATRICIA WISWALL, Individually, as surviving

Spouse, and Personal Representative of the Estate of
DAVID WISWALL, Deceased;

71
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 13 of 30

AMY WISWALL EDGINGTON, as surviving Child of

DAVID WISWALL, Deceased;
KEITH WISWALL, as surviving Child of DAVID
WISWALL, Deceased;
ROBERT WISWALL, as surviving Sibling of DAVID
WISWALL, Deceased;

ANNE WODENSHEK, Individually, as surviving

Spouse, and Personal Representative of the Estate of
CHRISTOPHER WODENSHEK, Deceased;
SARAH WODENSHEK, as surviving Child of
CHRISTOPHER WODENSHEK, Deceased;
RAYMOND WODENSHEK, as Personal Representative
of the Estate of FLORENCE WODENSHEK, Deceased,
surviving Sibling of CHRISTOPHER WODENSHEK
HALEY WODENSHEK, as surviving Child of
CHRISTOPHER WODENSHEK, Deceased;
MOLLIE WODENSHEK, as surviving Child of
CHRISTOPHER WODENSHEK, Deceased;
WILLIAM WODENSHEK, as surviving Child of
CHRISTOPHER WODENSHEK, Deceased;
ANNE WODENSHEK on behalf of ZACHARY
WODENSHEK, minor, as surviving Child of
CHRISTOPHER WODENSHEK, Deceased;
MARIELLEN DELELLIS, as surviving Sibling of
CHRISTOPHER WODENSHEK, Deceased;
PATRICIA WODENSHEK, as surviving Sibling of
CHRISTOPHER WODENSHEK, Deceased;
RAYMOND WODENSHECK, as surviving Sibling of
CHRISTOPHER WODENSHEK, Deceased;

SUSAN WOHLFORTH, Individually, as surviving

Spouse, and Personal Representative of the Estate of
MARTIN WOHLFORTH, Deceased;

CHARLES G. WOLF, Individually, as surviving Spouse,

and Personal Representative of the Estate of
KATHERINE WOLF, Deceased;

WILLIAM DREIER, as Personal Representative of the

Estate of NEIL WRIGHT, Deceased;

CELLA WOO-YUEN, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ELKIN YUEN, Deceased;

72
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 14 of 30

HELEN ZACCOLI, Individually, as surviving Spouse,

and Personal Representative of the Estate of JOSEPH
ZACCOLI, Deceased;

ZHANNA GALPERINA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ARKADY ZALTSMAN, Deceased;

DAVID ZIMINSKI, Individually, as surviving Spouse,

and Personal Representative of the Estate of IVELIN
ZIMINSKI, Deceased;
CELINA RODRIGUEZ, as surviving Parent of IVELIN
ZIMINSKI, Deceased;
IVAN RODRIGUEZ, as surviving Parent of IVELIN
ZIMINSKI, Deceased;
JANET SWENSON, as surviving Sibling of IVELIN
ZIMINSKI, Deceased;

DYAN ZINZI, Individually, as surviving Spouse, and

Personal Representative of the Estate of MICHAEL
ZINZI, Deceased;
DYAN ZINZI on behalf of DEAN ZINZI, minor, as
surviving Child of MICHAEL ZINZI, Deceased;

CAROL ZION, Individually, as surviving Spouse, and

Personal Representative of the Estate of CHARLES A.
ZION, Deceased;

RICHARD KLEIN, Individually, as surviving Spouse,

and Personal Representative of the Estate of JULIE
LYNNE ZIPPER, Deceased;
JASON KLEIN, as surviving Child of JULIE LYNNE
ZIPPER, Deceased;

DOROTA ZOIS, Individually, as surviving Spouse, and

Personal Representative of the Estate of PROKOPIOS
ZOIS, Deceased;

MADELEINE A. ZUCCALA, Individually, as surviving

Spouse, and Personal Representative of the Estate of
JOSEPH J. ZUCCALA, Deceased;
JOLAINE J. ZUCCALA, as surviving Child of JOSEPH
J. ZUCCALA, Deceased;
KAYLENE E. ZUCCALA-SAMS, as surviving Child of
JOSEPH J. ZUCCALA, Deceased;

73
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 15 of 30

SANDRA ZUCCALA, as surviving Sibling of JOSEPH

J. ZUCCALA, Deceased;
THERESA PATERSON, as surviving Sibling of
JOSEPH J. ZUCCALA, Deceased;
TINA CAMMARATA, as surviving Sibling of JOSEPH
J. ZUCCALA, Deceased;

ERICA ZUCKER HEISLER, Individually, as surviving

Spouse, and Personal Representative of the Estate of
ANDREW S. ZUCKER, Deceased;
ERICA ZUCKER HEISLER on behalf of JASON A.
ZUCKER, minor, Deceased;

1. Personal Injury Claimants

PASQUALE ABATANGELO, Individually;

ANTHONY ACCARDO, Individually;
JOSEPH ACCETTA, Individually;
LUIS ACEVEDO, Individually;
PETER ACQUAFREA, Individually;
PAUL ADAMS, Individually;
ALDO ADISSI, Individually;
THEODORUS ADRICHEM, Individually;
MICHAEL AGOVINO, Individually;
RICHARD AGUGLIARO, Individually;
ALAMO AGUSTINO, Individually;
ROGER AHEE, Individually;
KENNETH AHLERS, Individually;
THOMAS AKERBERG, Individually;
EDWARD ALFARANO, Individually;
RICHARD ALLES, Individually;
CHRISTOPHER AMATO, Individually;
ANTHONY ANDERSON, Individually;
STEPHEN ANDERSON, Individually;
VINCENT ANDERSON, Individually;
FRANK ANDINO, Individually;
STANLEY ANDRUSYCZYN, Individually;
SALVATORE ANNERINO, Individually;
ROBERT ANNUNZIATO, Individually;
ANDREW ANSBRO, Individually;
HARRY ANTONOPOULOS, Individually;
SALVATORE ANZALONE, Individually;
EDWARD AND KATHLEEN ARANCIO, Individually;
LAWRENCE ARCHER, Individually;
RAYMOND ARCOS, Individually;

74
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 16 of 30

LEONARD AND BARBARA ARDIZZONE,

Individually;
MICHAEL ARMETTA, Individually;
DAVID AROCHO, Individually;
RUTH ARON, Individually;
THOMAS ASHER, Individually;
JOSEPH ASTARITA, Individually;
CHRISTOPHER ATTANASIO, Individually;
ANTHONY AUCIELLO, Individually;
MARYLOU AURRICHIO, Individually;
ANGEL AYALA, Individually;
CHRISTOPHER BACH, Individually;
JOSEPH BACHERT, Individually;
BENJAMIN BADILLO, Individually;
THOMAS BAEZ, Individually;
MICHAEL BAILEY, Individually;
CANDIACE BAKER, Individually;
JOSEPH V. BAKSH, Individually;
AUGUSTIN BALARAM, Individually;
WEST BALLOU, Individually;
NICHOLAS BALSAMO, Individually;
RICHARD BANAT, Individually;
ARTURO BANCHS, Individually;
MICHAEL BANKER, Individually;
ROBERT BARAN, Individually;
JAMES J. BARANEK, Individually;
PAUL BARBARA, Individually;
PAUL BARDO, Individually;
THOMAS BAROZ, Individually;
CHRISTOPHER BARRETT, Individually;
KEVIN BARRETT, Individually;
ROBERT BARRETT, Individually;
BRUCE BARVELS, Individually;
STEVEN BASCELLI, Individually;
PAUL BASSO, Individually;
ANDREW BEARD, Individually;
EDITH BEAUJON, Individually;
MICHAEL BEHETTE, Individually;
JOHN BELFORD, Individually;
MARIO BELL, Individually;
JOHN BELMONTE, Individually;
LORI-ANN BENINSON, Individually;
JOSEPH BENNETT, Individually;
TIMOTHY BENNETT, Individually;
JAMES BERGEN, Individually;
JOSEPH BERING, Individually;

75
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 17 of 30

ROBERT BERMINGHAM, Individually;

CHARLES BERNARDI, Individually;
MARK BERNHEIMER, Individually;
FRANK BERRAN, Individually;
RUBEN BERRIOS, Individually;
JOSEPH BERTOLINO, Individually;
MARVIN BETHEA, Individually;
JAMES BEUERMAN, Individually;
DANIEL BEYAR, Individually;
GEORGE BEYER, Individually;
GREGORY BIERSTER, Individually;
DONALD BIGI, Individually;
STEVEN BILICH, Individually;
HOWARD BISCHOFF, Individually;
JOSEPH BISERTA, Individually;
RICHARD BITTLES, Individually;
IRENE BLAICH, Individually;
PETER BLAICH, Individually;
WILLIAM BLAICH, Individually;
SUSAN BLAKE, Individually;
MARK BLANCHARD, Individually;
MATTHEW BLASKOVICH, Individually;
GODFREY BLYTHE, Individually;
THOMAS BOCCAROSSA, Individually;
KENNETH BOHAN, Individually;
MICHAEL BOLAND, Individually;
CHARLES BONAR, Individually;
JOHN BONGIORNO, Individually;
REGINALD BONNER, Individually;
MARK BONSANTI, Individually;
ANDREW BORGESE, Individually;
ROBERT BORNHOEFT, Individually;
NICHOLAS BORRILLO, Individually;
MARIA BOURDIS, Individually;
ENIS BOYER, Individually;
MICHAEL BOYLE, Individually;
GEORGE BRAADT, Individually;
MANUEL BRACERO, Individually;
JAMES BRADY, Individually;
THOMAS BRADY, Individually;
ANDREW BRAUN, Individually;
MARTIN BRAUN, Individually;
JOSEPH BREEN, Individually;
GERALD BRENKERT, Individually;
JAMES BRENNAN, Individually;
RONALD BRENNEISEN, Individually;

76
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 18 of 30

DONALD BRIERLEY, Individually;

VITO BRINZO, Individually;
LADWIN BRISSETT, Individually;
MICHAEL BROCATO, Individually;
MICHAEL BRODY, Individually;
MICHAEL BROSCHART, Individually;
CHRISTOPHER BROUGHTON, Individually;
JAMES BROWN, Individually;
JOZETTE BROWN, Individually;
PAUL BROWN, Individually;
PETER BROWN, Individually;
RAYMOND BROWN, Individually;
PETER BRUNAES, Individually;
GREG BRUNO, Individually;
JAMES BRUNO, Individually;
STEPHEN BRUNO, Individually;
DAVID BRUNSDEN, Individually;
MICHAEL BUCKLEY, Individually;
MICHAEL BUDISCHEWSKY, Individually;
MATTHEW BUONO, Individually;
VINCENT BUONOCORE, Individually;
CHARLES BURGE, Individually;
JAMES BURKE, Individually;
MICHAEL BURKE, Individually;
STEPHEN BURKE, Individually;
WILLIAM BURKE, Individually;
THOMAS BURKE, Individually;
ROBERT BURNS, Individually;
JACQUELINE BURTON, Individually;
JOHN BYRNES, Individually;
NELSON CABAN, Individually;
EDWARD CACHIA, Individually;
MICHAEL CAHILL, Individually;
FRANCIS CALABRO, Individually;
KEVIN CALHOUN, Individually;
GARY CALI, Individually;
ROBERT CALISE, Individually;
THOMAS CALKINS, Individually;
VINCENZO CALLA, Individually;
THOMAS CALLAGHAN, Individually;
ERNANDO CAMACHO, Individually;
PATRICK CAMACHO, Individually;
RICHARD CAMIOLO, Individually;
RONALD CAMMARATA, Individually;
BRYAN CAMPBELL, Individually;
RICHARD CAMPBELL, Individually;

77
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 19 of 30

ATTHEW CAMPISI, Individually;

VINCENT CANALE, Individually;
THOMAS CANN, Individually;
BIAGIO CANTATORE, Individually;
VICTOR CANTELMO, Individually;
MICHAEL CAPASSO, Individually;
CHARLES CAPLE, Individually;
ROBERT CAPOLONGO, Individually;
DAVID CAPUTO, Individually;
FRANK CAPUTO, Individually;
DAVID CARDINALE, Individually;
HARRY CARDIO, Individually;
PATRICK CAREY, Individually;
PETER CARINO, Individually;
RICHARD CARLINO, Individually;
WILLIAM CARLSON, Individually;
ANGEL CARRERO, Individually;
CHRISTOPHER CARRI, Individually;
JOHN CARROLL, Individually;
WILLIAM CARROLL, Individually;
ROBERT CARUSO, Individually;
RICHARD CASALETTO, Individually;
JOSEPH CASALIGGI, Individually;
RAYMOND CASCIO, Individually;
THOMAS CASCIO, Individually;
DONALD CASEY, Individually;
GERARD CASEY, Individually;
JAMES CASH, Individually;
STEPHEN CASSE, Individually;
JOHN CASSIDY, Individually;
KEVIN CASSIDY, Individually;
STEPHEN CASSIDY, Individually;
GREGORY CASTELLANO, Individually;
JOHN CATATANO, Individually;
ANTHONY CATERA, Individually;
JOHN CAVAELLI, Individually;
HENRY CERASOLI, Individually;
JOSEPH CESTARI, Individually;
ANTHONY CHAIMOWITZ, Individually;
WILLIAM CHESNEY, Individually;
GERALD CHIAVELLI, Individually;
DINO CHIRCO, Individually;
SHERWIN CHOW, Individually;
JEFFREY CHRISTENSEN, Individually;
ROBERT CHRISTY, Individually;
BUNDY CHUNG, Individually;

78
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 20 of 30

PETER CIAPPA, Individually;

FRANK CIARAVINO, Individually;
ZOSIA CIESLIK, Individually;
JAMES CIZIKE, Individually;
RAYMOND CLANCY, Individually;
DONALD CLARK, Individually;
LAWRENCE CLARK, Individually;
DENNIS CLARKE, Individually;
BRIAN CLARO, Individually;
DAVID CUNGAIN, Individually;
JOHN CLINTON, Individually;
DERMOTT CLOWE, Individually;
JAMES CODY, Individually;
CHRISTOPHER COEN, Individually;
ROBERT COLACINO, Individually;
JONATHAN COLEMAN, Individually;
ROBERT COLLIGAN, Individually;
WILLIAM COLLINS, Individually;
GEORGE COLUCCI, Individually;
CARMELO COMPOSTO, Individually;
STEPHEN CONKLIN, Individually;
DAVID CONLIN, Individually;
KEVIN CONNELLY, Individually;
JAMES CONNOLLY, Individually;
MICHAEL CONNOLLY, Individually;
PATRICK CONNOLLY, Individually;
THOMAS CONNOLLY, Individually;
WILLIAM CONNOLLY, Individually;
CHRISTOPHER CONNOR, Individually;
STEVEN CONNOR, Individually;
THOMAS CONROY, JR., Individually;
JEFFREY CONTI, Individually;
KENNETH COOK, Individually;
WALTER COOK, Individually;
WERNER COOK, Individually;
JOHN COOMBS, Individually;
JAMES COONEY, Individually;
DOUGLAS F. COPP, Individually;
MICHAEL CORR, Individually;
MICHAEL CORRIGAN, Individually;
CHRISTOPHER CORSI, Individually;
STEVEN COSCIA, Individually;
MICHAEL COSTA, Individually;
EDWARD COSTELLO, Individually;
ROY COTIGNOLA, Individually;
JOSEPH COTTER, Individually;

79
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 21 of 30

JOSE COTTI, Individually;

JOHN COTTON, Individually;
PATRICK COTTON, Individually;
CHRISTOPHER COUGHLIN, Individually;
JOHN COUGHLIN, Individually;
THOMAS COURTENAY, Individually;
EDWARD COYLE, Individually;
RICHARD COYLE, Individually;
TERENCE COYLE, Individually;
BRIAN COYLE, Individually;
JOHN COYLE, Individually;
RICHARD COYNE, Individually;
GIBSON A. CRAIG, Individually;
CHRIS CRAVEN, Individually;
GERARD CRAWFORD, Individually;
WILLIAM CRAWFORD, Individually;
PAUL CRESCI, Individually;
GEORGE CRISCITIELLO, Individually;
OMAR CRISOSTOMO, Individually;
BRENT CROBAK, Individually;
CHARLES CROCCO, Individually;
JOHN CRONLEY, Individually;
FRANK CSEKO, Individually;
DONALD CSORNY, Individually;
JOHN CUCCIOLA, Individually;
STEVEN CUEVAS, Individually;
PATRICK CULLEN, Individually;
LEONARD CURCIO, Individually;
PETER CURCIO, Individually;
RICHARD CURIEL, Individually;
EDWARD CURLEY, Individually;
JOHN CURLEY, Individually;
FRANK CURNYN, Individually;
JOSEPH CURRAN, Individually;
EDWARD CUTTING, Individually;
DENNIS CZECZOTKA, Individually;
ALAN DAGISTINO, Individually;
STEVEN DAHLSTROM, Individually;
KENNETH D'ALBERO, Individually;
ALBERT D'ALLESANDRO, Individually;
JAMES DALTON, Individually;
BRADLEY DALY, Individually;
DANIEL DALY, Individually;
JOHN DALY, Individually;
PAUL DALY, Individually;
DOMINICK DAMIANO, Individually;

80
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 22 of 30

THOMAS DAMORE, Individually;

PETER D'ANCONA, Individually;
ARTHUR DARBY, Individually;
KEVIN DARCY, Individually;
DOMINIC D'ARRIGO, Individually;
GERARD DAVAN, Individually;
HARROLD DAVER, Individually;
MARK DAVINO, Individually;
JIMMIE DAVIS, Individually;
JOSEPH DAWSON, Individually;
VINCENT DECICCO, Individually;
RODNEY DECORT, Individually;
FRANCIS DEFEO, Individually;
GEORGE DEGEWORTH, Individually;
KEVIN DELANO, Individually;
WILLIAM DELEHANTY, Individually;
FRED DELGROSSO, Individually;
JOSEPH DELGROSSO, Individually;
ROBERT J. D'ELIA, Individually;
KIRK DELNICK, Individually;
PHILIP DEMARIA, Individually;
VINCENT DEMARINIS, Individually;
NICHOLAS DEMASI, Individually;
RAYMOND DENNINGER, Individually;
RUDOLF DENT, Individually;
JAMES DEPAOB, Individually;
MICHAEL DEPIETRO, Individually;
ROBERT DESANDIS, Individually;
ETIENNE DEVILLIERS, Individually;
DOMINICK DEVITO, Individually;
JOHN DEVLIN, Individually;
JOHN DIAZ, Individually;
RAYMOND DIAZ, Individually;
ROLAND DIAZ, Individually;
DONALD DIDOMENICO, Individually;
RONALD J. DIFRANCESCO, Individually;
ROBERT DIGIOVANNI, Individually;
ANDREW DIGIUGNO, Individually;
MARK DIMAGGIO, Individually;
MICHAEL DINATALE, Individually;
RICHARD DIORIO, Individually;
CHARLES DIRICO, Individually;
ROBERT DISANZA, Individually;
JOHN DIXON, Individually;
VICTOR DIZ, Individually;
JAMES DOBSON, Individually;

81
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 23 of 30

THOMAS DOHERTY, Individually;

KEVIN DOHERTY, Individually;
MICHAEL DOLAN, Individually;
FRANCIS DONAHUE, Individually;
SEAN DONAHUE, Individually;
STEPHEN DONNELLY, Individually;
THOMAS DONNELLY, Individually;
TIMOTHY DONNERY, Individually;
MICHAEL DONOHUE, Individually;
WILLIAM DONOHUE, Individually;
JOSEPH DONOVAN, Individually;
MICHAEL DONOVAN, Individually;
MICHAEL DORGAN, Individually;
JAMES DORMAN, Individually;
KEVIN DORRIAN, Individually;
ROBERT DORRITIE, Individually;
JOHN DOUGHERTY, Individually;
CHARLES DOWNEY, Individually;
JOSEPH R. DOWNEY, Individually;
LEONARD DRAVES, Individually;
JOSEPH DREXLER, Individually;
JOHN R. DRISCOLL, Individually;
JOSEPH DRISCOLL, Individually;
RICHARD DRISCOLL, Individually;
RICHARD DUBOIS, Individually;
RICHARD DUBOWY, Individually;
DANIEL DUDDY, Individually;
BOBBY DUDLEY, Individually;
BRIAN DUFFY, Individually;
KEVIN DUFFY, Individually;
KEVIN DUNCAN, Individually;
JOHN DUNN, Individually;
JOSEPH DUNN, Individually;
WILLIAM DUNN, Individually;
THOMAS DUNN, Individually;
JODY DUPUIS, Individually;
GEORGE EDGEWORTH, Individually;
CHRISTOPHER EDWARDS, Individually;
WILLIAM EDWARDS, Individually;
JAMES EFTHIMIADES, Individually;
ERNEST EHLBERG, Individually;
GREG EINSFELD, Individually;
WILLIAM ELLIS, Individually;
JAMES ELMENDORF, Individually;
MICHAEL ENDRIZZI, Individually;
JOHN ENGEL, Individually;

82
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 24 of 30

JOSEPH ENIA, Individually;

KENNETH ERB, Individually;
RICHARD ERDEY, Individually;
ALBERT ESTRADA, Individually;
DAVID FARRAN, Individually;
DENNIS FARRELL, Individually;
KEVIN FARRELL, Individually;
THOMAS FARRELL, Individually;
JOSEPH FAZZINO, Individually;
ELIZABETH FEATHERSTON, Individually;
STEVEN FEDORCZUK, Individually;
FRANCIS FEEHAN, Individually;
JAMES FEELEY, Individually;
JOSEPH FELLE, Individually;
TERRY FELRICE, Individually;
DANIEL FENNELL, Individually;
RUTH FENNER, Individually;
JILL FENWICK, Individually;
ROSARIO FERLISI, Individually;
MANUEL FERNANDEZ, Individually;
THOMAS FERRANOLA, Individually;
EDWARD FERRARO, Individually;
NICOLE FERRELL, Individually;
SALVADOR FERRER, Individually;
JAMES FILOMINO, Individually;
JAMES FINN, Individually;
TERENCE FINNERMAN, Individually;
FRANK FIORE, Individually;
DAVID FISCHBEIN, Individually;
CHRISTOPHER FISCHER, Individually;
LEE FISCHER, Individually;
CARL FISHER, Individually;
ROBERT FITHIAN, Individually;
DAVID FITTON, Individually;
MICHAEL FITZMAURICE, Individually;
MIKE FITZPATRICK, Individually;
PATRICK FITZSIMMONS, Individually;
LIAM FLAHERTY, Individually;
WILLIAM FLAHERTY, Individually;
HOLLIS FLANAGAN, Individually;
JAMES FLANAGAN, Individually;
MICHAEL FLANAGAN, Individually;
THOMAS FLEMING, Individually;
THOMAS FLETCHER, Individually;
DONALD FLORE, Individually;
DANIEL FLORENCO, Individually;

83
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 25 of 30

HOWARD FLUGMACHER, Individually;

JOHN FLYNN, Individually;
JOSEPH FLYNN, Individually;
MICHAEL FLYNN, Individually;
RICHARD FLYNN, Individually;
WILLIAM FODER, Individually;
GREGORY FODOR, Individually;
BENJAMIN FOGEL, Individually;
DANIEL FOLEY, Individually;
ROBERT FOLEY, Individually;
FRANK FONTAINO, Individually;
ALAN FORCIER, Individually;
GEORGE FORIS, Individually;
NICHOLAS FORNARIO, Individually;
VINCENT FORRAS, Individually;
WARREN FORSYTH, Individually;
CHARLES FORTIN, Individually;
MICHAEL FOSSATI, Individually;
ANTHONY FRACHIOLLA, Individually;
LEO FRAGAPANO, Individually;
LUIS FRAGOSO, Individually;
PETER FRANK, Individually;
SCOTT FRAZIER, Individually;
JAMES FREER, Individually;
TIMOTHY FROLICH, Individually;
DANIEL FUCELLA, Individually;
FREDERICK FUCHS, Individually;
ALFREDO FUENTES, Individually;
JOHN FULLAM, Individually;
DANIEL FURLAND, Individually;
CHARLES GAFFNEY, Individually;
JOHNNY GAGLIANO, Individually;
JOHN GAINE, Individually;
JACK GALANTE, Individually;
ANDREW GALASSO, Individually;
DENNIS GALLAGHER, Individually;
ROBERT GALLAGHER, Individually;
JAMES GALLICCHIO, Individually;
ANTHONY GALLO, Individually;
CHARLES GALLOGY, Individually;
PHILIP GAMBINO, Individually;
EDWARD GANASSA, Individually;
PETER GANNON, Individually;
ANNE GARCIA, Individually;
JAMES GARCIA, Individually;
RAFAEL GARCIA, Individually;

84
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 26 of 30

ANDREW GARGIULO, Individually;

WAYNE GARGIULO, Individually;
JOHN GARNETT, Individually;
ROBERT GAROFOLO, Individually;
SHARON GATTO, Individually;
STEPHEN GAUDUT, Individually;
RUDOLPH GEIGER, Individually;
SEAN GENOVESE, Individually;
CHRISTOS GEORGE, Individually;
PAUL GERMANN, Individually;
BRUCE GERRIE, Individually;
THOMAS GERRISH, Individually;
PETER GIAMMARINO, Individually;
GUERINO GIANNATTANASIO, Individually;
KENNETH GIANNELLI, Individually;
BONNIE GIEBERIED, Individually;
SALVATORE GIGANTE, Individually;
JOSEPH GILDEN, Individually;
DENNIS GILHOOLY, Individually;
NORMAN GILLARD, Individually;
STEVEN M. GILLESPIE, Individually;
MICHAEL GIMPEL, Individually;
MICHAEL GINTY, Individually;
CRAIG GIUFFRE, Individually;
JOHN GIUFFRIDA, Individually;
BRIAN GLEASON, Individually;
ROBERT GLEASON, Individually;
WILLIAM GLEASON, Individually;
MICHAEL GLENN, Individually;
KEVIN GLOCK, Individually;
PETER GLOWACZ, Individually;
BARRY GOFFRED, Individually;
WILLIAM GOLDSTEIN, Individually;
MARK GOLDWASSER, Individually;
DONALD GOLLER, Individually;
AWILDA GOMEZ, Individually;
TONY GONZALEZ, Individually;
FRANCINE GOODMAN, Individually;
GLORIA-GIGI GORDON, Individually;
JOHN GORGONE, Individually;
MICHAEL GORMAN, Individually;
PATRICK GORMAN, Individually;
WILLIAM GORMAN, Individually;
RICHARD GOULD, Individually;
STEPHEN GRABNER, Individually;
KEVIN GRACE, Individually;

85
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 27 of 30

MICHAEL GRACE, Individually;

JOHN GRAHAM, Individually;
LANAIRD GRANGER, Individually;
JOHN GRAZIANO, Individually;
CHRISTOPHER GREEN, Individually;
WILLIAM GREEN, Individually;
ANTHONY GREENE, Individually;
MICHAEL GREGORY, Individually;
ROBERT GRELL, Individually;
AURELIO GRILLO, Individually;
MICHAEL GRILLO, Individually;
DANIEL GROGUL, Individually;
KEITH GROSS, Individually;
KRISTEN GROSS, Individually;
LLOYD GROSSBERG, Individually;
DANIEL GROSSI, Individually;
MICHAEL GUARDINO, Individually;
PHILIP GUARNIERI, Individually;
THOMAS GUARNIERI, Individually;
STEVEN GUISE, Individually;
FRANK GUNTHER, Individually;
MICHAEL GURNICK, Individually;
KEVIN GUTFLEISCH, Individually;
LUIS GUTIERREZ, Individually;
KEVIN GUY, Individually;
PAUL HAARMAN, Individually;
JAMES HALABY, Individually;
JAMES HALEY, Individually;
PAUL HALEY, Individually;
GARY HALL, Individually;
ISRAEL HALPERN, Individually;
KENNETH HAMILTON, Individually;
JOSEPH G. HANDS, Individually;
LEAKAT HANIF, Individually;
GARY HANLEY, Individually;
KENNETH HANSEN, Individually;
SCOTT HANSON, Individually;
RON HARDING, Individually;
DOUGLAS HARKINS, Individually;
JEREMIAH HARNEY, Individually;
EMIL HARNISCHFEGER, Individually;
TIMOTHY HARRIGAN, Individually;
KIRK HARRINGTON, Individually;
THOMAS HARRINGTON, Individually;
EUGENE HARRIS, Individually;
JOSEPH HARRIS, Individually;

86
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 28 of 30

MICHAEL HARRIS, Individually;

WILLIAM HARRIS, Individually;
RICHARD HARRISON, Individually;
MICHAEL HART, Individually;
ROBERT HARTIE, Individually;
BRIAN HARVEY, Individually;
FRANCIS HASKELL, Individually;
JOHN HASSETT, Individually;
PATRICK HAYDEN, Individually;
WARREN C. HAYES, Individually;
LEROY HAYNES, Individually;
RAYMOND HAYWOOD, Individually;
MELFORD HAZEL, Individually;
JAMES HEAL, Individually;
BRIAN HEALY, Individually;
DAVID HEALY, Individually;
GEORGE HEAR, Individually;
STEPHEN HEAVEY, Individually;
MICHAEL HEFFERNAN, Individually;
TODD HEIMAN, Individually;
GREGORY HELFER, Individually;
EUGENE HENDERSON, Individually;
WILLIAM HENDERSON, Individually;
WILLIE HENDERSON, Individually;
WILLIAM HENNESSY, Individually;
MICHAEL HENNIGNA, Individually;
JOHN HENRICKSEN, Individually;
JOHN HENRY, Individually;
THOMAS HENRY, Individually;
WILLIAM HERLIHY, Individually;
JEFF HESTNES, Individually;
HERBERT HICKEY, Individually;
JOSEPH HICKEY, Individually;
PATRICK HICKEY, Individually;
SEAN HICKEY, Individually;
JOSEPH HIGGINS, Individually;
WILLIAM HOAG, Individually;
JAMES D. HODGES, Individually;
ROBERT HOFER, Individually;
DONALD HOFFMAN, Individually;
JOHN HOGAN, Individually;
JOHN HOLOHAN, Individually;
TERRENCE HOLT, Individually;
TIMOTHY HOPPEY, Individually;
BRYAN HORAN, Individually;
MICHAEL HORAN, Individually;

87
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 29 of 30

LAURA HORDT, Individually;

ANDREW HORNBUCKLE, Individually;
ROBERT HOURICAN, Individually;
ANDREA HOWELL, Individually;
ROBERT HOYT, Individually;
EDWARD HRONEC, Individually;
MORRIS HUBBARD, Individually;
SCOTT HUGHES, Individually;
THOMAS HUGHES, Individually;
ROBERT HUMPHREY, Individually;
WILLIAM HUMPHREY, Individually;
PAIGE HUMPHRIES, Individually;
CHRISTOPHER HUNT, Individually;
JAMES HURON, Individually;
JAMES HURSON, Individually;
RICHARD HUTRA, Individually;
JOHN IAMMATTEO, Individually;
DAVID IANELLI, Individually;
MICHAEL IANNAZZO, Individually;
RAFAEL IGLESAIS, Individually;
MICHAEL INCANTALUPO, Individually;
LLOYD INFANZON, Individually;
EARTHA INGRAM, Individually;
WILLIAM INGRAM, Individually;
PETER IOVENO, Individually;
EDWARD IRELAND, Individually;
SALVATORE ISABELLA, Individually;
ANDREW ISOLANO, Individually;
NETTA ISSACOF, Individually;
JOSEPH JABLONSKI, Individually;
DANIEL JACKSON, Individually;
VERONICA JACOBS, Individually;
JOHN JAGODA, Individually;
PETER JAKUBOWSKI, Individually;
BRIAN JANELLI, Individually;
THADDEUS JANKOWSKI, Individually;
JOSEPH JANKUNIS, Individually;
RICHARD JANOSCAK, Individually;
MATTHEW JASKO, Individually;
WILLIAM JENNERICH, Individually;
LAWRENCE JENSEN, Individually;
PETER JENSEN, Individually;
WALTER JENSEN, Individually;
JOHN F. JERMYN, Individually;
STANLEY JESSAMINE, Individually;
DESMOND JHAGROO, Individually;

88
 Case 1:17-cv-02003 Document 1-2 Filed 03/20/17 Page 30 of 30

PAUL JOHNSEN, Individually;

ANITA JOHNSON, Individually;
BISHOP DAN JOHNSON, Individually;
BRIAN JOHNSON, Individually;
BYRON JOHNSON, Individually;
KEITH JOHNSON, Individually;
NATHANIAL JOHNSON, Individually;
ROBERT JOHNSTON, Individually;
LEROY JONAS, Individually;
JEFFREY JONES, Individually;
ROBERT JONES, Individually;
NIELS JORGENSEN, Individually;
IRWIN JOSEPH BRODSKY, Individually;
JOHN JOYCE, Individually;
KAZIMIERZ JURGIEL, Individually;
WILLIAM JUTT, Individually;
JOSEPH KADILLAK, Individually;
KEITH KAISER, Individually;
GARY KAKEH, Individually;
WILLIAM KALLETTA, Individually;
THOMAS KANE, Individually;
DANIEL KARP, Individually;
JAMES KAY, Individually;
JURGIEL KAZIMIERZ, Individually;
DANIEL KEANE, Individually;
ROBERT KEANE, Individually;
KENNETH KEARNS, Individually;
ROBERT KEATING, Individually;
WILLIAM KEEGAN, Individually;
THOMAS KEERY, Individually;
MICHAEL KELLEHER, Individually;
ROBERT KELLER, Individually;
JILL KELLEY, Individually;
JILL KELLY, Individually;
JAMES KELLY, Individually;
JOHN KELLY, Individually;
ROBERT KELLY, Individually;
JOHN KELTON, Individually;
DANIEL KEMMET, Individually;
DANIEL KEMMET, SR., Individually;
MICHAEL KEMPER, Individually;
GERARD KENNEDY, Individually;
JOSEPH KENNEDY, Individually;
RICHARD KENNY, Individually;
DENNIS KERBIS, Individually;
KENNETH KERR, Individually;

89
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 1 of 31

JOHN KIELTY, Individually;

JOHN KILCOYNE, Individually;
ROGER KILFOIL, Individually;
JOSEPH KILLEEN, Individually;
CHRISTOPHER KING, Individually;
WILLIAM KING, Individually;
JOHN KIRK, Individually;
PATRICK KISSANE, Individually;
WINFIELD KLUTH, Individually;
ROBERT KMAK, Individually;
WILLIAM KNOTH, Individually;
ERIC KNUTSEN, Individually;
CRAIG KOBES, Individually;
CHARLES KOTOV, Individually;
WALTER KOWALCEZYK, Individually;
MICHAEL KOZAK, Individually;
STEVEN KRAKOWER, Individually;
FRANK KROPF, Individually;
RICHARD KUERNER, Individually;
MICHAEL KULL, Individually;
CARLOS KUPER, Individually;
JOHN LABARBERA, Individually;
RICHARD LACERRA, Individually;
ROBERT LACEY, Individually;
RAYMOND LACHHMAN, Individually;
ERIK LAHODA, Individually;
MICHAEL LALLY, Individually;
LANCE LAMAZZA, Individually;
RAYMOND LAMBDIN, Individually;
MARTIN LANG, Individually;
RICHARD LANG, Individually;
PATRICK LANZA, Individually;
CHRISTOPHER LAROCCA, Individually;
MICHAEL LAROSA, Individually;
JOSEPH LASHER, Individually;
ROBERT LASTELLA, Individually;
JAMES LAUER, Individually;
JOSEPH LAVIN, Individually;
PATRICK LAVIN, Individually;
JOHN LAYTON, Individually;
HOUSSAIN LAZAAR, Individually;
CHAD LEACH, Individually;
WILLIAM LEAHY, Individually;
MICHAEL LEAMY, Individually;
FRANK LEANDRO, Individually;
JOSEPH LECLAIR, Individually;

90
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 2 of 31

WOODY LEDWITH, Individually;

EDWARD LEE, Individually;
STEPHEN LEE, Individually;
ARTIE LEECOCK, Individually;
DANIEL LEFEBVRE, Individually;
CHRISTOS LEFKADITIS, Individually;
JAMES LEIBMAN, Individually;
JOSEPH LEMBO, Individually;
RICHARD LEMONDA, Individually;
KEVIN LENAHAN, Individually;
JOHN LENIHAN, Individually;
HUGH LENNON, Individually;
JOHN LENNON, Individually;
THOMAS LENT, Individually;
JOHN LEVENDOSKY, Individually;
JEFF LEVER, Individually;
VINCENT LEVIEN, Individually;
ABRAHAM LEVINSON, Individually;
PATRICIA LEWIS, Individually;
JAMES LEWIS, Individually;
DANIEL LIND, Individually;
MICHAEL T. LINDY, Individually;
DENNIS LINEHAN, Individually;
RONALD LITTLEJOHN, Individually;
LANCE LIZZUL, Individually;
ROBERT LODATO, Individually;
EDWARD LOEHMANN, Individually;
FRANK LOMBARDI, Individually;
MICHAEL LOMBARDI, Individually;
THOMAS LONEGAN, Individually;
GEORGE LONERGAN, Individually;
STEPHEN LONERGAN, Individually;
MANUAL LOPEZ, Individually;
ROBERT LOPEZ, Individually;
MICHAEL LOPORCARO, Individually;
CHARLES LOSACCO, Individually;
MARK LOTITO, Individually;
VINCENT LOUIS, Individually;
JOHN LOVETT, Individually;
EDWARD LUCIANI, Individually;
STEVEN LUISI, Individually;
VINCENT LUISI, Individually;
SALVATORE LUMIA, Individually;
ADAM LUTFI, Individually;
DAVID LYNN, Individually;
THOMAS LYONS, Individually;

91
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 3 of 31

CHRISTIAN LYSY, Individually;

GREGORY MACAGNONE, Individually;
JACK MACALUSO, Individually;
MICHAEL MACDONALD, Individually;
MICHAEL MACKL, Individually;
FRANK MACRI, Individually;
ROBERT MADDEN, Individually;
JOSEPH MAGGI, Individually;
SANDY AMRITA MAHABIR, Individually;
JAMES MAHON, Individually;
PATRICK MAHONEY, Individually;
FRANK MAISANO, Individually;
ANDRE MAJORS, Individually;
ANDREW MAJORS, Individually;
GLEN MAKUCH, Individually;
CECIL MALONEY, Individually;
PATRICK MALONEY, Individually;
TIMOTHY MALONEY, Individually;
DEBORAH MANDELL, Individually;
ROBERT MANDIA, Individually;
FRANK MANETTA, Individually;
THOMAS MANGUS, Individually;
CHARLES MANISCALCO, Individually;
JAMES MANITTA, Individually;
GREGORY E. MANNING, Individually;
WILLIAM MANNION, Individually;
DANIEL MANOCHIO, Individually;
WAYNE MANZIE, Individually;
LEON MARASHAJ, Individually;
FELIPE MARCANO, Individually;
EDMOND MARCOUX, Individually;
ROBERT MARCOUX, Individually;
RICHARD MARGINO, Individually;
MARY MARINELLI, Individually;
STEVE MARION, Individually;
JOHN MARK, Individually;
LAWRENCE MARLEY, Individually;
JOHN MARR, Individually;
ERIK MARRERO, Individually;
JAMES MARTIN, Individually;
WILLAM MARTIN, Individually;
DARIO MARTINEZ, Individually;
DORIS MARTINEZ, Individually;
WILLIAM MARTINEZ, Individually;
ANTONIO MARTINO, Individually;
MICHAEL MARTORANA, Individually;

92
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 4 of 31

ROCCO MASCIOLO, Individually;

CHRISTOPHER MASSARIA, Individually;
JOHN MASSAROTTI, Individually;
THOMAS MASTRODOMENICO, Individually;
MARC MASTROS, Individually;
DANIEL MATTEO, Individually;
ANTHONY MATTONE, Individually;
GARRY MAURICE, Individually;
THOMAS MAY, Individually;
ROBERT MAYNES, Individually;
RICHARD MAYRONNE, Individually;
GARY MAZALATIS, Individually;
JOSEPH MAZZARELLO, Individually;
LORI MAZZEO, Individually;
KEVIN MCARDLE, Individually;
THOMAS MCAREE, Individually;
BRIAN MCAVOY, Individually;
SEAN MCBRIEN, Individually;
JAMES MCBURNEY, Individually;
EDWARD MCCABE, Individually;
KEVIN MCCABE, Individually;
STEVEN MCCAFFERY, Individually;
THOMAS MCCAFFREY, Individually;
EDWARD MCCAMPHILL, Individually;
JOHN MCCANN, Individually;
NEIL MCCARTHY, Individually;
JAMES MCCARTHY, Individually;
HAROLD MCCLUTCHY, Individually;
CHRISTOPHER MCCORMACK, Individually;
PATRICK MCCORMACK, Individually;
IRVING MCCOY, Individually;
KEVIN MCCUTCHAN, Individually;
JOHN MCDONALD, Individually;
KELLY MCDONALD, Individually;
DANIEL MCDONOUGH, Individually;
DAVID MCDONOUGH, Individually;
KEVIN MCDOWELL, Individually;
CHARLES MCELHONE, Individually;
GREGORY MCENROE, Individually;
PATRICK MCEVOY, Individually;
JOANN MCFARLAND, Individually;
MICHAEL MCFARLAND, Individually;
TERRENCE MCGANN, Individually;
JAMES MCGETRICK, Individually;
SHAUN MCGILL, Individually;
PATRICK MCGIVNEY, Individually;

93
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 5 of 31

JOHN MCGONIGLE, Individually;

CORNELIUS MCGOVERN, Individually;
DAVID MCGOVERN, Individually;
JOSEPH MCGOVERN, Individually;
OWEN J. MCGOVERN, Individually;
KEVIN MCGOWAN, Individually;
BRIAN MCGUIRE, Individually;
ROBERT MCGUIRE, Individually;
THOMAS MCHUGH, Individually;
TIM MCINERNEY, Individually;
JAMES MCKAY, Individually;
WALTER MCKEE, Individually;
BRAIN MCKEEVER, Individually;
THOMAS MCKENNA, Individually;
SHAWN MCKEON, Individually;
CHRISTOPHER MCLAUGHLIN, Individually;
JOHN MCLAUGHLIN, Individually;
WILLIAM MCLAUGHLIN, Individually;
JOSEPH MCMAHON, Individually;
PAUL MCMENAMY, Individually;
WILLIAM MCNALLY, Individually;
JAMES MCNAMARA, Individually;
JOHN MCNAMARA, Individually;
GARY MCNULTY, Individually;
GERARD MCPARLAND, Individually;
ELLEN MCQUEEN, Individually;
ROBERT MEADOWS, Individually;
PHILIP MEDEIROS, Individually;
PAUL MEDORDI, Individually;
VINCENT MEDORDI, Individually;
KEVIN MEEHAN, Individually;
KEVIN MELFI, Individually;
MICHAEL MELILLO, Individually;
KEVIN MELODY, Individually;
JAMES MELVIN, Individually;
RICHARD MEO, Individually;
JOSEPH MEOLA, Individually;
DENNIS MEYERS, Individually;
JAMES MILLER, Individually;
NEIL MILLER, Individually;
MICHAEL MILNER, Individually;
DERRICK MILONE, Individually;
DONALD MIMNAUGH, Individually;
LOUIS MINUTOLI, Individually;
RICHARD MIRANDA, Individually;
JOHN MISKANIC, Individually;

94
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 6 of 31

MARK MISSALL, Individually;

JOHN MIXON, Individually;
JOSEPH MIYNARCZYK, Individually;
ANTHONY MODICA, Individually;
STEVE MODICA, Individually;
AMON MODINE, Individually;
JANET MOLCZYK, Individually;
FRANK MOLLICA, Individually;
PETER MOLNAR, Individually;
PAUL MOLONEY, Individually;
ALWISH MONCHERY, Individually;
FRANK MONDELLI, Individually;
PAUL MONFRE, Individually;
JOHN MONGIELLO, Individually;
WARREN MONROE, Individually;
DOMINICK MONTALTO, Individually;
JOSE MONTALVO, Individually;
YVETTE MONTALVO, Individually;
JOSEPH MONTANARO, Individually;
ELIZARDO MONTES, Individually;
KEVIN MONTGOMERY, Individually;
KENNETH MOODY, Individually;
FRANK MOORE, Individually;
GARY MOORE, Individually;
MICHAEL MOORE, Individually;
THOMAS MOORE, Individually;
ROBERT MOORE, Individually;
JAMES MORAN, Individually;
JOHN MORAN, Individually;
WILLIAM MORAN, Individually;
DONALD MORMINO, Individually;
ALBERTO MORRALES, Individually;
ROBERT MORRIS, Individually;
WILLIAM MORRIS, Individually;
HENRY MORRISON, Individually;
EDWARD MORRISSEY, Individually;
BLANCA MORRONE, Individually;
KEVIN MORRONE, Individually;
JOHN MORRONGIELLO, Individually;
AUDREY MOSLEY MARCUS, Individually;
JOSEPH MOTTOLA, Individually;
FRANK MOTYKA, Individually;
KEVIN MOUNT, Individually;
JERZY MROZEK, Individually;
JOHN MUCCIOLA, Individually;
ANTHONY MUIA, Individually;

95
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 7 of 31

RICHARD MULHERN, Individually;

MARK MULLADY, Individually;
KEVIN MULLANE, Individually;
WILLIAM MULLER, Individually;
HUGH MULLIGAN, Individually;
KENNETH MULLIGAN, Individually;
DANIEL MULLINS, Individually;
JAMES MULLINS, Individually;
BRENDAN MULROY, Individually;
BRIAN MULRY, Individually;
LEONARD MUNDA, Individually;
RAUL MUNIZ, Individually;
MICHAEL MUNOZ, Individually;
MURRAY MURAD, Individually;
JONATHAN MURATH, Individually;
JESSE MURPHY, Individually;
JOHN MURPHY, Individually;
KEITH MURPHY, Individually;
KEVIN G. MURPHY, Individually;
MICHAEL MURPHY, Individually;
PATRICK MURPHY, Individually;
ROBERT MURPHY, Individually;
STEVEN MURPHY, Individually;
THOMAS MURPHY, Individually;
DANIEL MURRAY, Individually;
JOHN MURRAY, Individually;
KEVIN MURRAY, Individually;
GERARD MURTHA, Individually;
MICHAEL MUSTO, Individually;
ARTHUR MYERS, Individually;
FRANK MYERS, Individually;
ANDREA NANNA-MONTGOMERY, Individually;
RICHARD NAPLES, Individually;
JOSEPH NAPOLI, Individually;
JOSEPH NARDONE, Individually;
REYNALDO NARVAEZ, Individually;
ROBERT NEBEL, Individually;
RALPH NEGRON, Individually;
JAMES NEVILLE, Individually;
JOHN NEWELL, Individually;
PETER NEWEN, Individually;
STEVEN NEWMAN, Individually;
THOMAS NEWMAN, Individually;
STEPHEN NICHOLS, Individually;
GERARD NICOLETTI, Individually;
ROBERT NIEBLER, Individually;

96
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 8 of 31

PAUL NIGRO, Individually;

JEFFREY NIX, Individually;
NANCY NOBLE, Individually;
ALBERT NOCELLA, Individually;
WILLIAM NOLAN, Individually;
ALEXANDER NONEY, Individually;
DANIEL NOONAN, Individually;
RICHARD OBERMAYER, Individually;
GREGORY O'BRIEN, Individually;
JOHN O'BRIEN, Individually;
JOSEPH O'BRIEN, Individually;
RICHARD O'BRIEN, Individually;
SEAN O'BRIEN, Individually;
CLARE O'CONNELL, Individually;
MICHAEL O'CONNELL, Individually;
JOHN O'CONNOR, Individually;
PATRICK O'CONNOR, Individually;
THOMAS O'CONNOR, Individually;
WILLIAM O'CONNOR, Individually;
JOHN ODDO, Individually;
JANICE O'DELL, Individually;
WALTER ODINOKOW, Individually;
GEORGE O'DOHERTY, Individually;
CHRISTOPHER O'DONNELL, Individually;
JAMES O'DONNELL, Individually;
JOSEPH O'DONNELL, Individually;
ROBERT O'DOWD, Individually;
MICHAEL O'GORMAN, Individually;
JOSEPH O'HARA, Individually;
HOWARD O'HRINGER, Individually;
BRIAN O'LEARY, Individually;
THOMAS O'LEARY, Individually;
DANIEL OLIVERI, Individually;
DAVID O'NEIL, Individually;
CHARLES O'NEILL, Individually;
TROISI ONOFRIO, Individually;
ROBERT OPALECKY, Individually;
MICHAEL O'ROURKE, Individually;
THOMAS O'ROURKE, Individually;
WILLIAM OROZCO, Individually;
JOSE ORTIZ, Individually;
ARTHUR OSCHMANN, Individually;
MICHAEL O'SHEA, Individually;
HARRY OSTER, Individually;
LUIS OSTOLOZAGA, Individually;
CHRISTOPHER O'SULLIVAN, Individually;

97
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 9 of 31

JOSEPH O'SULLIVAN, Individually;

MICHAEL O'SULLIVAN, Individually;
SEAN O'SULLIVAN, Individually;
GIRARD OWENS, Individually;
GERARD PACE, Individually;
JACQUELINE PADILLA, Individually;
ELROY PAGAN, Individually;
THOMAS PAIR, Individually;
VINCENT PALMIERI, Individually;
MICHELE PAOLINI, Individually;
EDWARD PARKER, Individually;
ROBERT PARKER, Individually;
RONALD PARKER, Individually;
TIMOTHY PARKER, Individually;
GREGORY PARR, Individually;
RONALD PASCUCCI, Individually;
SCOTT PASKEWITZ, Individually;
JOSEPH PASQUARELLO, Individually;
MICHAEL PASQUARELLO, Individually;
PETER PATTERSON, Individually;
DENNIS PATTI, Individually;
JEFFREY PAWLICKI, Individually;
HILTON PEARCE, Individually;
FRANK PEPE, Individually;
GEORGE PEPE, Individually;
FRANK PEREZ, Individually;
LUIS PEREZ, Individually;
OSVALDO PEREZ, Individually;
DANIEL PERITORE, Individually;
JASON PERRONE, Individually;
FRANK PERRY, Individually;
MICHAEL PERRY, Individually;
ROBERT PESCE, Individually;
DARRYL PETTIGREW, Individually;
ROBIN PFEFFER, Individually;
RON PFEFFER, Individually;
FREEDMAN PFEIL, Individually;
CHRISTOPHER PHILLIPS, Individually;
VINCENT PICCIANO, Individually;
JOSEPH PICCININNI, Individually;
RICHARD PICCIOTTO, Individually;
GREGORY PICCONI, Individually;
GEORGE PICKETT, Individually;
JAMES PICONE, Individually;
BOZENA PIELARZ, Individually;
GLEN PILLARELLA, Individually;

98
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 10 of 31

ROBERT PILLARELLA, Individually;

LORRAINE PIRILLO, Individually;
CHRISTOPHER PISANO, Individually;
PERRY PIZZOLO, Individually;
LEWIS PIZZULLI, Individually;
THOMAS PLANE, Individually;
DEDIE PLASENCIA, Individually;
BRYAN PLATT, Individually;
MICHELLE POHL, Individually;
ANDREW POLINSKY, Individually;
MARIE POLITE, Individually;
WILLIAM POLLACK, Individually;
DOMINICK POMA, Individually;
JOSEPH POMA, Individually;
SALVATORE POMA, Individually;
ANDREW PORRAZZO, Individually;
STEPHEN POSE, Individually;
JAMES POWERS, Individually;
LARRY PRATHER, Individually;
FREDERICK PREVETE, Individually;
ROBIN PRINTY, Individually;
KIRK PRITCHARD, Individually;
DANIEL J. PRITZKER, Individually;
MARTIN PROKUP, Individually;
DENNIS PROSICK, Individually;
NICHOLAS PUCCIARELLI, Individually;
ROBERT PUGLIESE, Individually;
RICHARD PULZONE, Individually;
FRANK PUMA, Individually;
CARL PUNZONE, Individually;
ANTHONY QUARANTI, Individually;
PHILIP QUATTROCCHI, Individually;
PABLO QUESADA, Individually;
HENRY QUEVEDO, Individually;
WILLIAM QUICK, Individually;
TIMOTHY QUIN, Individually;
ANDREW QUINN, Individually;
DENNIS QUINN, Individually;
JOSEPH QUINN, Individually;
KEVIN QUINN, Individually;
MICHAEL QUINN, Individually;
RICHARD RACCIOPPI, Individually;
GLENN RADERMACHER, Individually;
JAMES RAGARN, Individually;
MICHAEL RAIMER, Individually;
LOUIS RAIMONDI, Individually;

99
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 11 of 31

DAVID RAPP, Individually;

THOMAS RAPPE, Individually;
ANDREW RASAVONGSZUK, Individually;
STEPHEN RASWEILER, Individually;
RICHARD RATTAZZI, Individually;
DAVID RAYMOND, Individually;
STEVEN RAZICKAS, Individually;
JOSUE RECIO, Individually;
DANIEL REDDAN, Individually;
JAMES REDMOND, Individually;
ROBERT REEG, Individually;
SHAUN REEN, Individually;
DAVID REEVE, Individually;
JOHN REGAN, Individually;
ROBERT REGAN, Individually;
GERARD REILLY, Individually;
JOHN REILLY, Individually;
KEVIN REILLY, Individually;
MARK REILLY, Individually;
STEPHEN REILLY, Individually;
LEONARD REINA, Individually;
ROBERT REIP, Individually;
MICHAEL RELAY, Individually;
JOHN REMENTERIA, Individually;
WILLIAM RENDINO, Individually;
ROBERT JR.. RENODE, Individually;
DAVID RESTUCCIO, Individually;
MICHAEL REUTTER, Individually;
HERMAN REYES, Individually;
JOHN RHATIGAN, Individually;
VITO RIBAUDO, Individually;
MICHAEL RICCIARDI, Individually;
ROBERT RICCIARDI, Individually;
STEPHEN RICCIO, Individually;
EUGENE RICE, Individually;
HOWARD RICE, Individually;
JOHN RICE, Individually;
STEPHEN RICE, Individually;
ROGER RICHES, Individually;
ROCCO RINALDI, Individually;
JOHN RINCIARI, Individually;
LOUIE RIOS, Individually;
DAVID RIVAS, Individually;
ALCIDES RIVERA, Individually;
ALFRED RIVERA, Individually;
DANIEL RIVERA, Individually;

100
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 12 of 31

HECTOR RIVERA, Individually;

ROBERT RIVERA, Individually;
TERENCE RIVERA, Individually;
THOMAS RIVICCI, Individually;
JOHN RIZZI, Individually;
MATTHEW ROACH, Individually;
GARY ROBBINS, Individually;
RAINFORD ROBERTS, Individually;
TIMOTHY ROBERTS, Individually;
THOMAS ROBISKY, Individually;
ANTHONY ROCCHIO, Individually;
JOSEPH ROCHA, Individually;
ROBERT ROCHFORD, Individually;
ALAN ROCKEFELLER, Individually;
BRIAN ROCOVICH, Individually;
WILLIAM RODGERS, Individually;
PETER RODRIGUEZ, Individually;
KENNETH ROGERS, Individually;
KEVIN ROGERS, Individually;
STEVE ROGERS, Individually;
CARMEN ROMERO, Individually;
GUY ROSBROOK, Individually;
TAMAR ROSBROOK, Individually;
BRUCE ROSS, Individually;
MICHAEL ROY, Individually;
DONALD ROZAS, Individually;
JOHN RUBINO, Individually;
KEITH RUBY, Individually;
STEWART RUETER, Individually;
JOSEPH RUGGIRELLO, Individually;
RICHARD RUIZ, Individually;
JAMES RULAND, Individually;
STEPHEN RUSSACK, Individually;
DAVID RUSSELL, Individually;
BRIAN RUSSO, Individually;
SALVATORE RUSSO, Individually;
VITO RUVOLO, Individually;
DENIS RYAN, Individually;
HENRY RYAN, Individually;
KEVIN RYAN, Individually;
RICHARD RYAN, Individually;
ROBERT RYAN, Individually;
THOMAS RYAN, Individually;
EDWARD RZEMPOLVCH, Individually;
ROBERT SACCHI, Individually;
CHRISTINE SAKOUTIS, Individually;

101
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 13 of 31

JOSEPH SALADIS, Individually;

PARIS SALEM, Individually;
STEVEN SAMMIS, Individually;
FELIX SANCHEZ, Individually;
RUDY SANFILIPPO, Individually;
JOHN SANJURJO, Individually;
PETER SANTELLI, Individually;
BOBBY SANTIAGO, Individually;
JOSEPH SAPIENZA, Individually;
JOSEPH SARDO, Individually;
MARK SARNES, Individually;
LOUIS SARTINI, Individually;
ARTHUR SARTOR, Individually;
JEREMY SASSMAN, Individually;
PETER SAVARESE, Individually;
PATRICIA SCADUTO-SOTO, Individually;
ERIC SCAKNOFF, Individually;
MICHAEL SCALARD, Individually;
THOMAS SCALLY, Individually;
THOMAS SCAMBONE, Individually;
KEVIN SCANLON, Individually;
GILBERT SCARAZZINI, Individually;
SALVATORE SCARENTINO, Individually;
PATRICK SCARINGELLO, Individually;
STEVEN SCARINZI, Individually;
JOHN SCARSELLA, Individually;
JOHN SCHAEFER, Individually;
LOUIS SCHAEFER, Individually;
JAMES SCHIAVONE, Individually;
SCOTT SCHIELDS, Individually;
JOHN SCHILLINGER, Individually;
WILLIAM SCHILLINGER, Individually;
RICHARD SCHLUECK, Individually;
CHARLES SCHMID, Individually;
ROBERT SCHMIDT, Individually;
CLINTON SCHMITTERER, Individually;
ROBERT SCHMUCK, Individually;
MICHAEL SCHNITZER, Individually;
ROBERT SCHOR, Individually;
MICHAEL SCHREIBER, Individually;
SCOTT SCHRIMPE, Individually;
ROBERT SCHULZ, Individually;
JAMES SCHWICKE, Individually;
VINCENT SCIALPI, Individually;
VICTOR SCIARAPPA, Individually;
ANGELO SCIFO, Individually;

102
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 14 of 31

GREGORY SCLAFANI, Individually;

JOHN SCOTCH, Individually;
ROBERT SCOTT, Individually;
SUSAN SCOTT, Individually;
MICHAEL SCULLY, Individually;
LISA SECKLER-OODE, Individually;
JOSEPH SEENEY, Individually;
VINCENT SEPE, Individually;
RICHARD SERE, Individually;
ANGEL SERRANO, Individually;
LUIS SERRANO, Individually;
WILLIAM SESSELMAN, Individually;
MICAHEL SFORZA, Individually;
DAVID SGROMO, Individually;
PETER SHANLEY, Individually;
JAMES SHANNON, Individually;
MATTHEW SHANNON, Individually;
BRIAN SHEA, Individually;
JAMES SHEA, Individually;
KEVIN SHEEHAN, Individually;
EDWARD SHEEHY, Individually;
GARY SHERIDAN, Individually;
KEVIN SHEROD, Individually;
JAMES SHERWOOD, Individually;
GIUSEPPE SIBILLA, Individually;
ALPHONSE SICIGNANO, Individually;
ANTHONY SIGNORILE, Individually;
THOMAS SILVESTRI, Individually;
VINCENT SIMEONE, Individually;
DAVID SIMMS, Individually;
JEFFREY SIMMS, Individually;
AUGUSTINE SIMONCINI, Individually;
RAYMOND SIMONS, Individually;
GERARD SIMPSON, Individually;
SAMBA SINERA, Individually;
KHEMRAJ SINGH, Individually;
DENNIS SIRJUESINGH, Individually;
DENNIS SIRY, Individually;
SCOTT SIVERT, Individually;
ANTHONY SKOMINA, Individually;
JOSEPH SKONIECZNY, Individually;
LEO SKORUPSKI, Individually;
GARY SLATTERY, Individually;
JAMES SMAGALA, Individually;
GARY SMILEY, Individually;
CARLTON SMITH, Individually;

103
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 15 of 31

GEORGE SMITH, Individually;

GERARD SMITH, Individually;
JAMES SMITH, Individually;
PATRICK SMITH, Individually;
WARREN SMITH, Individually;
WILLIAM SMITH, Individually;
MICHAEL SMITH, Individually;
GERALD SNELL, Individually;
RICHARD SNYDER, Individually;
WILLIAM SOHMER, Individually;
MARK SOLARI, Individually;
GERARD SOMERVILLE, Individually;
FRANK SOMMA, Individually;
STEVEN SORGER, Individually;
WALTER SORRENTI, Individually;
MICHAEL SORRENTINO, Individually;
PHILIP SOTO, Individually;
DEAN SPADARO, Individually;
WILLIAM SPADE, Individually;
JOSEPH SPAGNOLA, Individually;
FRANK SPALDO, Individually;
DOUGLAS SPANO, Individually;
CHRISTOPHER SPARACIA, Individually;
HENRY SPEICHER, Individually;
ROBERT SPELLMAN, Individually;
JAMES SPENCER, Individually;
STEPHEN SPINELLI, Individually;
ROBERT SPINELLI, Individually;
BRIAN SPISTO, Individually;
THOMAS SPITZBARTH, Individually;
FRANK SPRING, Individually;
BERTRAM SPRINGSTEAD, Individually;
ROBERT SPUTH, Individually;
MICHAEL SPYNTIUK, Individually;
ANTHONY SROUR, Individually;
EUGENE ST. JOHN, Individually;
CLIFFORD STABNER, Individually;
BERTRAM STAHLBERG, Individually;
JOHN STAIANO, Individually;
ADOLPH STAMPFEL, Individually;
JAMES STANG, Individually;
ROBERT STANLEWICZ, Individually;
ROBERT STANTON, Individually;
JAMES STASIO, Individually;
KEVIN STEININGER, Individually;
SYLVESTER STEWART, Individually;

104
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 16 of 31

MARK STONE, Individually;

PETER STRAHL, Individually;
LOUIS STRANDBERG, Individually;
BRIAN STRENGE, Individually;
RAY STRONG, Individually;
BRIAN J. SULLIVAN, Individually;
JIMMIE SULLIVAN, Individually;
PATRICK SULLIVAN, Individually;
JAMES SULLIVAN, Individually;
STEVEN SUPEK, Individually;
DANIEL SURAT, Individually;
GARY SUSON, Individually;
ERIC SUTTON, Individually;
MICHAEL SUWALSKI, Individually;
ISA SWEDIN, Individually;
EDWARD SWEENEY, Individually;
JOSEPH SYKES, Individually;
DENNIS TAAFFE, Individually;
KEITH TANICO, Individually;
DAVID TANZMAN, Individually;
ALPHA TARAWALLY, Individually;
PETER TARTAGLIONE, Individually;
FELICIA TAYLOR, Individually;
JOHN TEDESCO, Individually;
MICHAEL TENTEROMANO, Individually;
JEFF TESORIERO, Individually;
VINCENT TESORIERO, Individually;
LUIS THOMAS, Individually;
THOMAS THOMASEN, Individually;
DONALD THOMPSON, Individually;
JAMES THOMPSON, Individually;
ROBERT THOMPSON, Individually;
SCOTT THOMSON, Individually;
ROBERT TILEARCIO, Individually;
THOMAS TILLOTSON, Individually;
RICHARD TING, Individually;
DONALD TOMM, Individually;
KEVIN TONKIN, Individually;
STEVEN TONREY, Individually;
ALVIN TORO, Individually;
ANGEL TORRES, Individually;
EDGAR TORRES, Individually;
EDITH TORRES, Individually;
GEORGE L. TORRES, Individually;
WALTER TORRES, Individually;
JOSEPH TORRILLO, Individually;

105
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 17 of 31

JOSEPH TOSCANO, Individually;

RUSSELL TOUHEY, Individually;
CHARLES TOZZO, Individually;
JAMES TOZZO, Individually;
PETER TRACY, Individually;
FRANCIS TRAPANI, Individually;
PETER TRAUT, Individually;
BARRY TRAVIS, Individually;
LOUIS TREGLIA, Individually;
TINA TRESCA, Individually;
MICHAEL TREZZA, Individually;
MICHAEL TRIGLIANOS, Individually;
ROBERT V. TRIVIGNO, Individually;
JOHN TROIANIELLO, Individually;
VICTOR TROISI, Individually;
RALPH TUFANO, Individually;
EDWARD TURNER, Individually;
JOSEPH TUSTIN, Individually;
ERIC TVEDT, Individually;
LEONARD TYRELL, Individually;
THOMAS UBERTINI, Individually;
BRIAN URBAN, Individually;
NEIL VAILLANCOURT, Individually;
ANTHONY VALETTA, Individually;
CHARLES VAN PELT, Individually;
THOMAS VANROSSEM, Individually;
JOHN VANWAGONER, Individually;
MARIO VASCON, Individually;
DONALD VASTOLA, Individually;
ONELIA VAZQUEZ, Individually;
DANIEL VELAZQUEZ, Individually;
JOSE VELAZQUEZ, Individually;
SALVATORE VENTIMIGLIA, Individually;
JOHN VERACKA, Individually;
STEVEN VERDEROSA, Individually;
RICHARD VETLAND, Individually;
GUY VILLANO, Individually;
PHILIP VINCENZO, Individually;
ROBERT VINCIGUERRA, Individually;
BETTY VIOLETA-LLANO, Individually;
GREGORY VOCE, Individually;
RUSSELL J. VOMERO, Individually;
HARRY WAIZER, Individually;
FREDERICK WALKER, Individually;
ED WALLACE, Individually;
ROBERT WALLEN, Individually;

106
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 18 of 31

DANIEL WALSH, Individually;

EDWARD WALSH, Individually;
WILLIAM WALSH, Individually;
CHRISTOPHER WANKER, Individually;
CHRISTOPHER WARD, Individually;
KEITH WARD, Individually;
GARY WASHINGTON, Individually;
MACK WASHINGTON, Individually;
RICHARD WATTS, Individually;
ALBERT WEBER, Individually;
JOHN WEBER, Individually;
CHARLES WEINSHEIMER, Individually;
PAUL WEIS, Individually;
STEVEN WEISNER, Individually;
JAMES WELDON, Individually;
RICHARD WELDON, Individually;
CHARLES WELLS, Individually;
WILLIAM WELSH, Individually;
GARY WENDELL, Individually;
JAMES WERNER, Individually;
MICHAEL WERNICK, Individually;
JAMES WHITE, Individually;
JOHN WHOLIHAN, Individually;
JOHN WHYTE, Individually;
ROBERT WIEDMANN, Individually;
ROBERT WILDAY, Individually;
JOHN WILLADSEN, Individually;
DEREK WILLIAMS, Individually;
HERMAN WILLIAMS, Individually;
KEVIN WILLIAMS, Individually;
THOMAS WILLIAMS, Individually;
TYRONE WILLIAMS, Individually;
VANDON WILLIAMS, Individually;
VINCENT WILLIAMS, Individually;
ROBERT WILLIAMSON, Individually;
JAMES WILLIS, Individually;
JOHN WILSON, Individually;
JOHN WILSON, Individually;
ROBERT WILSON, Individually;
JAMES WINTERS, Individually;
DENNIS WIRBICKAS, Individually;
MICHAEL WITKOWSKI, Individually;
GARY WOOD, Individually;
JOHN WROBEL, Individually;
SPIRO YIORAS, Individually;
JOHN YORKS, Individually;

107
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 19 of 31

VINCENT YORKS, Individually;

MARK YOUNGBERG, Individually;
JAMES ZADROGA, Individually;
ROBERT ZAJKOWSKI, Individually;
STEPHEN ZASA, Individually;
MICHAEL ZECHEWYTZ, Individually;
PHILIP J. ZEISS, Individually;
THOMAS ZELIOS, Individually;
PATRICK ZODA, Individually;
MARTIN ZOLLNER, Individually;
MAURICE ZUNIGA, Individually;

SHERI G. BURLINGAME, Individually as Spouse and SPEISER KRAUSE

as Personal Representative of the Estate of CHARLES
FRANK BURLINGAME, III, Deceased;

RUDY ABAD, Individually as Spouse and as Personal

Representative of the Estate of MARIE ROSE ABAD,
Deceased;

CYNTHIA LYNN BARKWAY, Individually as Spouse,

and as Personal Representative of the Estate of
DAVID MICHAEL BARKWAY, Deceased;

THOMAS BOCCHINO, Individually as Sibling, and as

Personal Representative of the Estate of MICHAEL
BOCCHINO, Deceased;

IRENE BOEHM, Individually as Spouse and as Personal

Representative of the Estate of BRUCE BOEHM,
Deceased;

NANCY H. KIMBELL, Individually as Sibling and as

Personal Representative of the Estate of MARY
BOOTH, Deceased;

KRISTEN BREITWEISER, Individually as Spouse, and

as Personal Representative of the Estate of RONALD
BREITWEISER, Deceased;

ERICA BRENNAN, Individually as Spouse, and as

Personal Representative of the Estate of PETER
BRENNAN, Deceased;

108
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 20 of 31

KATHLEEN BRUNTON, Individually as Spouse, and as

Personal Representative of the Estate of VINCENT
BRUNTON, Deceased;

ERNST H. BUCK and JOSEPHINE BUCK, Individually

as Parents of GREGORY J. BUCK, Deceased;

KENNETH CHU, Individually as Parent and as Personal

Representative of the Estate of PAMELA CHU,
Deceased;

DEBORAH RAZZANO, Individually as Spouse and as

Personal Representative of the Estate of ANTHONY
COLADONATO, Deceased;

MELINDA COOPER, Individually as Spouse and

as Personal Representative of the Estate of JULIAN
COOPER, Deceased;

THERESA COVE, Individually as Spouse, and as

Personal Representative of the Estate of JAMES E.
COVE, Deceased;

JAMES CUDMORE, Individually as Parent and as

Personal Representative of the Estate of NEIL
CUDMORE, Deceased;

AMY WATERS, Individually, and as Personal

Representative of the Estate of SCOTT DAVIDSON,
Deceased;

LORRAINE DELAPENHA, Individually as Spouse, and

as Personal Representative of the Estate of DONALD A.
DELAPENHA, Deceased;

KATHRYN R. DENNIS, Individually as Spouse and as

Personal Representative of the Estate of THOMAS F.
DENNIS, Deceased;

IRENE DICKEY, Individually as Spouse and as Personal

Representative of the Estate of JOSEPH DICKEY,
Deceased;

ROSEMARY DILLARD, Individually as Spouse and as

109
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 21 of 31

Personal Representative of the Estate of EDDIE

DILLARD, Deceased;

LESLIE DIMMLING, Individually as Spouse and as

Personal Representative of the Estate of WILLIAM
DIMMLING, Deceased;

MARGUERITA DOMANICO, Individually as Spouse

and as Personal Representative of the Estate of JAMES
DOMANICO, Deceased;

MAUREEN S. DOMINGUEZ, Individually as Spouse

and as Personal Representative of the Estate of Carlos
Dominguez, Deceased;

CHRISTOPHER DOWLING, Individually as Parent and

as Personal Representative of the Estate of MARY
YOLANDA DOWLING, Deceased:

CYNTHIA M. DROZ, Individually as Spouse and as

Personal Representative of the Estate of CHARLES
DROZ, Deceased;

JACQUELINE EATON, Individually as Spouse and as

Personal Representative of the Estate of ROBERT
EATON, Deceased;

CATHERINE ANN FAUGHNAN, Individually as

Spouse as Personal Representative of the Estate of
CHRISTOPHER FAUGHNAN, Deceased;

MARY AND FRANK FETCHET, Individually as

Parents and as Personal Representatives of the Estate of
BRADLEY FETCHET, Deceased;

ERIN FINNEGAN, Individually as Spouse and as

Personal Representative of the Estate of MICHAEL
FINNEGAN, Deceased;

PATRICIA FITZSIMONS, Individually as Spouse and

as Personal Representative of the Estate of RICHARD
FITZSIMONS, Deceased;

CATHY GEYER, Individually as Spouse and as

Personal Representative of the Estate of JAMES G.
GEYER, Deceased;

110
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 22 of 31

PHYLLIS GILLY and JOSEPH GILLY, Individually as

Parents and as Personal Representatives of the Estate of
Laura Gilly, Deceased;

GERALD GOLKIN and JANET GOLKIN, Individually

as Parents and as Personal Representatives of the Estate
of ANDREW H. GOLKIN, Deceased;

SANDRA MUNRO, Individually as Sibling and as

Personal Representative of the Estate of ELVIRA
GRANITTO, Deceased;

RAYMOND HABIB, Individually as Spouse and as

Personal Representative of the Estate of BARBARA
HABIB, Deceased;

MARY JEAN HELLER, Individually as Spouse and as

Personal Representative of the Estate of H. JOSEPH
HELLER, Deceased;

TENNYSON HUIE, Individually as Father and as

Personal Representative of the Estate of Susan Huie,
Deceased;

SHERI ANN ISKENDERIAN, Individually as Spouse

and as Personal Representative of the Estate of ARAM
ISKENDERIAN, Deceased;

JENNIFER L. JARDIM, Individually as Spouse and as

Personal Representative of the Estate of MARK S.
JARDIM, Deceased;

CHRISTINE JEAN-PIERRE, Individually as Spouse and

as Personal Representative of the Estate of FRANCOIS
JEAN-PIERRE, Deceased;

ELIZABETH JORDAN, Individually as Spouse and as

Personal Representative of the Estate of ROBERT
JORDAN, Deceased;

GEOFFREY JUDGE, Individually a Spouse and as

Personal Representative of the Estate of ANN JUDGE,
Deceased;

111
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 23 of 31

DOHEE KANG, Individually as Spouse and as Personal

Representative of the Estate of JOON KOO KANG,
Deceased;

JANET KELLEY, Individually as Spouse and as

Personal Representative of the Estate of FREDERICK
KELLEY, Deceased;

JOANNE KELLY, Individually as Spouse and as

Personal Representative of the Estate of JAMES
KELLY, Deceased;

PAUL AND VIVIAN KOLPAK, Individually as Parents

and as Personal Representatives of the Estate of
VANESSA KOLPAK, Deceased;

ELIZABETH KOVALCIN, Individually as Spouse and

as Personal Representative of the Estate of DAVID P.
KOVALCIN, Deceased;

ANNA M. KREN, Individually and as Personal

Representative of the Estate of JOHN J. KREN,
Deceased;

DONNA CABALLERO, and WILLIAM M. LANG,

Individually as Siblings and as Personal Representatives
of the Estate of ROSEANN LANG, Deceased;

CAROLE LEAVEY, Individually as Spouse and as

Personal Representative of the Estate of JOSEPH
GERARD LEAVEY, Deceased;

JOSEPH J. REITANO, as Personal Representative of the

Estate of VINCENT LITTO, Deceased;

EILEEN LYNCH, Individually as Spouse and as

Personal Representative of the Estate of FARRELL
LYNCH, Deceased;

CHRISTINA LYNCH, Individually as Spouse and as

Personal Representative of the Estate of RICHARD D.
LYNCH, Deceased;

LORRAINE LYNCH, Individually as Spouse and as

Personal Representative of the Estate of SEAN LYNCH,
Deceased;

112
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 24 of 31

BRINLEY MALONEY, Individually as Spouse and as

Personal Representative of the Estate of EDWARD F.
MALONEY, III, Deceased;

MEGAN MANNING, Individually as Spouse and as

Personal Representative of the Estate of TERENCE
JOHN MANNING, Deceased;

NICHOLAS MAOUNIS, Individually as Parent and as

Personal Representative of the Estate of JAMES
MAOUNIS, Deceased;

SHEILA MARTELLO, Individually as Spouse and as

Personal Representative of the Estate of JAMES
MARTELLO, Deceased;

TARYN McHALE, Individually as Spouse and as

Personal Representative of the Estate of THOMAS
McHALE, Deceased;

ELIZABETH McLAUGHLIN, Individually as Spouse,

and as Personal Representative of the Estate of ROBERT
McLAUGHLIN, Deceased;

ELIZABETH McNALLY, Individually as Spouse and as

Personal Representative of the Estate of EDMUND
MCNALLY, Deceased;

JOSEPH RICHARD MICKLEY, Individually as Spouse

and as Personal Representative of the Estate of
PATRICIA E. MICKLEY, Deceased;

ARJAN MIRPURJ, Individually as Parent and as

Personal Representative of the Estate of RAJESH
MIRPURI, Deceased;

MARK MORABITO, Individually as Spouse and as

Personal Representative of the Estate of LAURA LEE
MORABITO, Deceased;

CATHERINE MORAN, Individually as Parent and as

Personal Representative of the Estate of KATHLEEN
MORAN, Deceased;

113
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 25 of 31

KIMBERLY A. MARTONE, Individually as Spouse and

as Personal Representative of the Estate of
CHRISTOPHER M. MORRISON, Deceased;

MADELINE LEW MOY, Individually as Spouse and as

Personal Representative of the Estate of TEDDINGTON
H. MOY, Deceased;

PATRICK MULLAN, Individually as Parent and as

Personal Representative of the Estate of MICHAEL D.
MULLAN, Deceased;

AMY NACKE, Individually, and as Personal

Representative of the Estate of LOUIS J. NACKE,
Deceased;

HEIDI NAPLES, Individually as Spouse and as Personal

Representative of the Estate of FRANK J. NAPLES,
Deceased;

AMY NEWTON, Individually as Spouse and as Personal

Representative of the Estate of CHRISTOPHER
NEWTON, Deceased;

SUSAN NEWTON-CARTER, Individually as Spouse,

and as Personal Representative of the Estate of
CHRISTOPHER NEWTON-CARTER, Deceased;

LISA O'BRIEN, Individually as Spouse, and as Personal

Representative of the Estate of TIMOTHY O'BRIEN,
Deceased;

MARY DUFF-ORTALE, Individually as Spouse and as

Personal Representative of the Estate of PETER KEITH
ORTALE, Deceased;

DANIEL ORTH, MICHELLE ORTH and ELIZABETH

ORTH, Individually as Children and as Personal
Representatives of the Estate of JANE MARIE ORTH,
Deceased;

WANDA GARCIA-ORTIZ, Individually as Spouse and

as Personal Representative of the Estate of EMILIO
ORTIZ, Deceased;

ALEXANDRA M. ORTIZ, Individually and as Personal

114
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 26 of 31

Representative of the Estate of SONIA M. ORTIZ,

Deceased;

CAROLYN PANATIER, Individually as Spouse, and as

Personal Representative of the Estate of CHRISTOPHER
M. PANATIER, Deceased;

NAVILA PATTERSON, Individually as Spouse, and as

Personal Representative of the Estate of BERNARD E.
PATTERSON, Deceased;

MEGAN P. PELINO, Individually as Spouse and as

Personal Representative of the Estate of TODD
DOUGLAS PELINO, Deceased;

MICHAEL QUINN, Individually as Parent and as

Personal Representative of the Estate of JAMES
QUINN, Deceased;

NANCY HOLZHAUER, Individually as Sibling and as

Personal Representative of the Estate of GERARD P.
RAUZI, Deceased;

JAMES J. RICHES, Individually as Parent, and as

Personal Representative of the Estate of JAMES C.
RICHES, Deceased;

BARBARA ROPITEAU-GALLOWAY, Individually as

Parent and as Personal Representative of the Estate of
ERIC THOMAS ROPITEAU, Deceased;

BRENDAN RYAN, Individually as Spouse and as

Personal Representative of the Estate of KRISTIN
IRVINE RYAN, Deceased;

SALLY CALVIN, Individually as Spouse and as

Personal Representative of the Estate of FRANK
SALVATERRA, Deceased;

EUGENIA BOGADO, Individually as Parent and as

Personal Representative of the Estate of CARLOS A.
SAMANIEGO, Deceased;

LYNNE SAN PHILLIP, Individually as Spouse, and as

Personal Representative of the Estate of MICHAEL V.
SAN PHILLIP, Deceased;

115
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 27 of 31

ABRAHAM SCOTT, Individually as Spouse and as

Personal Representative of the Estate of JANICE M.
SCOTT, Deceased;

DARA SEAMAN, Individually as Spouse and as

Personal Representative of the Estate of MICHAEL
SEAMAN, Deceased;

MARIA SILVERSTEIN, Individually as Spouse and as

Personal Representative of the Estate of CRAIG
SILVERSTEIN, Deceased;

LAURIE SIMOWITZ, Individually as Spouse and as

Personal Representative of the Estate of BARRY
SIMOWITZ, Deceased;

JAMES P. SLATTERY, Individually as Parent and as

Personal Representative of the Estate of CHRISTOPHER
PAUL SLATTERY, Deceased;

SUSAN M. SLIWAK, Individually as Spouse and as

Personal Representative of the Estate of ROBERT F.
SLIWAK, Deceased;

YONGJIN L. SONG and HYUNGSHIN K. SONG,

Individually as Parents and as Personal Representatives
of the Estate of Daniel W. Song a/k/a Won-Hyeong
Song, Deceased;

CHRISTINE SPENCER, Individually as Spouse and as

Personal Representative of the Estate of ROBERT A.
SPENCER, Deceased;

JACQUELINE GALLERON, Individually and as

Personal Representative of the Estate of SELINA
SUTTER, Deceased;

LORRAINE SZOCIK, Individually as Spouse and as

Personal Representative of the Estate of KEVIN T.
SZOCIK, Deceased;

MARC TADDONIO, Individually as Sibling and as

Personal Representative of the Estate of MICHAEL
TADDONIO, Deceased;

116
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 28 of 31

JANE TERRENZI, Individually as Spouse and as

Personal Representative of the Estate of BRIAN
TERRENZI, Deceased;

BASIL G. THORPE and VALDA M. BINNS,

Individually, and as Co-Administrators of the Estate of
NICHOLA ANGELA THORPE, Deceased;

ANNE TODISCO, Individually as Spouse and as

Personal Representative of the Estate of RICHARD
TODISCO, Deceased;

TANJA TOMASEVIC, Individually as Spouse, and as

Personal Representative of the Estate of VLADIMIR
TOMASEVIC, Deceased;

DORRY GROH-TOMPSETT, Individually as Spouse

and as Personal Representative of the Estate of
STEPHEN TOMPSETT, Deceased;

MARY ELIZABETH TUCKER, Individually as Spouse

and as Personal Representative of the Estate of
MICHAEL P. TUCKER, Deceased;

JENNIFER VAUK, Individually as Spouse and as

Personal Representative of the Estate of RONALD
VAUK, Deceased;

DENNIS VIANNA and MARILYNDA VIANNA,

Individually as Parents and as Personal Representatives
of the Estate of MATHEW G. VIANNA, Deceased;

NAYDA VOSKERIJIAN, Individually as Spouse and as

Personal Representative of the Estate of GARO
VOSKERIJIAN, Deceased;

CAROL WALDIE, Individually as Spouse and as

Personal Representative of the Estate of KENNETH
WALDIE, Deceased;

ALLISON WALLICE, Individually as Spouse and as

Personal Representative of the Estate of JOHN
WALLICE, JR., Deceased;

MICHELLE GARTNER, as Personal Representative of

the Estate of DINAH WEBSTER, Deceased;

117
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 29 of 31

MARCIA WEISS, Individually as Spouse and as

Personal Representative of the Estate of DAVID T.
WEISS, Deceased;

PATRICK WELSH, Individually as Spouse and as

Personal Representative of the Estate of DEBORAH
ANNE WELSH, Deceased;

PAMELA WORKS, Individually as Spouse and as

Personal Representative of the Estate of JOHN
BENTLEY WORKS, Deceased;

PATRICIA WREN, Individually as Spouse and as

Personal Representative of the Estate of WILLIAM
WREN, Deceased;

KATHY A. CORDERO, Individually;

PATRICIA CUBAS-BIELFELD, Individually;

VIRGINIA DICHIARA, Individually;

ROBERT EICHELE and CARMELA EICHELE,

Individually;

KEVIN FARRELL, Individually; CHONG P.

FARRELL, Individually;

MICHAEL HENRY and REBECCA HENRY,

Individually;

JAMES B. LEACH and CARRIE LEACH, Individually;

ERIC LEVINE, Individually;

JAMES McCAFFREY and AGNES McCAFFREY,

Individually;

EDWARD NICHOLLS, and STACIE NICHOLLS,

Individually;

VALENCIAL. PARKER, Individually;

KEVIN WARD, Individually;

118
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 30 of 31

LING N. YOUNG and DONALD M. YOUNG,

Individually;

VIRGINIA BAUER, Individually, as surviving Spouse,

and Executrix of the Estate of W. DAVID BAUER, II, Baumeister & Samuels P.C.
Deceased;
W. DAVID BAUER, III, as surviving Child of W.
DAVID BAUER, II;
STEPHEN BAUER, as surviving Child of W. DAVID
BAUER, II;
JACQUELINE BAUER, as surviving Child of W.
DAVID BAUER, II;
DOROTHY BAUER, Individually, as surviving Mother,
and Executrix of the Estate of WALTER D. BAUER,
Deceased, surviving Father of W. DAVID BAUER, II;
GRETCHEN ABERNATHY, as surviving Sibling of W.
DAVID BAUER, II;
HEIDI BAUER-POLLARD, as surviving Sibling of W.
DAVID BAUER, II;
ROBERT G. BAUER, as surviving Sibling of W. DAVID
BAUER, II;

LISA BEAMER, Individually, as surviving Spouse, and

Executrix of the Estate of TODD M. BEAMER,
Deceased;
LISA BEAMER, as Mother and Natural Guardian of
A.T.B., a minor, as surviving Child of TODD M.
BEAMER;
LISA BEAMER, as Mother and Natural Guardian of
M.K.B., a minor, as surviving Child of TODD M.
BEAMER;
DAVID P. BEAMER, as surviving Child of TODD M.
BEAMER;
DAVID BEAMER, as surviving Father of TODD M.
BEAMER;
MARGARET BEAMER, as surviving Mother of TODD
M. BEAMER;
MELISSA WILSON, as surviving Sibling of TODD M.
BEAMER;
MICHELE BEAMER-SORENSEN, as surviving Sibling
of TODD M. BEAMER;

119
 Case 1:17-cv-02003 Document 1-3 Filed 03/20/17 Page 31 of 31

SUSAN BEATINI, Individually, as surviving Spouse, and

Administratrix of the Estate of PAUL F. BEATINI,
Deceased;
JULIA BEATINI, as surviving Child of PAUL F.
BEATINI;
DARIA BEATINI, as surviving Child of PAUL F.
BEATINI;
MARK BEATINI, Individually, and Executor of the
Estate of MICHAEL C. BEATINI, Deceased, as surviving
Father of PAUL F. BEATINI;
MARK BEATINI, Individually, and Executor
of the Estate of DORIS BEATINI, Deceased, as surviving
Mother of PAUL F. BEATINI;
THOMAS BEATINI and NANDA BEATINI,
Individually, and Co-Administrators of the Estate of
MICHAEL L. BEATINI, surviving Sibling of PAUL F.
BEATINI;
MARK BEATINI, as surviving Sibling of PAUL F.
BEATINI;
THOMAS BEATINI, as surviving Sibling of PAUL F.
BEATINI;
NANDA BEATINI, as surviving Sibling of PAUL F.
BEATINI;

PANDORA BHARVANEY, Individually, as surviving

Spouse, and Administratrix of the Estate of ANIL T.
BHARVANEY, Deceased;

CATHYANN BONNETT, Individually, as surviving

Spouse, and Administratrix of the Estate of COLIN
BONNETT, Deceased;
KODY BONNETT, as surviving Child of COLIN
BONNETT;
JULIA V. BONNETT, as surviving Mother of COLIN
BONNETT;
AUBREY A. PARRIS, as surviving Father of COLIN
BONNETT;
HEATHER BONNETT, as surviving Sibling of COLIN
BONNETT;

DEBORAH BOWDEN HART, Individually, as surviving

Spouse, and Executrix of the Estate of THOMAS
BOWDEN, Deceased;
DEBORAH BOWDEN HART, as Mother and Natural
Guardian of A.V.B.H., a minor, as surviving Child of
THOMAS BOWDEN;

120
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 1 of 28

DEBORAH BOWDEN HART, as Mother and Natural

Guardian of S.J.B.H., a minor, as surviving Child of
THOMAS BOWDEN;
JAMES BOWDEN, as surviving Sibling of THOMAS
BOWDEN;

JENNIFER HENRY, Individually, as surviving Spouse,

and Administratrix of the Estate of SHAWN E.
BOWMAN, JR., Deceased;
JENNIFER HENRY, as Mother and Natural Guardian of
L.E.B.H., a minor, as surviving Child of SHAWN E.
BOWMAN, JR.;
JENNIFER HENRY, as Mother and Natural Guardian of
J.S.B.H., a minor, as surviving Child of SHAWN E.
BOWMAN, JR.;
SHAWN E. BOWMAN, SR., as surviving Father of
SHAWN E. BOWMAN, JR.;
CAROL A. BOWMAN, as surviving Mother of SHAWN
E. BOWMAN, JR.;
JAMES E. BOWMAN, as surviving Sibling of SHAWN
E. BOWMAN, JR.;

JENNIFER BRENNAN WATERHOUSE, Individually,

as surviving Spouse, and Administratrix of the Estate of
THOMAS BRENNAN, Deceased;
JENNIFER BRENNAN WATERHOUSE, as Mother and
Natural Guardian of T.M.B., a minor, as surviving Child
of THOMAS BRENNAN;
JENNIFER BRENNAN WATERHOUSE, as Mother and
Natural Guardian of C.A.B., a minor, as surviving Child
of THOMAS BRENNAN;
JOHN V. BRENNAN, as surviving Father of THOMAS
BRENNAN;
ANITA BRENNAN, as surviving Mother of THOMAS
BRENNAN;
JOHN 0. BRENNAN, as surviving Sibling of THOMAS
BRENNAN;
PAUL BRENNAN, as surviving Sibling of THOMAS
BRENNAN;
MARY BETH MAGEE, as surviving Sibling of
THOMAS BRENNAN;
MICHAEL BRENNAN, as surviving Sibling of
THOMAS BRENNAN;

121
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 2 of 28

LAURA BUSTILLO, Individually, as surviving Spouse,

and Administratrix of the Estate of MILTON BUSTILLO,
Deceased;
LAURA BUSTILLO, as Mother and Natural Guardian of
A.B., a minor, as surviving Child of MILTON
BUSTILLO;
DAYNA SPORDONE, as surviving step-daughter of
MILTON BUSTILLO;
MARGARITA BETTER, as surviving Mother of
MILTON BUSTILLO;
DISSA BUSTILLO, Individually, and Personal
Representative of the Estate of GILBERTO BUSTILLO,
SR., as surviving Father of MILTON BUSTILLO; DISSA
BUSTILLO, as surviving Sibling of MILTON
BUSTILLO;
HENRY BUSTILLO, as surviving Sibling of MILTON
BUSTILLO;
MIRNA BUSTILLO, as surviving Sibling of MILTON
BUSTILLO;
GILBERTO BUSTILLO, JR., as surviving Sibling of
MILTON BUSTILLO;

ELIZABETH CANDELA, Individually, as surviving

Spouse, and Administratrix of the Estate of JOHN
ANTHONY CANDELA, Deceased;
JULIETTE CANDELA, as surviving Child of JOHN
ANTHONY CANDELA;
JOHN ARTHUR CANDELA, as surviving Child of
JOHN ANTHONY CANDELA;
JOSEPH G. CANDELA, Individually, and Executor of
the Estate of JOHN C. CANDELA, Deceased, as
surviving Father of JOHN ANTHONY CANDELA;
JOSEPH G. CANDELA, Individually, and Executor of
the Estate of PHYLLIS CANDELA, Deceased, as
surviving Mother of JOHN ANTHONY CANDELA;
JOSEPH G. CANDELA, as surviving Sibling of JOHN
ANTHONY CANDELA;
VALERIE SPELLER, as surviving Sibling of JOHN
ANTHONY CANDELA;
KAREN ANN MEE, as surviving Sibling of JOHN
ANTHONY CANDELA;
JOAN BRADY, as surviving Sibling of JOHN
ANTHONY CANDELA;

122
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 3 of 28

MARIE CARLINO, Individually, as surviving Spouse,

and Executrix of the Estate of EDWARD CARLINO,
Deceased;
LISA TORRES, as surviving Child of EDWARD
CARLINO;

TERESEA CUNNINGHAM, Individually, as surviving

Spouse, and Administratrix of the Estate of MICHAEL J.
CUNNINGHAM, Deceased;
TERESA CUNNINGHAM, as Mother and Natural
Guardian of W.C., a minor, as surviving Child of
MICHAEL J. CUNNINGHAM;
PAUL CUNNINGHAM, as surviving Sibling of
MICHAEL J. CUNNINGHAM;
JULIEANNE CUNNIINGHAM, as surviving Sibling of
MICHAEL J. CUNNINGHAM;
BERNADETTE T. HAYES, as surviving Sibling of
MICHAEL J. CUNNINGHAM;
SEAN CUNNINGHAM, as surviving Sibling of
MICHAEL J. CUNNINGHAM;
ANDREW CUNNINGHAM, as surviving Sibling of
MICHAEL J. CUNNINGHAM;

KAREN D'AMBROSI, Individually, as surviving

Spouse, and Executrix of the Estate of JACK L.
D'AMBROSI, JR., Deceased;
JACQUELINE D'AMBROSI, as surviving Child of
JACK L. D'AMBROSI;
EMILY D'AMBROSI, as surviving Child of JACK L.
D'AMBROSI, JR.;
TINA D'AMBROSI, Executrix of the Estate of JACK L.
D'AMBROSI, SR., Deceased, as surviving Father of
JACK L. D'AMBROSI, JR.;
DENISE BONOLI, as surviving Sibling of JACK L.
D'AMBROSI, JR.;
DEAN J. D'AMBROSI, as surviving Sibling of JACK L.
D'AMBROSI, JR.;

MARY DANAHY, Individually, as surviving Spouse, and

Executrix of the Estate of PATRICK W. DANAHY,
Deceased;
MARY DANAHY, as Mother and Natural Guardian of
K.T.D., a minor, as surviving Child of PATRICK W.
DANAHY;

123
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 4 of 28

MARY DANAHY, as Mother and Natural Guardian of

G.A.D, a minor, as surviving Child of PATRICK W.
DANAHY;
ALISON M. DANAHY, as surviving Child of PATRICK
W. DANAHY;

JOHN DIMEGLIO, Individually, and Administrator of

the Estate of DAVID DIMEGLIO, Deceased;
JOHN DIMEGLIO, as surviving Father of DAVID
DIMEGLIO;
PATTI S. DIMEGLIO, as surviving Mother of DAVID
DIMEGLIO;
DANIEL DIMEGLIO, as surviving Sibling of DAVID
DIMEGLIO;

SANDRA FELT, Individually, as surviving Spouse, and

Executrix of the Estate of EDWARD P. FELT, Deceased;
KATHRYN FELT, as surviving Child of EDWARD P.
FELT;
ADRIENNE FELT, as surviving Child of EDWARD P.
FELT;
SHIRELY A. FELT, as surviving Mother of EDWARD P.
FELT;
LAWRENCE FELT, as surviving Sibling of EDWARD P.
FELT;
GORDON FELT, as surviving Sibling of EDWARD P.
FELT;

NANCY FOSTER, Individually, as surviving Spouse, and

Administratrix of the Estate of NOEL J. FOSTER,
Deceased;
NANCY FOSTER, as mother and Natural Guardian of
Megan Foster, an incapacitated adult, as surviving Child
of NOEL J. FOSTER;
NICOLE FOSTER, as surviving Child of NOEL J.
FOSTER;

BARBARA GALLUCCI, Individually, as surviving

Spouse, and Administratrix of the Estate of VINCENZO
GALLUCCI, Deceased;
ALYSSA GALLUCCI, as surviving Child of VINCENZO
GALLUCCI;
ANGELA GALLUCCI, as surviving Mother of
VINCENZO GALLUCCI;
JOSEPH GALLUCCI, as surviving Father of VINCENZO
GALLUCCI;

124
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 5 of 28

FILOMENA GRACE SANTORELLI, as surviving

Sibling of VINCENZO GALLUCCI;

MICHAEL J. GIORDANO, Individually, and

Administrator of the Estate of DONNA GIORDANO,
Deceased;
MICHAEL J. GIORDANO, as surviving Child of
DONNA GIORDANO; DOMENICK D'AMBOLA,
Individually, and Personal Representative of the Estate of
JESSAMINE D'AMBOLA, Deceased, as surviving
Mother of DONNA GIORDANO;
DOMENICK D'AMBOLA, as surviving Father of
DONNA GIORDANO;
ELAINE BARRETT, as surviving Sibling of DONNA
GIORDANO;

LYZBETH GLICK BEST, Individually, as surviving

Spouse, and Administratrix of the Estate of JEREMY
GLICK, Deceased;
LYZBETH GLICK BEST, as Mother and Natural
Guardian of E.G., a minor, as surviving Child of JEREMY
GLICK;
LLOYD GLICK, as surviving Father of JEREMY
GLICK;
JOAN GLICK, as surviving Mother of JEREMY GLICK;
JENNIFER GLICK, as surviving Sibling of JEREMY
GLICK;
JED GLICK, as surviving Sibling of JEREMY GLICK;
JARED GLICK, as surviving Sibling of JEREMY
GLICK;
JOANNA GLICK, as surviving Sibling of JEREMY
GLICK;
JONAH GLICK, as surviving Sibling of JEREMY
GLICK;

JILL GOLDSTEIN, Individually, as surviving Spouse,

and Administratrix of the Estate of STEVEN
GOLDSTEIN, Deceased;
JILL GOLDSTEIN, as Mother and Natural Guardian of
H.G., a minor, as surviving Child of STEVEN
GOLDSTEIN;
HANNA GOLDSTEIN, as surviving Child of STEVEN
GOLDSTEIN;

125
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 6 of 28

ELSA G. STRONG, Individually, and Executrix of the

Estate of LINDA K. GRONLUND, Deceased;
DORIS GRONLUND, as surviving Mother of LINDA K.
GRONLUND;
BARBARA GRONLUND, Personal Representative of the
Estate of ARTHUR G. GRONLUND, Deceased, as
surviving Father of LINDA K. GRONLUND;
ELSA G. STRONG, as surviving Sibling of LINDA K.
GRONLUND;

EILEEN HANNAFORD, Individually, as surviving

Spouse, and Administratrix of the Estate of KEVIN J.
HANNAFORD, Deceased;
EILEEN HANNAFORD, as Mother and Natural Guardian
of K.J.H., a minor, as surviving Child of KEVIN J.
HANNAFORD;
EILEEN HANNAFORD, as mother and Natural Guardian
of P.H., a minor, as surviving Child of KEVIN J.
HANNAFORD;

BARBARA RACHKO, Individually, as surviving

Spouse, and Administratrix of the Estate of BRYAN
JACK, Deceased;
JAMES T. JACK, Individually, and Personal
Representative of the Estate of JAMES H. JACK,
Deceased, as surviving Father of BRYAN JACK;
JAMES T. JACK, Individually, and Executor of the Estate
of HELEN M. JACK, Deceased, as surviving Mother of
BRYAN JACK;
JAMES T. JACK, as surviving Sibling of BRYAN JACK;

THOMAS S. JOHNSON, Individually, and Administrator

of the Estate of SCOTT JOHNSON, Deceased;
THOMAS S. JOHNSON, as surviving Father of SCOTT
JOHNSON;
MARGARET ANN JOHNSON, as surviving Mother of
SCOTT JOHNSON;
MARGARET WAGER, Executrix of the Estate of
THOMAS P. JOHNSON, Deceased, as surviving Sibling
of SCOTT JOHNSON;
MARGARET WAGER, as surviving Sibling of SCOTT
JOHNSON;

MICHELE JONES FERRELL, Individually, as surviving

Spouse, and Executrix of the Estate of DONALD T.
JONES, II, Deceased;

126
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 7 of 28

MICHELE JONES FERRELL, as Mother and Natural

Guardian of D.T.J., a minor, as surviving Child of
DONALD T. JONES, II;
TAYLOR N. JONES, as surviving Child of DONALD T.
JONES, II;
JUDITH JONES, Individually, and Executrix of the Estate
of DONALD T. JONES, SR., as surviving Father of
DONALD T. JONES, II;
JUDITH JONES, as surviving Mother of DONALD T.
JONES, II;
WILLIAM B. JONES, as surviving Sibling of DONALD
T. JONES, II;

LORI KANE, Individually, as surviving Spouse, and

Administratrix of the Estate of HOWARD KANE,
Deceased;
JASON B. KANE, as surviving Child of HOWARD
KANE; ROCHELLE KANE, as surviving Mother of
HOWARD KANE;
ADAM KANE, Individually, and Executor of the Estate
of BRUCE KANE, Deceased, as surviving Father of
HOWARD KANE;
ADAM KANE, as surviving Sibling of HOWARD
KANE;
HOLLY ANN TANZ, as surviving Sibling of HOWARD
KANE;

ROSE KELLER D'ALESSANDRO, Individually, as

surviving Spouse, and Administratrix of the Estate of
JOSEPH J. KELLER, Deceased;
ROSE KELLER D'ALESSANDRO, as Mother and
Natural Guardian of S.K., a minor, as surviving Child of
JOSEPH J. KELLER;
JOSEPH DANIEL KELLER, as surviving Child of
JOSEPH J. KELLER;
JUNE SASLOW, as surviving Mother of JOSEPH J.
KELLER;
JENNIFER LUTZ, as surviving Sibling of JOSEPH J.
KELLER;

H. MICHAEL KEDEN, Executor of the Estate of ADAM

J. LEWIS, Deceased;
PATRICIA D. LEWIS, as surviving Spouse of ADAM J.
LEWIS;

127
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 8 of 28

PATRICIA D. LEWIS, as mother and Natural Guardian

of S.L., a minor, as surviving Child of ADAM J. LEWIS;
REILLY LEWIS, as surviving Child of ADAM J. LEWIS;
ARTHUR LEWIS, as surviving Child of ADAM J.
LEWIS;
CAROLINE LEWIS, as surviving Child of ADAM J.
LEWIS;
GERALDING LEWIS, as surviving Mother of ADAM J.
LEWIS;
PAMELA PASSERETTA, as surviving Sibling of ADAM
J. LEWIS;
KATHRYN HEBERT, as surviving Sibling of ADAM J.
LEWIS;

CAMERON F. MACRAE, III, Individually, and

Administrator of the Estate of CATHERINE F.
MACRAE, Deceased;
CAMERON F. MACRAE, III, as surviving Father of
CATHERINE F. MACRAE;
ANN B. MACRAE, as surviving Mother of CATHERINE
F. MACRAE;
ANN C. MACRAE, as surviving Sibling of CATHERINE
F. MACRAE;

AUDREY MAGNUSON, Individually, as surviving

Spouse, and Executrix of the Estate of RONALD E.
MAGNUSON, Deceased;
JEFFREY A. MAGNUSON, as surviving Child of
RONALD E. MAGNUSON;
SHERYL A. MAGNUSON, as surviving Child of
RONALD E. MAGNUSON;
KNUT MAGNUSON, as surviving Sibling of RONALD
E. MAGNUSON;

KATHERINE MAHER, Individually, as surviving

Spouse, and Executrix of the Estate DANIEL L. MAHER,
Deceased;
DANIEL R. MAHER, as surviving Child of DANIEL L.
MAHER;
JOSEPH MAHER, as surviving Child of DANIEL L.
MAHER;
JAMES MAHER, Individually, and Executor of the Estate
of JEANNE MAHER, Deceased, as surviving Mother of
DANIEL L. MAHER;
JAMES MAHER, as surviving Sibling of DANIEL L.
MAHER;

128
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 9 of 28

JEANNE BRANDOFINO, as surviving Sibling of

DANIEL L. MAHER;
CHRISTINA MAHER, Executrix of the Estate of
RAYMOND MAHER, JR., Deceased, as surviving
Sibling of DANIEL L. MAHER;

MARGARET MEYER, Individually, as surviving

Spouse, and Executrix of the Estate of DAVID R.
MEYER, Deceased;
HEIDI MENNONA, as surviving Child of DAVID R.
MEYER;
HEATHER VULPONE, as surviving Child of DAVID R.
MEYER;
DAWN MEYER-FUCHS, as surviving Child of DAVID
R. MEYER;
KRISTINE MEYER, as surviving Sibling of DAVID R.
MEYER;
CHARLES MEYER, as surviving Sibling of DAVID R.
MEYER;

ELLEN ROBB and FRANK MONTANARO,

Individually, and Co-Administrators of the Estate of
KRISTEN MONTANARO, Deceased;
ELLEN ROBB, as surviving Mother of KRISTEN
MONTANARO;
FRANK MONTANARO, as surviving Father of
KRISTEN MONTANARO;
JAMIE MONTANARO, as surviving Sibling of
KRISTEN MONTANARO;
KAREN MONTANARO, as surviving Sibling of
KRISTEN MONTANARO;

BETH K. MURPHY, Individually, as surviving Spouse,

and Administratrix of the Estate of KEVIN J. MURPHY,
Deceased;
CONNOR J. MURPHY, as surviving Child of KEVIN J.
MURPHY;
CAITLYN B. MURPHY, as surviving Child of KEVIN J.
MURPHY;
SALLY F. RYAN, Individually, and Personal
Representative of the Estate of TIMOTHY F. MURPHY,
JR., Deceased, as surviving Father of KEVIN J.
MURPHY;
SALLY F. RYAN, as surviving Mother of KEVIN J.
MURPHY;

129
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 10 of 28

MICHAEL MURPHY, as surviving Sibling of KEVIN J.

MURPHY;
TIMOTHY P. MURPHY, as surviving Sibling of KEVIN
J. MURPHY;
JOHN F. MURPHY, as surviving Sibling of KEVIN J.
MURPHY;
MARY BETH DOUGHERTY, as surviving Sibling of
KEVIN J. MURPHY;

ARLENE ORSINI, Individually, as surviving Spouse, and

Executrix of the Estate of RONALD ORSINI, Deceased;
DANIELLE ORSINI PANDOLFI, as surviving Child of
RONALD ORSINI;
ROBERT ORSINI, as surviving Sibling of RONALD
ORSINI;
BARBARA STANG, as surviving Sibling of RONALD
ORSINI;

JOAN PARKER, Individually, as surviving Spouse, and

Administratrix of the Estate of PHILIP LACEY
PARKER, Deceased;
STEPHANIE PARKER, as surviving Child of PHILIP
LACEY PARKER;

JENNIFER PRICE-SALKEVER, Individually, and

Administratrix of the Estate of JEAN H. PETERSON,
Deceased;
JENNIFER PRICE-SALKEVER, as surviving Child of
JEAN H. PETERSON;
CATHERINE AUSTIN STOVER, as surviving Child of
JEAN H. PETERSON;
GRACE PRICE SHERWOOD, as surviving Child of
JEAN H. PETERSON;
RICHARD HOADLEY, Individually, and Executor of the
Estate of WALTER E. HOADLEY, Deceased, as
surviving Father of JEAN H. PETERSON;
RICHARD HOADLEY, Individually, and Executor of the
Estate of HELEN M. HOADLEY, Deceased, as surviving
Mother of JEAN H. PETERSON;
RICHARD HOADLEY, as surviving Sibling of JEAN H.
PETERSON;

MARGARET ECKERT, Personal Representative of the

Estate of SEAN ROONEY, Deceased;

130
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 11 of 28

MARGARET ECKERT, Individually, and Executrix of

the Estate of BEVERLY ECKERT, Deceased, as
surviving Spouse of SEAN ROONEY;
CYNTHIA BLEST, Individually, and Executrix of the
Estate of ROSEMARY ROONEY, Deceased, as surviving
Mother of SEAN ROONEY;
CYNTHIA BLEST, as surviving Sibling of SEAN
ROONEY;
MAURA ROONEY, as surviving Sibling of SEAN
ROONEY;
SHEILA ROONEY, as surviving Sibling of SEAN
ROONEY;
BRENDAN ROONEY, as surviving Sibling of SEAN
ROONEY;
BRIAN ROONEY, as surviving Sibling of SEAN
ROONEY;

PATRICIA RYAN, Individually, as surviving Spouse,

and Executrix of the Estate of JOHN J. RYAN, Deceased;
LAURA RYAN, as surviving Child of JOHN J. RYAN;
KRISTEN RYAN, as surviving Child of JOHN J. RYAN;
COLIN RYAN, as surviving Child of JOHN J. RYAN;

JOHN SANDERS, Individually, and Administrator of the

Estate of STACEY SANDERS, Deceased;
JOHN SANDERS, as surviving Father of STACEY
SANDERS;
MARTHA SANDERS, as surviving Mother of STACEY
SANDERS;
LAURA SANDERS WYATT, as surviving Sibling of
STACEY SANDERS;

TOMOKO T. SCHLAG, Individually, as surviving

Spouse, and Executrix of the Estate of STEVEN F.
SCHLAG, Deceased;
DAKOTA I. SCHLAG, as surviving Child of STEVEN F.
SCHLAG;
GARRETT M. SCHLAG, as surviving Child of STEVEN
F. SCHLAG;
SIERRA A. SCHLAG, as surviving Child of STEVEN F.
SCHLAG;
DONALD SCHLAG, as surviving Father of STEVEN F.
SCHLAG;
PATRICIA SCHLAG, as surviving Mother of STEVEN
F. SCHLAG;

131
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 12 of 28

JEAN NEBBIA, as surviving Sibling of STEVEN F.

SCHLAG;
ELLEN HUGHES, as surviving Sibling of STEVEN F.
SCHLAG;

SUZANNE SISOLAK PENAVIC, Individually, as

surviving Spouse, and Administratrix of the Estate of
JOSEPH M. SISOLAK, Deceased;
ELLEN SISOLAK, Individually, and Executrix of the
Estate of PAUL SISOLAK, Deceased, as surviving Father
of JOSEPH M. SISOLAK;
ANNA J. POWELL, as surviving Mother of JOSEPH M.
SISOLAK;
TERESA RELLER, as surviving Sibling of JOSEPH M.
SISOLAK;
YVONNE SISOLAK, Individually, and Executrix of the
Estate of THOMAS P. SISOLAK, Deceased, as surviving
Sibling of JOSEPH M. SISOLAK;

MARY SMITH, Individually, as surviving Spouse, and

Administratrix of the Estate of DANIEL SMITH,
Deceased;
ELIZABETH SMITH, as surviving Child of DANIEL
SMITH;
MICHAEL SMITH, as surviving Child of DANIEL
SMITH;
MCCARTHY SMITH, as surviving Sibling of Daniel
Smith, Deceased, SEAN PATRICK SMITH, as surviving
Sibling of DANIEL SMITH;
SUSAN HICKS, as surviving Sibling of DANIEL
SMITH;

MICHELE TANNER, Individually, as surviving Spouse,

and Executrix of the Estate of MICHAEL TANNER,
Deceased;
SASHA TANNER, as surviving Child of MICHAEL
TANNER; GIANNA TANNER, as surviving Child of
MICHAEL TANNER;
RENEE ABBATE, Individually, and Executrix of the
Estate of MARY TANNER, Deceased, as surviving
Mother of MICHAEL TANNER;
RENEE ABBATE, as surviving Sibling of MICHAEL
TANNER;
KENNETH C. TANNER, as surviving Sibling of
MICHAEL TANNER;

132
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 13 of 28

MARIA MARASCIULO, as surviving Sibling of

MICHAEL TANNER;
NICOLE TANNER-D'AMBROSIO, as surviving Sibling
of MICHAEL TANNER;

JENNIFER TARANTINO, Individually, as surviving

Spouse, and Executrix of the Estate of KENNETH
JOSEPH TARANTINO, Deceased;
JENNIFER TARANTINO, as Mother and Natural
Guardian of J.J.T., a minor, as surviving Child of
KENNETH JOSEPH TARANTINO;
KENNETH JAMES TARANTINO, as surviving Child of
KENNETH JOSEPH TARANTINO;

AMY C. VASEL, Individually, as surviving Spouse, and

Administratrix of the Estate of SCOTT VASEL,
Deceased;
AMY C. VASEL, as Mother and Natural Guardian of
M.J.V., a minor, as surviving Child of SCOTT VASEL;
RYAN A. VASEL, as surviving Child of SCOTT
VASEL;
JANYNE V. DEMBICKI, Individually, and Executrix of
the Estate of CHARLES VASEL, Deceased, as surviving
Father of SCOTT VASEL;
JANYNE V. DEMBICKI, Individually, and Executrix of
the Estate of MYNDA VASEL, Deceased, as surviving
Mother of SCOTT VASEL;
JANYNE V. DEMBICIKI, as surviving Sibling of
SCOTT VASEL;

KATHLEEN M. WISNIEWSKI, Individually, as

surviving Spouse, and Administratrix of the Estate of
ALAN L. WISNIEWSKI, Deceased;
JESSICA M. WISNIEWSKI, as surviving Child of ALAN
L. WISNIEWSKI;
ERICA C. WISNIEWSKI, as surviving Child of ALAN
L. WISNIEWSKI;
MATTHEW P. WISNIEWSKI, as surviving Child of
ALAN L. WISNIEWSKI;

CHIEMI YORK, Individually, as surviving Spouse, and

Administratrix of the Estate of KEVIN P. YORK,
Deceased;
CHIEMI YORK, as Mother and Natural Guardian for
A.Y., a minor, as surviving Child of KEVIN P. YORK;

133
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 14 of 28

CONNOR YORK, as surviving Child of KEVIN P.

YORK;
JOHN YORK, as surviving Father of KEVIN P. YORK;
TIMOTHY YORK, as surviving Sibling of KEVIN P.
YORK;

ROSEANN ZISA, Individually, as surviving Spouse, and

Administratrix of the Estate of SALVATORE ZISA,
Deceased;
CHRISTINA ZISA, as surviving Child of SALVATORE
ZISA;
JOSEPH ZISA, as surviving Child of SALVATORE
ZISA;
ROSEMARIE MARTIE, Individually, and Executrix of
the Estate of JOSEPH ZISA, Deceased, as surviving
Father of SALVATORE ZISA;
JOSEPHINE ZISA, as surviving Mother of
SALVATORE ZISA;
ANTHONY ZISA, as surviving Sibling of SALVATORE
ZISA;
JANE PRESTO, as surviving Sibling of SALVATORE
ZISA;
PHYLLIS A. KELLY, as surviving Sibling of
SALVATORE ZISA;

x
CHERYL SCHNEIDER, Individually and
as surviving spouse and the Executrix of the
ESTATE OF IAN SCHNEIDER, Deceased; Jonathan C. Reiter Law Firm,
PLLC
NANCY DIMINO, Individually and
as surviving spouse and as the Executrix of
the ESTATE OF STEPHEN DIMINO, Deceased;

MATILDE SALCEDO, Individually and as the

as the surviving spouse and the Personal Representative
of the ESTATE OF ESMERLIN SALCEDO, Deceased;

SUSAN CONNORS, Individually and

as surviving spouse and as the Executrix of the
ESTATE OF JONATHAN M. CONNORS, Deceased;
GERARD JEAN BAPTISTE, Individually, as surviving
Parent,
and as the Personal Representative of the
ESTATE OF GERARD BAPTISTE, Deceased;

134
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 15 of 28

DEBORA ANN CRISMAN, Indivdually as surviving

Parent, and as the Personal Representative of the
ESTATE OF DANIEL HAL CRISMAN, Deceased;

Plaintiffs,
v.

KINGDOM OF SAUDI ARABIA,

Defendant.
X

COMPLAINT

Plaintiffs, by and through their undersigned counsel, hereby allege:

1. Plaintiffs are the surviving spouses, children, parents, siblings and estate

representatives of the victims murdered in the September 11, 2001 terrorist attacks on the United

States (the "September 11th Attacks") and individuals who suffered personal injuries in the

September 11th Attacks.

2. Plaintiffs bring this action against the defendant Kingdom of Saudi Arabia under

the 2016 Justice Against Sponsors of Terrorism Act (JASTA), which Congress enacted over a

Presidential veto

to provide civil litigants with the broadest possible basis, consistent with the Constitution
of the United States, to seek relief against...foreign countries, wherever acting and
wherever they may be found, that have provided material support, directly or indirectly,
to foreign organizations or persons that engage in terrorist activities against the United
States...

28 U.S.C. 2333 note; as a result, JASTA establishes federal court jurisdiction over the tortious

acts of a foreign state anywhere in the world that cause injury and death in a terrorist attack in

the United States.

3. Plaintiffs seek such relief against the Kingdom of Saudi Arabia for the attributable

acts of the Kingdom's governmental Ministries and bodies, alter-egos, and officers, employees

135
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 16 of 28

and agents acting within the scope of their office, employment or agency by knowingly

providing material support and resources to the al Qaeda terrorist organization and facilitating

the September 11th Attacks, in that, as set forth in detail herein, they:

a. raised, laundered and paid substantial financial support to al Qaeda to fund its

budget and terrorist activities, including the preparation and execution of the September llth

Attacks;

b. funded the terrorist training camps in Afghanistan where al Qaeda indoctrinated

and taught their hijackers the skills they used to carry out the September llth Attacks;

c. provided critical logistical support and resources to al Qaeda around the world,

funding safe houses, furnishing false passport and travel documents, transferring al Qaeda

money, weapons and equipment across international borders and other assistance, all of which

enabled al Qaeda to conduct the September 11th Attacks;

d. actively supported al Qaeda in its final preparations for the September 11th

Attacks through a network of the Kingdom's officers, employees and/or agents who met with

and aided the hijackers, providing them with money, cover, advice, contacts, transportation,

assistance with language and U.S. culture, identification, access to pilot training and other

material support and resources.

4. The defendant Kingdom of Saudi Arabia is a foreign state within the meaning of

28 U.S.C. 1603(a), and "Saudi Arabia" as used hereinafter refers to the Kingdom of Saudi

Arabia, its government Ministries and other bodies (including but not limited to its Ministry of

Islamic Affairs, Ministry of the Interior, Ministry of Foreign Affairs and Embassies throughout

the world), its alter-egos, and its officials, employees, or agents not only in the United States but

throughout the world, while acting within the scope of their office, employment, or agency.

136
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 17 of 28

5. The defendant Kingdom of Saudi Arabia is subject to jurisdiction pursuant to 28

U.S.C. 1330 and JASTA's 28 U.S.C. 1605B, in that, as set forth in detail below, this action:

seeks money damages against the Kingdom of Saudi Arabia for injury and death caused by the

September 11th Attacks, which constitute an act of "international terrorism" in the United States

as defined in 18 U.S.C. 2331; alleges that the September 11th Attacks and the resulting injuries

and deaths were caused by a tortious act or acts of Saudi Arabia, by providing material support

and resources to and facilitating the al Qaeda leaders, planners and hijackers responsible for the

September 11th Attacks, and that such act or acts constitute more than mere negligence, and

were intentional, knowing, reckless, willful and/or grossly negligent.

6. The defendant Kingdom of Saudi Arabia is also subject to jurisdiction pursuant to

28 U.S.C. 1330 and 28 U.S.C. 1605(a)(5), in that, as set forth in detail below, this action seeks

money damages against the Kingdom of Saudi Arabia for injury and death occurring in the

United States and caused by the tortious act or omission of the Kingdom of Saudi Arabia and/or

one or more of its officials or employees acting within the scope of their office or employment.

7. Venue in this District is proper pursuant to 28 U.S.C. 1391(b)(2) and

1391(f)(1), as a substantial part of the events giving rise to this litigation occurred within this

District, as well as 28 U.S.C. 2334(a).

8. The plaintiffs who are the estate representatives of a decedent are listed as such in

the caption, have been duly appointed by a court prior to the commencement of this action and

have the legal authority to bring this action to recover the damages set forth herein, including

wrongful death damages on behalf of all legally entitled beneficiaries of the decedent and

survival damages for the decedent's personal injuries.

137
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 18 of 28

9. For years prior to and on September 11, 2001, Saudi Arabia established, owned,

operated and controlled a series of state-run "charity" organizations, namely

the Muslim World League (MWL),

the International Islamic Relief Organization (IIRO),
the Rabita Trust,
the World Assembly of Muslim Youth (WAMY),
the Benevolence International Foundation (BIF),
the al Haramain Islamic Foundation (AHIF),
the Saudi High Commission for Relief of Bosnia and Herzegovina (SHC),
the Saudi Joint Relief Committee for Kosovo and Albania (SJRC), and
the Saudi Red Crescent (SRC),

and these organizations are referred to hereinafter as "Saudi Arabia's charity organizations" and,

as further described herein, each of these organizations (i) were so closely related to Saudi

Arabia that they must be considered as part of Saudi Arabia, and/or (ii) were government agents

of Saudi Arabia and/or (iii) were alter-egos of Saudi Arabia, because Saudi Arabia: established,

controlled, operated and regulated each organization through its King, Council of Ministers, the

Supreme Council of Islamic Affairs, the Council of Senior Ulema, Ministry of Islamic Affairs,

Ministry of Foreign Affairs, other Ministries and bodies and Saudi Arabia's Embassies

throughout the world; maintained significant, repeated and extensive control of the day-to-day

operations of each organization; provided each organization with virtually all of its funding and

determined how its funds were distributed; established guidelines, plans and policies that each

organization was required to follow; appointed Saudi Arabia officials and employees to the lead

positions within each organization; staffed each organization with Saudi Arabia's officials and

employees; hired, fired and directed each organization's officers and employees; required each

organization to obtain its approval for ordinary business decisions, including purchases, the

locations of its operations and offices, banking, budgeting and grant decisions; used each

organization's personnel and property as its own; ignored the separate legal status, if any, of each

138
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 19 of 28

organization; treated each organization as a part of Saudi Arabia; used each organization to

perform its core governmental functions, including foreign affairs and the advancement of Saudi

Arabia's state religion of Wahhabism throughout the world; and operated, controlled and used

each organization in such a manner that it would work a fraud or injustice to regard the

organization as a legal entity separate from Saudi Arabia.

I.
Saudi Arabia's knowledge of
al Qaeda and its terrorist agenda against
the United States prior to September 11, 2001

10. In 1986-89, Saudi Arabia's MWL, IIRO, WAMY, BIF, SRC and AHIF

collaborated with Osama Bin Laden to open offices in Pakistan and Afghanistan as a means to

establish al Qaeda and provide material support and resources for its terrorist operations, and a

top ranking Saudi Arabia official together with other officials, employees and agents of Saudi

Arabia joined in this effort including:

SRC Director-Pakistan Wael Jelaidan, a close friend and schoolmate of Osama Bin
Laden, who along with the SRC's Aqeel Abdulaziz al Aqeel, founded the AHIF in
Pakistan in 1988 as a division of the SRC and in 1989 took charge of the MWL/IIRO
office in Pakistan;

MWL's Mohamed Khalifa, Osama Bin Laden's brother-in-law, who established the
offices of the MWL and IIRO in Peshawar, Pakistan in 1986 using funds provided by
Osama Bin Laden, pursuant to the instructions of Abdullah Naseef, then MWL's
Secretary General;

WAMY's Adel Batterjee, a close friend of Osama Bin Laden who in 1988-89 established
the operations of the WAMY and BIF (then called Lajnat al Bir al Islamiyah, or LBI) in
Pakistan;

a top ranking Saudi Arabia official who controlled the Afghan Jihad Support Committee
and used it to provide funding for al Qaeda through the various charities, in conjunction
with a 1988 speech of Osama Bin Laden in Saudi Arabia that solicited contributions to
that Committee;

139
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 20 of 28

MWL's Naseef, who met at MWL's office in Peshawar, Pakistan in 1988 with Osama
Bin Laden and discussed how the MWL could provide operational support for al Qaeda,
including but not limited to using MWL's offices as a base for al Qaeda operations and
providing covert assistance to al Qaeda operatives to cross international borders;

and with the material support and resources provided by Saudi Arabia's officials, employees and

agents, and its MWL, IIRO, WAMY, BIF, SRC and AHIF, Osama Bin Laden, Wael Jelaidan,

Mohamed Khalifa, Abdullah Naseef, Adel Batterjee and others founded al Qaeda in Pakistan in

late 1988 - early 1989.

11. At all relevant times mentioned herein, Saudi Arabia: adopted an extremist

version of Islam, Wahhabism, as the state religion; declared that its propagation was a core

function of the state; and, sought to advance it around the world through Saudi Arabia's Ministry

of Islamic Affairs, Embassies, Saudi Arabia's charity organizations and other government

agents.

12. As detailed herein, Saudi Arabia knew from at least the early 1990s that al Qaeda

had begun to pursue and carry out terrorist attacks against the United States, and used

Wahhabism to justify its campaign of anti-American violence, but Saudi Arabia's charitable

organizations and Saudi Arabia's officials, employees and agents continued to provide material

support and resources for al Qaeda through and including September 11, 2001.

13. From 1988 to 1990, Saudi Arabia knew that Osama Bin Laden made public

speeches at his family's mosque in Jeddah and other locations in Saudi Arabia where he declared

that the United States was the primary target of al Qaeda; as an example, in 1990 he stated that:

The Americans won't stop their support of Jews in Palestine until we give them a
lot of blows. They won't stop until we do jihad against them.

14. For years prior to September 11, 2001, as further detailed herein, Saudi Arabia,

including but not limited to its Embassies, its Ministry of Islamic Affairs, its Ministry of the

140
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 21 of 28

Interior and Saudi Arabia's charity organizations, had a relationship and communications with

Osama Bin Laden and al Qaeda's operatives, associates and activities throughout the world.

15. For at least a decade prior to and on September 11, 2001, as detailed herein, Saudi

Arabia knew that numerous officials, employees and agents of Saudi Arabia were al Qaeda

operatives or sympathizers who actively supported al Qaeda's terrorist agenda against the United

States.

16. For years prior to and including September 11, 2001, Saudi Arabia's passport

offices and authorities applied a secret marker/indicator to the passports of persons who had

known ties to al Qaeda, and this marker/indicator was found in the passports of at least three of

the 19 hijackers responsible for the September 11th Attacks, including Nawaf al Hazmi and

Khalid al Mihdhar, and others who assisted them, including Omar al Bayoumi, a Saudi Arabia

employee and agent who aided the hijackers in 2000-2001 in California, as detailed herein, and

information about this marker/indicator was not known by United States consular officers,

immigration or law enforcement agencies.

17. For at least a decade prior to and on September 11, 2001, as detailed herein, Saudi

Arabia had knowledge of the violent goals of al Qaeda and its leader Osama Bin Laden to wage

terrorist attacks against the United States and its citizens and that al Qaeda had engaged in

numerous terrorist attacks and attempted attacks against United States targets.

18. For at least a decade prior to and on September 11, 2001, support for al Qaeda's

terrorist agenda against the United States was pervasive among officials and employees of Saudi

Arabia, and Saudi Arabia was duplicitous: it presented a public face to the United States and

other Western countries of a nation fighting al Qaeda and terrorism while at the same time, as

141
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 22 of 28

detailed herein, Saudi government actors gave al Qaeda substantial material support and

resources.

19. For many years prior to and on September 11, 2001, Saudi Arabia knew of many

attempts by al Qaeda to conduct terrorist attacks directed against the United States, including the

December 1992 attempt by al Qaeda to attack the United States by bombing two hotels in Sanaa,

Yemen where al Qaeda thought U.S. military personnel were staying.

20. On or shortly after February 26, 1993, Saudi Arabia knew that terrorists affiliated

with al Qaeda exploded a truck bomb in the parking garage of the World Trade Center in New

York City, with the intent to topple one of the towers into the other, resulting in 6 deaths and

over 1,000 injuries.

21. In or about October 1993, Saudi Arabia knew that al Qaeda was involved in the

attack on U.S. military forces in Somalia that resulted in 18 deaths and numerous injuries to U.S.

soldiers.

22. From at least early in 1995, Saudi Arabia knew of an al Qaeda plan to attack the

United States called the "Bojinka" plot to simultaneously bomb 10 or more commercial aircraft

operated by United States carriers over the Pacific and that al Qaeda did a test run of that plot on

December 11, 1994, when it bombed a Philippine Airlines flight, killing one passenger and

injuring numerous others.

23. From at least 1996 through and on September 11, 2001, the United States shared

with Saudi Arabia specific information about the threat of al Qaeda terrorist attacks against the

United States, including the specific threat of hijacking by al Qaeda of commercial aircraft

operated by U.S. carriers.

142
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 23 of 28

24. Specifically, from the first half of 1996 through and including September 11,

2001, the United States urgently told Saudi Arabia that it needed background and financial

information and other assistance regarding al Qaeda's leader Osama Bin Laden in order to

disrupt or interdict the threat of al Qaeda terrorist attacks against the United States and its

nationals.

25. In May 1996, Saudi Arabia knew that Osama Bin Laden had to move al Qaeda's

base of operations from Sudan to Afghanistan and that Osama Bin Laden's flight from Sudan to

Afghanistan received air traffic control services and clearance from Saudi Arabia to overfly its

territory.

26. In August 1996, Saudi Arabia knew that al Qaeda through its leader Osama Bin

Laden declared and publicized a fatwa for jihad urging the use of terrorism to attack the United

States and United States citizens.

27. From 1996 through and including September 11, 2001, Saudi Arabia knew that

the Taliban rulers in Afghanistan were providing a safe haven for al Qaeda, Osama Bin Laden

and their terrorist operations, including the Afghan terrorist training camps and safe houses

described herein.

28. In February 1998, Saudi Arabia knew that al Qaeda through its leader Osama Bin

Laden declared and publicized a second fatwa for jihad urging the use of terrorism to attack the

United States and its nationals in all nations throughout the world.

29. For at least one year prior to and including August 7, 1998, Saudi Arabia's AHIF

knew that al Qaeda was planning to conduct a terrorist attack against the United States

Embassies in Kenya and Tanzania, and had specific information that the planned attack against

the U.S. Embassy in Kenya would be a suicide bombing carried out by crashing a vehicle into

143
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 24 of 28

the Embassy gate and Saudi Arabia's AHIF and IIRO provided material support and resources to

al Qaeda to carry out the attack.

30. On or shortly after August 7, 1998, Saudi Arabia knew that al Qaeda carried out

the twin suicide bombing attacks of the United States Embassies in Kenya and Tanzania that

resulted in over 200 deaths.

31. On or shortly after August 20, 1998, Saudi Arabia knew that President Clinton

issued Executive Order 13099, defining al Qaeda and its leader Osama Bin Laden as terrorists

because of their role in the U.S. Embassy bombings and ordered the U.S. military to conduct a

cruise missile strike to destroy al Qaeda terrorist bases in Afghanistan.

32. On or shortly after October 8, 1999, Saudi Arabia knew, from public

announcements made by the U.S. government and other sources, that al Qaeda was formally

designated by the U.S. Secretary of State under section 219 of the Immigration and Nationality

Act, 8 U.S.C. 1189, as a Foreign Terrorist Organization, and Saudi Arabia subsequently knew

that the designation of al Qaeda as a Foreign Terrorist Organization remained in force from

October 1999 through and including September 11, 2001.

33. In or shortly after December 1999, Saudi Arabia knew that al Qaeda prepared and

attempted to execute a "millennium" bomb attack on the United States, planned for January 1,

2000 at the Los Angeles International Airport, but was thwarted by U.S. and Canadian

authorities.

34. On or shortly after October 12, 2000, Saudi Arabia knew that al Qaeda bombed

the U.S.S. Cole while it was being refueled in Yemen, resulting in 17 deaths and numerous

injuries to U.S. Navy sailors.

144
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 25 of 28

35. From May 2001 to September 11, 2001, Saudi Arabia knew that the United States

made urgent requests for assistance from Saudi Arabia concerning an individual in Saudi Arabia

who was in contact with a senior al Qaeda operational coordinator concerning an upcoming al

Qaeda terrorist attack against the United States; a high level U.S. government officer later stated

that had those requests been heeded, the September 11th Attacks could have been avoided.

II.
Saudi Arabia's tortious acts were a
proximate cause of the September 11th Attacks

36. The planning for the September 11th Attacks began in 1996 with initial

discussions among al Qaeda members of the feasibility of hijacking planes and crashing them

into landmarks in the United States and Osama Bin Laden's suggestion that large passenger

aircraft be used as the mode of attack; between 1997 and 1999, al Qaeda reconnaissance teams

travelled to the U.S. to look at potential targets; in November 1999, a "dry run" was conducted

on a U.S. passenger flight to test cockpit security; during 1999 and 2000, the hijackers were

recruited by al Qaeda, mainly in Saudi Arabia, and then indoctrinated and trained at various

terrorist camps in Afghanistan; in January 2000, the first two hijackers arrived in the United

States, and in 2000 and 2001 additional hijackers came to the United States, received flight

training and made their final preparations, and then assembled in September 2001 to conduct the

attacks.

37. On September 11, 2001, the 19 al Qaeda hijackers violently broke into the

cockpits of four commercial airliners and piloted those planes as weapons in a coordinated

terrorist attack on the United States and its citizens, flying two planes into the World Trade

Center Towers in New York and a third plane into the Pentagon in Virginia; the fourth plane

145
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 26 of 28

crashed in Shanksville, Pennsylvania as the passengers fought with the hijackers over control of

the aircraft and thwarted their plans to destroy the U.S. Capitol or White House.

38. As detailed herein, at each stage of al Qaeda's planning and execution leading up

to the September llth Attacks, Saudi Arabia knowingly provided al Qaeda with support,

financing and resources that were material, substantial and critical to the success of the

September 11th Attacks.

A. Saudi Arabia's direct funding of al Qaeda

39. During the decade prior to and including September 11, 2001, Saudi Arabia was

responsible for substantial funding of al Qaeda that was vital to the operation of that terrorist

organization and its preparations for and realization of the September llth Attacks, including but

not limited to the following:

a. Saudi Arabia's MWL, IIRO, Rabita Trust, WAMY, BIF, AHIF, SJC, SHC and

SRC made substantial financial contributions to al Qaeda, as confirmed by U.S., French,

German, Swiss and Saudi Arabia government reports, United Nations reports, the statement of al

Qaeda's Zacarias Moussaoui and other sources;

b. top ranking Saudi Arabia officials made substantial financial contributions to al

Qaeda;

c. from 1995 through and including September 11, 2001, Saudi Arabia, acting

through its employees and agents, including Khalid al Suwailem, a diplomat and senior official

of the Ministry of Islamic Affairs at the Saudi Arabia Embassy in Washington, D.C. and Omar

Abdi Mohamed, employed by Saudi Arabia's Ministry of Islamic Affairs with the job title of

"Propagator": fraudulently sought and obtained a visa for Mohamed to enter the United States as

a "religious worker" and intentionally disguised the fact that Mohamed was a Saudi Arabia

146
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 27 of 28

employee; had Mohamed form and operate the Western Somali Relief Agency (WSRA), a

California non-profit corporation in San Diego, California; and, used WSRA in a scheme to send

substantial funds to al Qaeda;

d. from 1998 through and including September 11, 2001, Saudi Arabia, acting

through its aforesaid employees and agents of Saudi Arabia's Ministry of Islamic Affairs: (i)

fraudulently obtained and/or maintained 26 U.S.C. 501(c)(3) charitable status for WSRA from

the Internal Revenue Service, despite the fact that WSRA never performed any charitable acts;

(ii) used WSRA to receive money from various sources affiliated with al Qaeda, including but

not limited to the AHIF, and (iii) had WSRA send over $350,000 to al Qaeda, via Dahab Shil, a

money transfer agency used by al Qaeda, including but not limited to the Dahab Shil office in

Karachi, Pakistan, which was founded, staffed and controlled by al Qaeda;

e. during the same time period that Saudi Arabia's employees and agents sent over

$350,000 via WSRA to al Qaeda, including through the Dahab Shil office in Karachi, Pakistan,

Khalid Sheikh Mohamed, the mastermind of the September 11th attacks, was located in Karachi

and was handing and sending a total of approximately $400,000 in cash to the hijackers which

constituted the primary funding for the September 11th Attacks;

f. from 1998 through and including September 11, 2001, Saudi Arabia, acting

through its employees and agents, including but not limited to Fahad al Thumairy, funded al

Qaeda by sending substantial sums of money from Saudi Arabia through the King Fahad

Mosque, also known as the Ibn Tamiyah Mosque, in Culver City, California, to al Qaeda, or

through various organizations, individuals and/or private businesses, including but not limited to

charities and/or other businesses, to al Qaeda;

147
 Case 1:17-cv-02003 Document 1-4 Filed 03/20/17 Page 28 of 28

g. from 1998 through and including September 11, 2001, Fahad al Thumairy: (i) was

an accredited diplomat working at Saudi Arabia's Los Angeles Consulate for Saudi Arabia's

Ministry of Islamic Affairs; (ii) reported to more senior officials of Saudi Arabia's Ministry of

Islamic Affairs at Saudi Arabia's Embassy in Washington, D.C.; (iii) had been selected for his

job in Los Angeles by Saudi Arabia's Head of Islamic Affairs in Washington, D.C.; and (iv) was

an extremist Imam at the King Fahad Mosque, which was founded and funded by Saudi Arabia;

h. from 1998 through and including September 11, 2001, Saudi Arabia funded al

Qaeda by sending substantial sums of money through the Islamic Center of San Diego, or

through various organizations, individuals and/or private businesses, including but not limited to

U.S.-based Somali charities and/or other businesses, to al Qaeda;

i. Saudi Arabia hired and paid employees and agents, including Omar al-Bayoumi

and Osama Basnan, who Saudi Arabia knew were al Qaeda operatives and/or sympathizers and

who provided al Qaeda with substantial assistance to prepare for the September llth Attacks;

j. Bayoumi was employed by Saudi Arabia from the 1970s, and starting in 1995

through and including September 11, 2001, he was assigned by Saudi Arabia to work in San

Diego and was compensated by Saudi Arabia through various "ghost jobs" that Bayoumi never

actually performed;

k. in 2000, Bayoumi had a ghost job as a "Senior DSS Programmer" and Saudi

Arabia was paying him $3,000 per month when, as detailed herein, he was instructed by two

officials from Saudi Arabia's Ministry of Islamic Affairs to provide substantial assistance for

two al Qaeda hijackers in California, and Saudi Arabia paid Bayoumi an additional $4,000 per

month, categorized as "Other Allowances," that was tied to his work to assist those hijackers and

raised his total compensation to $7,000 per month from April 2000 through September 2001,

148
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 1 of 26

after which that additional monthly payment ended and his compensation reverted to $3,000 per

month;

1. Basnan, who also provided material support and services to the hijackers in

California, as detailed herein, received approximately $75,000 in a series of transfers from the

Riggs Bank account of the Saudi Arabia Embassy in Washington, D.C. from 1998 through

September 2001, including $25,000 paid by the Embassy to Basnan and his wife in 1998 that

was reimbursed to the Embassy by Yasin Kadi, a known al Qaeda financial operative, who wired

the Embassy $25,000 in May 1998 from his Swiss bank account;

m. from the late 1990s through and including September 11, 2001, Ahmed al

Dubayan and Mohamed Jaber Hassan Fakihi, working for Saudi Arabia's Ministry of Islamic

Affairs in Germany and acting in the course and scope of their jobs for Saudi Arabia as Head of

its Islamic Affairs Office at the Saudi Arabia Embassy in Bonn and/or Berlin, provided

substantial funds of approximately $800,000 from the Saudi Embassy to support al Qaeda in

Germany, including the al Nur Mosque in Berlin;

n. in addition, Dubayan, Fakihi and the Ministry of Islamic Affairs arranged for the

AHIF, with the approval and direct involvement of AHIF's General Director, Aqeel Abdulaziz al

Aqeel, to provide funds in excess of $1,000,000 to support al Qaeda through the al Nur Mosque;

o. the funds were paid by Saudi Arabia's Embassy and the AHIF to the al Nur

Mosque at the specific instructions of al Qaeda operatives and Osama Bin Laden; that Mosque

was frequented by members of the Hamburg al Qaeda cell led by Mohamed Atta that

coordinated and carried out the September 11th Attacks; and, U.S. authorities concluded that

Fakihi was "more than just a sympathizer of bin Laden" and was "organizationally involved"

with al Qaeda;

149
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 2 of 26

p. from 1996 through and including September 11, 2001, Saudi Arabia funded al

Qaeda's recruitment efforts in Germany by sending money to individuals, organizations and/or

businesses there, including but not limited to al Qaeda financial operative Mamoun Darkazanli,

Darkazanli Import Export and Abdelfatah Zammar, and those funds underwrote the recruitment

by Mamoun Darkazanli, Abdelfatah Zammar and Mohamed Zammar at the al Quds Mosque in

Hamburg, Germany of the Hamburg al Qaeda cell members that participated in the September

11th Attacks, including hijackers Mohamed Atta, Ziad Jarrah and Marwan al Shehhi and other al

Qaeda operatives who helped carry out the September 11th Attacks, including Ramzi bin al-

Shibh;

q. starting in 2000 through and including September 11, 2001, AHIF collected over

$1,000,000 for al Qaeda from donors in Saudi Arabia and instructed AHIF's employee and/or

agent Abdulaziz Abdulrahman al Baddah to send those funds to al Qaeda via the Dahab Shil

office in Karachi, Pakistan and Al Wafa Humanitarian Organization in Pakistan;

r. from 1988 through and including September 11, 2001, senior managers of Saudi

Arabia's IIRO, through its office in Pakistan, laundered and diverted IIRO funds to al Qaeda and

used false distribution lists of orphan beneficiaries in Afghanistan as a subterfuge to direct funds

to al Qaeda, as confirmed by Jamal al Fadl, an al Qaeda defector, and senior officials at the

headquarters offices of the MWL and IIRO were aware that IIRO funds were being diverted to al

Qaeda in 1994, if not sooner, yet the practice continued;

s. the IIRO's funding of al Qaeda was further confirmed by a 2001 Ernst & Young

accounting investigation, which reviewed IIRO records from 1996-2001 and detailed numerous

serious discrepancies in IIRO's financial statements and accounts, including but not limited to

that: over half of the funds transferred from IIRO's headquarters could not be accounted for;

150
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 3 of 26

over $3 million of expenditures could not be explained; about $250,000 purportedly spent on aid

to Afghan orphans went missing; signatures on financial documents were faked or forged;

invoices for construction were falsified; and, funds were sent to fictitious companies created by

IIRO directors;

t. from 1993 through 1998, Saudi Arabia's IIRO funded al Qaeda by sending

approximately $500,000 from the IIRO to the IIRO's endowment arm, Sana-Bell, administered

by the IIRO's Suliman al Ali, for a purported real estate project in Fort Washington, MD,

managed by Soliman Biheiri, and all or the large majority of that money, along with

contributions made by Osama Bin Laden's mother and sisters, Abdullah Bin Laden, Osama Bin

Laden's nephew, Yasin Kadi, an al Qaeda operative, and others, altogether totaling

approximately $2 million, went missing, and Biheiri's accountant told the FBI that funds were

transferred overseas to al Qaeda, or through various organizations, individuals and/or private

businesses to al Qaeda, and Biheiri was tried in the Eastern District of Virginia and convicted on

federal charges for passport fraud and making false official statements to obstruct a terrorism

investigation;

u. from 2000 through and including September 11, 2001, Saudi Arabia's WAMY

funded al Qaeda by sending over $50,000 to WAMY's account in Canada which was channeled

through BIF's orphan program in Afghanistan to al Qaeda, or through various organizations,

individuals and/or private businesses to al Qaeda, and less than 25% of the funding for BIF's

orphan program was actually used for orphans;

v. in 1996-1999, under the pretext of doing construction work in Bosnia, Saudi

Arabia's SHC funneled hundreds of thousands of dollars to al Qaeda through companies

established by al Qaeda operatives Wael Jelaidan, Yasin Kadi and Shafiq Ayadi, who were later

151
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 4 of 26

designated by the United States as Specially Designated Global Terrorists because of their

activities to support al Qaeda for the decade prior to the September 11th Attacks;

w. from 1998 through and including September 11, 2001, Saudi Arabia created the

SJRC and appointed Wael Jelaidan, a Saudi Arabia employee since 1985 and former Director of

the MWL, as its Executive Director, despite the fact that Saudi Arabia knew that Jelaidan was an

active al Qaeda operative and one of the founders of al Qaeda;

x. Jelaidan proceeded to use his position as SJRC Executive Director in Albania and

Kosovo to provide financial and logistical support to al Qaeda through businesses in Albania that

were owned and operated by (i) Yasin Kadi, a known al Qaeda financial operative, (ii) Abdelatif

Saleh, a known al Qaeda operative and financial supporter with ties to Osama Bin Laden and (iii)

Jelaidan himself;

y. in September 1999, Jelaidan was declared as an "undesirable" by Albania and

ordered to leave the country because of his links to a 1998 al Qaeda terrorist plot against the U.S.

Embassy in Albania, yet after his expulsion Saudi Arabia continued to retain Jelaidan as SJRC's

Executive Director, and Jelaidan was invited to join top ranking Saudi Arabia officials on Saudi

Arabia government business trips;

z. in 1997-2000, Saudi Arabia's BIF sent approximately $80,000 to al Qaeda

through a front company named Maram, in Istanbul, Turkey, ostensibly a trading company, that

was founded, owned and run by al Qaeda, through its operatives Mahmdou Salim (also a BIF

employee), Wael Jelaidan and Mohamed Bayazid (BIF's President);

aa. in or around February 2000, Saudi Arabia's AHIF sent approximately $150,000 to

al Qaeda through a money laundering scheme whereby funds were received by the AHIF in its

U.S. bank account and then withdrawn from that account and illegally carried out of the U.S. in

152
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 5 of 26

the form of cash and traveler's checks by Soliman al Buthe, a senior member of the Saudi

government for the city of Riyadh, an AHIF officer and President of AH1F in the U.S., and then

distributed through various channels to al Qaeda;

bb. in the late 1980s, Saudi Arabia's MWL sent its employee and agent Mohamed

Khalifa, Osama Bin Laden's brother-in-law, to found a MWL/IIRO office in the Philippines and

thereafter in or around 1994, money from Saudi Arabia's IIRO through its Philippines' office

was used to fund an al Qaeda affiliated terrorist cell headed by Ramzi Yousef, the 1993 World

Trade Center bomber, to carry out terrorist attacks against the United States, including the 1995

Bojinka plot and its test run, the December 1994 Philippine Airlines bombing, which were

forerunners of the September 11th Attacks;

cc. following the September 11th Attacks, the United States formally declared in

Exec. Order No. 13224 (as issued in 2001 and updated in 2001, 2002, 2004, 2006 and 2008) that

all or portions of four of Saudi Arabia's charity organizations, namely the AHIF, IIRO, Rabita

Trust and BIF, and numerous employees of Saudi Arabia's charity organizations, including Wael

Jelaidan (MWL, IIRO, SRC, SJRC, Rabita Trust), Abdelhamid al Mujil (IIRO), Soliman al

Buthe (AHIF), Aqeel al Aqeel (AHIF), Adel Batterjee (WAMY, BIF), Enaam Arnaout (MWL,

WAMY, BIF) were Specially Designated Global Terrorists, based on the material support and

resources they provided to al Qaeda prior to the September 11th Attacks; and

dd. prior to and including September 11, 2001, Saudi Arabia funded al Qaeda in

additional ways, as will be determined through further investigation, disclosures and discovery of

Saudi Arabia.

B. Saudi Arabia's material support of

the Afghan terrorist training camps used to
indoctrinate and provide terrorist training for the 19 hijackers

153
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 6 of 26

40. Each of the 19 hijackers and others involved in supporting the September 11th

Attacks were indoctrinated and given their terrorist training necessary to prepare for and execute

the September llth Attacks at one or more al Qaeda terrorist training camps located in

Afghanistan, hereinafter called the "Afghan terrorist training camps", including:

"Al Farouq 1" (hijackers Nawaf al Hazmi and Khalid al Mihdhar);

"Al Farouq 2" (hijackers Abdelaziz al Omari, Ahmed al Ghamdi, Ahmed al Haznawi,
Ahmed al Nami, Fayez Banihammad, Hamza al Ghamdi, Hani Hanjour, Mohand Shehri,
Salem al Hazmi, Sayid al Ghamdi, Wail al Shehri and Walid al Shehri);

"Khalden" (hijackers Khalid al Mihdhar, Majed al Moqed, Satam al Suqami);

"al Matar" (hijackers Abdelaziz al Omari, Ahmed al Ghamdi, Ahmed al Haznawi,

Ahmed al Nami, Fayez Banihammad, Hamza al Ghamdi, Mohand Shehri, Salem al
Hazmi, Sayid al Ghamdi, Wail al Shehri and Walid al Shehri);

"Mes Aynak" (hijackers Nawaf al Hazmi and Khalid al Mihdhar); and

"Tarnak Farms" (hijackers Ziad Jarrah, Mohamed Atta and Marwan al Shehhi).

41. Those Afghan terrorist training camps provided training to the 19 hijackers in

various skills that they used to execute the September 11th Attacks, including aircraft hijacking,

discipline, hand-to-hand combat, weaponry (including the use of knives and blades to murder),

hostage taking, religious indoctrination, English language skills and U.S. culture.

42. For years prior to and including September 11, 2001, Saudi Arabia's IIRO, AHIF

and MWL provided substantial funding and other material support for the Afghan terrorist

training camps attended by the 19 hijackers in Afghanistan, including but not limited to the

following:

a. Saudi Arabia's IIRO was the principal source of funding and other material

support to establish and operate the Afghan terrorist training camps, as confirmed by:

154
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 7 of 26

i. a 1996 C.I.A. report, which stated that the IIRO funded six terrorist
training camps in Afghanistan;

ii. a 2003 report by the United Nations Security Council, which stated that
"IIRO funds directly supported six Al-Qaida training camps in Afghanistan prior to
September 11";

iii. a 2004 U.S. State Department cable, which described the IIRO as "the
principal sponsor of terrorist training camps in Afghanistan during the Taliban regime",
i.e. from 1996 through and including September 11, 2001;

iv. a 2003 report which stated that an IIRO employee, Abu Nasir, was
informed by his superiors in the 1990s that approximately 40 to 50 percent of IIRO' s
charitable funds was being diverted to finance terrorist training camps in Afghanistan and
Kashmir;

v. a January 2001 French intelligence report;

vi. the statement of Zacarias Moussaoui;

vii. U.S. reports regarding the September 11th Attacks which tied the IIRO to
funding of the Afghan training camps; and

viii. in 2001 through and including September 11, 2001, at least one IIRO
employee was also a trainer at the Afghan terrorist training camps;

b. Saudi Arabia's AHIF provided major funding to establish and operate the Afghan

training camps, as confirmed by:

i. the statement of Zacarias Moussaoui;

ii. U.S. reports regarding the September 11th Attacks tied the AHIF to
funding of the Afghan training camps; and

iii. in the 1990s through and including September 11, 2001, a representative
of Saudi Arabia's AHIF in Belgium was a recruiter for al Qaeda Afghan terrorist training
camps;

c. the MWL, IIRO and AHIF paid for transportation for al Qaeda operatives to

attend the Afghan terrorist training camps;

d. the MWL, IIRO and AHIF paid for building materials and electrical supplies

necessary to construct the Afghan terrorist training camps; and

155
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 8 of 26

e. the MWL, IIRO and AHIF funded and provided material support for the Afghan

terrorist training camps in additional ways, as will be determined through further investigation,

disclosures and discovery of Saudi Arabia.

C. Saudi Arabia's logistic211 support of al Qaeda

43. During the decade prior to and including September 11, 2001, and during the

period that al Qaeda was actively planning the September 11th Attacks, Saudi Arabia provided

material logistical support and resources to al Qaeda, including, but not limited to the following:

a. U.S. State Department officials concluded that Osama Bin Laden "used the entire

IIRO network for his terrorist activities";

b. in the late 1990s through and including September 11, 2001, the office and

guesthouse of Saudi Arabia's IIRO in Kandahar, Afghanistan was operated as a way-station and

safe house for al Qaeda operatives travelling to the Afghan terrorist training camps;

c. in or around October 1998 through and including September 11, 2001, Saudi

Arabia announced that it closed its Embassy/Ambassador's residence in Kabul, Afghanistan

(following al Qaeda's bombings of U.S. Embassies in Tanzania and Kenya) and thereafter, the

Director of the AHIF in Afghanistan was instructed by "Riyadh" (the capital city of Saudi Arabia

and location of the headquarters office of Saudi Arabia's AHIF) to open an office at that

Embassy/Ambassador's residence; and, the AHIF operated such an office and provided material

support and resources to al Qaeda through that office;

d. in or around October 1998 through and including September 11, 2001, Saudi

Arabia's Embassy/Ambassador's residence in Kabul was used as a "guesthouse", i.e. safe house,

by al Qaeda; and, Osama Bin Laden and numerous other al Qaeda operatives, likely including

several of the 19 hijackers, stayed at that safe house;

156
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 9 of 26

e. from 1998 through and including September 11, 2001, Saudi Arabia provided

funding and military equipment to the Taliban, including through Saudi Arabia's charity

organizations, including but not limited to the AHIF, to support the use of Afghanistan as a safe

haven for al Qaeda;

f. from 1998 through and including September 11, 2001, Saudi Arabia facilitated

and provided support and services for the Taliban controlled airline, Afghan Ariana Airlines, to

conduct flights between Afghanistan and Saudi Arabia which Saudi Arabia knew were being

conducted as a supply service for al Qaeda to shuttle guns, money and al Qaeda recruits and

operatives to Afghanistan;

g. prior to and including September 11, 2001, Saudi Arabia Embassy diplomats in

Bosnia coordinated financial support from Saudi Arabia's AHIF to al Qaeda operatives;

h. in 1997 through and including September 11, 2001, Saudi Arabia's AHIF

operated a program in Azerbaijan that provided training for AHIF employees in money

laundering techniques to fund al Qaeda using bank accounts, money transfer companies and cash

couriers and those employees were then deployed to Pakistan and used those money laundering

techniques to receive funds from the AHIF in Saudi Arabia and send those funds to al Qaeda in

Pakistan and Afghanistan, as described herein;

i. from 1998 through and including September 11, 2001, Saudi Arabia's BIF,

assisted al Qaeda and Osama Bin Laden with the procurement and transport of materials and

weapons, and the transfer of al Qaeda funds, including via the use of "front companies" in

various countries, including but not limited to Sudan, Turkey and the U.A.E.;

J SaudiArabia's state-run Imam Muhammad Ibn Saud Islamic University ("Imam

University") employed numerous instructors who were al Qaeda operatives or sympathizers,

157
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 10 of 26

recruited and indoctrinated its students to join al Qaeda, and at least five of the 19 hijackers

responsible for the September 11th Attacks, together with other al Qaeda operatives who

attended Imam University, were likely recruited as al Qaeda operatives by Saudi Arabia's

employees and agents;

k. in or around July 2001, Saudi Arabia's passport office and authorities issued a

passport under a false name to Khalid Sheikh Mohamed, a Pakistani citizen who worked with

and for al Qaeda to plan, carry out and mastermind the September 11th Attacks;

1. from 1996 through and including September 11, 2001, Saudi Arabia assisted

various of its employees and agents who provided material support and resources to al Qaeda for

the September 11th Attacks to obtain fraudulent visas to enter the United States, in violation of

federal law, and failed to advise U.S. officials, including the U.S. Attorney General, that the

employees and agents were working for Saudi Arabia inside the United States, in violation of

federal law, including but not limited to the following:

Omar Abdi Mohamed, who first entered the U.S. on a fraudulent religious worker visa in
1995, and did not declare that he was actually working for Saudi Arabia, and was
ultimately prosecuted, convicted and deported from the United States in 2006 for those
false statements;

Omar al Bayoumi, who repeatedly entered the U.S. on a student visa for several years
prior to and including 1999-2000, even though he was not attending school, was
collecting salary for a "ghost job" while actually working for Saudi Arabia, and provided
material support and resources for the al Qaeda hijackers, as described herein;

Osama Basnan, who entered the U.S. on a tourist visa in 1996, when he was working for
Saudi Arabia, and provided material support and resources for the al Qaeda hijackers, as
described herein, and did not leave the U.S. until August 2002, after he was convicted for
visa fraud and deported;

m. Saudi Arabia's passport offices and authorities provided al Qaeda operatives,

including several of the 19 hijackers involved in the September llth Attacks, with new,

158
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 11 of 26

"cleansed" passports to allow them to travel and obtain visas without suspicion, including but not

limited to removing references to travel through Pakistan to the Afghan terrorist training camps;

n. Saudi Arabia's SRC, MWL, IIRO, WAMY and/or AHIF provided Osama Bin

Laden and other al Qaeda operatives with identification cards and visas for travel, including to

the Afghan terrorist training camps;

o. Saudi Arabia's AHIF provided secret courier services for al Qaeda, including but

not limited to such services provided by AHIF employee and/or agent Abdirashid Aidid, who

was based in Pakistan in 2000;

P. Saudi Arabia's AHIF faxed coded messages for al Qaeda, including but not

limited to a message sent from AHIF in Albania to an al Qaeda operative in London in 1998

related to an al Qaeda plot in the summer of 1998 to attack the U.S. Embassy in Tirana, Albania;

q. in 1998-99, Saudi Arabia's IIRO and AHIF provided computers and other

materials to al Qaeda in Afghanistan;

r. in 1999-2000, Saudi Arabia provided Wahhabist books and literature to al Qaeda

in Kandahar, Afghanistan that were used to indoctrinate the Taliban leadership and al Qaeda

recruits, including the 19 hijackers involved in the September 11th Attacks;

s. in 1992-1996, al Qaeda sent operatives to fight in the Bosnian war, including two

of the 19 hijackers, and Saudi Arabia's charity organizations, including the SHC, WAMY, BIF

and AHIF, provided those al Qaeda operatives with employment, identification, food, weapons

and equipment, and the SHC employed various al Qaeda operatives, including Ali Ahmed Ali

Hamad, Abdelsamad al Bahrani, Hassam al Din, Abu Miqdad al Dosari, Abu Abdelmalik al Libi,

and Yusuf Rahman in Bosnia, and Abdullah al Matrafi in Mecca;

159
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 12 of 26

t. from 1992 to 1996, a high ranking Saudi Arabia official, the SHC and IIRO sent

millions of dollars to the Third World Relief organization, an al Qaeda front, with the knowledge

that a substantial portion of such contributions would fund al Qaeda, including the transportation

of al Qaeda operatives to the war in Bosnia, and the purchase of various weapons, including but

not limited to grenade launchers, rifles, guns and chemical cartridges;

u. in 1993, Saudi Arabia's SHC, which at the time was run by a top ranking Saudi

Arabia official, as confirmed by the U.S. Defense Intelligence Agency, provided weapons to a

Somali faction who were being trained by al Qaeda and those weapons were used to kill

numerous U.S. servicemen who were providing security for a U.N. humanitarian mission in

Somalia; and,

v. prior to and including September 11, 2001, Saudi Arabia provided logistical

support to al Qaeda in additional ways, as will be determined through further investigation,

disclosures and discovery of Saudi Arabia.

D. Saudi Arabia's material support for al Qaeda's

planning and execution of the September 11th Attacks

44. Saudi Arabia provided material support and resources for al Qaeda and the 19

hijackers directly linked to the actual planning and execution of the September 11th Attacks,

including but not limited to the following:

a. as detailed above, Saudi Arabia was responsible for the financing of the plot

through various schemes that funded al Qaeda at the same time that the 19 hijackers were being

handed or sent money (39c - h, 39q, 43h); paid Saudi Arabia's agents and employees for their

work to assist the hijackers (T39i -1); provided money for the recruitment and support of al

Qaeda's Hamburg cell (39rn - p); bankrolled the Afghan terrorist training camps attended by all

160
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 13 of 26

19 hijackers (40 - 42); and, logistical help used by the hijackers and their support network,

including safe houses and identification (43b - d, 43k - n);

b. in or before January 2000, a senior Saudi Arabia official at Saudi Arabia's

Embassy in Washington, D.C. gave instructions to Saudi diplomat Fahad al Thumairy and Omar

al Bayoumi, another agent and employee working for Saudi Arabia, including for its Embassy in

Washington, D.C., its Consulate in Los Angeles, Ministry of Higher Education, Ministry of

Islamic Affairs, Ministry of Defense, and/or other agencies, to meet with and provide cover,

advice, planning, safe houses and other material support and resources to al Qaeda hijackers

Khalid al Mihdhar and Nawaf al Hazmi, the first of the 19 hijackers to arrive in the United

States;

c. in or around January 2000, Thumairy met in person in Los Angeles with Mihdhar

and Hazmi upon their arrival in the United States, assisted them with transportation and housing,

including arranging an apartment for the hijackers at the Avalon Westside apartments in Los

Angeles, and met with and directed Bayoumi and others, including but not limited to Oualid

Benomrane and Mohdar Abdullah, to provide material support and resources to hijackers

Mihdhar and Hazmi;

d. from January 2000 through and including September 11, 2001, Bayoumi, acting

in the course and scope of his employment with Saudi Arabia and/or as an agent of Saudi Arabia,

provided money, cover, advice, planning, safe houses and other material support and resources to

al Qaeda hijackers Mihdhar and Hazmi, including: helping them learn English and American

culture and assimilate into the U.S. without drawing attention to themselves; finding them

apartments in San Diego; co-signing their lease and providing money for the rent and security

deposit; lending them his cellphone; assisting them to open bank accounts; introducing them to

161
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 14 of 26

others who could provide them with information and assistance, including but not limited to: (i)

Osama Basnan, a Saudi Arabia employee and agent working for Saudi Arabia, (ii) Yazeed al

Salmi (the nephew of Bayoumi's superior in Saudi Arabia's Ministry of Defense), (iii) Anwar al

Aulaqi, an al Qaeda operative in San Diego and Virginia (later designated by the United States as

a Specially Designated Global Terrorist), who had meetings not only with Mihdhar and Hazmi,

but also with hijacker Hani Hanjour, and provided them with guidance, encouragement and other

material support and resources, and (iv) Osama Nooh and Lafi al Harb, two Saudi Arabia Naval

officers attending U.S. Navy training in San Diego; and, otherwise assisting them with their

preparations for the September 11th Attacks;

e. from January 2000 and thereafter before September 11, 2001, Mohdar Abdullah,

at the direction of Thumairy and/or Bayoumi, provided material support and resources to

hijackers Mihdhar and Hazmi, including but not limited to: assisting them to acclimate and live

in California; providing them with transportation to various locations; helping them obtain social

security numbers and genuine California driver's licenses; aiding them to locate and obtain

phony and illegal California driver's licenses; assisting them to locate and apply to language and

flight schools; performing surveillance of airport facilities with them; assisting them with visa

issues to maintain their legal status in the United States; and, regularly having meals and various

social contacts with them;

f. from January 2000 and thereafter before September 11, 2001, Oualid Benomrane,

at the direction of Thumairy and another employee or agent of Saudi Arabia at its Los Angeles

Consulate, and for compensation paid by Saudi Arabia, provided material support and resources

to hijackers Mihdhar and Hazmi, including but not limited to: providing them with transportation

to various locations, assisting them as a translator and helping them to learn English; and,

162
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 15 of 26

Benomrane told U.S. law enforcement authorities that: (i) Thumairy asked him to assist Mihdhar

and Hazmi and told him not to tell anyone about the two men and to keep their presence in

California to himself, (ii) Thumairy told him that the two men were in Los Angeles to visit their

sick father in a local hospital and (iii) the Saudi Consulate had picked up the two men at the Los

Angeles airport and found an apartment for them;

g. from January 2000 and thereafter before September 11, 2001, Osama Basnan, a

known al Qaeda supporter acting in the course and scope of his employment with Saudi Arabia

and/or as an agent of Saudi Arabia, met with and had hundreds of phone conversations with

Bayoumi, lived across the street from hijackers Mihdhar and Hazmi in San Diego and met with

and provided material support and resources to them, including putting them in contact with a

commercial airline pilot, Khaled al-Kayed;

h. Basnan was working at the Saudi Arabia Embassy in Washington, D.C. in 1992

when he held an event to honor Omar Abdul Rahman, the "Blind Sheikh," who was an al Qaeda

supporter convicted in 1995 for his role in masterminding a foiled terrorist attack against various

New York City bridges, tunnels and landmarks; in 1998, Basnan and his wife received $25,000

through the Saudi Embassy in Washington, D.C. that was reimbursed to the Embassy by Yasin

Kadi, a known al Qaeda financial operative; from February 1999 through and including May

2002, Basnan's wife was paid $2,000-$3,000 each month via checks from that same Embassy;

prior to September 11, 2001, Basnan spoke of Osama Bin Laden "as if he were a God"; either

Basnan or an associate had phone contacts with the members of al Qaeda's Hamburg cell and

Basnan placed regular calls to members of Osama Bin Laden's family; and, after the September

11th Attacks, Basnan celebrated at a party saying that the hijackers were "heroes" and remarked

163
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 16 of 26

"what a wonderful glorious day it had been" and he later bragged that "that he did more for the

hijackers than Bayoumi did";

i. in or around June 2000, pursuant to the instructions of Thumiary and/or Bayoumi,

Mohdar Abdullah brought Mihdhar and Hazmi to Los Angeles for private meetings held at the

King Fahad Mosque and a Los Angeles motel with another al Qaeda operative;

j. from June 2000 and thereafter before September 11, 2001, after a trip to Saudi

Arabia by Bayoumi, the nephew of his superior in the Ministry of Defense, Yazid Salmi,

travelled to San Diego, and Bayoumi found Salmi accommodation with hijacker Hazmi, and

Salmi provided money, including $1,900 in traveller's checks, to Hazmi in September 2000;

k. in November 1999, Hamdan Shalawi and Mohamed Qudhaieen, both known al

Qaeda operatives and/or associates and Imam University graduates, were employed and paid by

Saudi Arabia to attend graduate school in Arizona and perform other duties as requested by the

Saudi Arabia Embassy in Washington, D.C., and were acting in the course and scope of their

employment with Saudi Arabia and/or as agents of Saudi Arabia when they travelled on a

commercial airline flight from Phoenix to Washington, D.C. and intentionally attempted on at

least two occasions to gain entry to the airplane's cockpit to test and learn U.S. airline security

procedures in a "dry run" of the September 11th Attacks;

1. Shalawi and Qudhaieen were travelling on that flight using tickets paid for by

Saudi Arabia with the ostensible purpose of attending a symposium at Saudi Arabia's Institute of

Islamic and Arabic Sciences in America (IIASA) with high ranking Saudi Arabia officials,

including Abdullah Naseef, former MWL Secretary-General and Vice-Chairman of the Shura

Council;

164
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 17 of 26

m. in the late 1980s Shalawi attended and received terrorist training at Masadat al

Ansar, then Osama Bin Laden's main training camp; before and after the "dry run," Shalawi

and/or Qudhaieen met with others involved in the planning and execution of the September 11th

Attacks, including (i) hijacker Hani Hanjour, who they met from 1997-1999 at the Saudi Arabia-

funded Tempe Islamic Center in Tempe, AZ; (ii) Thumairy, who they met at the opening of the

King Fahad Mosque in Culver City, CA in 1998; and (iii) several of the muscle hijackers

involved in the September 11th Attacks, who underwent training in the fall and winter of 2000-

2001 at an Afghan terrorist training camp at the same time as Shalawi; as a result of attending

that camp, Shalawi was watchlisted by the United States as a potential terrorist and denied a visa

when he attempted to re-enter the United States in August 2001 (likely as part of an al Qaeda

terrorist operation); and, in 2000-2001 both Shalawi and Qudhaieen continued their work for

Saudi Arabia, and were employed as teachers as Imam University;

n. from 1996 through 1999, a top ranking Saudi Arabia official sent money to a

construction business in Spain that was operated as a ploy to fund al Qaeda's Spanish cell, which

used the money it received to: (i) conduct surveillance and take videotapes of potential terrorist

targets, including the World Trade Center, for al Qaeda in the United States, (ii) send tapes of

those targets to Osama Bin Laden for his review; and (iii) establish a logistical cell in Turkey to

assist the movement of al Qaeda recruits from Europe to Chechnya and Afghanistan, a route

taken by members of al Qaeda's Hamburg cell, including several of the 19 hijackers;

o. it is likely that additional employees and agents of Saudi Arabia provided the 19

hijackers with material support and resources to carry out the September 11th Attacks, including

but not limited to:

i. Saleh al Hussayen, a Saudi Arabia Interior Ministry employee who stayed

at the same hotel as the hijackers on the evening of September 10, 2001;

165
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 18 of 26

ii. Saudi Arabia's pilots, who were uniquely situated to furnish the highly
specialized flight training obtained by the hijackers, as demonstrated by the flight skills
the hijackers used to carry out the September 11th Attacks, including Fahad Bakalka, a
Saudi Arabia pilot who flew for the Royal Family, Osama Bin Laden and Saudi Arabia's
National Commercial Bank and was a friend of two of the 19 hijackers, and Mohamed
Tahsin, who also flew for Saudi Arabia's National Commercial Bank and was
investigated by the FBI for being a financial associate of one of the 19 hijackers;

iii. Sayid Rageah, a WAMY employee and fund raiser for al Qaeda who was
the Imam at a mosque in Maryland visited by the hijackers on September 10, 2001;

iv. from 1999 through and including September 11, 2001, Abdullah Bin
Laden, nephew of Osama Bin Laden, was Saudi Arabia's Administrative Officer at its
United States Embassy and Head of WAMY's branch office in the United States, and
maintained a close business and personal relationship with Mohamed Harunani, a
WAMY contractor (Abdullah Bin Laden was listed as the emergency contact for
Harunani's children and they frequently called and sent messages to each other), and
Harunani was in contact with several of the al Qaeda hijackers and operatives from the
Hamburg cell, including Mohamed Atta and Marwan al Shehhi;

p. the AHIF's Director in Belgium, Tarek Maroufi, was hired by the AHIF in

January 2001 despite his known history as an al Qaeda operative who served a prison sentence

for a prior terrorist attack in Belgium, and Maroufi organized the September 9, 2001 murder of

Ahmad Shah Massoud, the commander of the Northern Alliance, an opposition force fighting the

Taliban and al Qaeda in Afghanistan, by recruiting the assassins and providing them with fake

Belgian passports, and Massoud's assassination was arranged to reduce the risk of an attack

from Northern Alliance forces that al Qaeda expected would follow from the September 11th

Attacks;

q. in interviews conducted by U.S. authorities following the September llth

Attacks, Saudi Arabia's officers, employees and agents repeatedly lied about their key contacts

and information concerning the material assistance they provided to the hijackers and al Qaeda,

including:

166
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 19 of 26

i. Thumairy falsely stated that: he did not recognize Bayoumi's name and
had never seen Bayoumi in Los Angeles (but they had met on several occasions there and
exchanged numerous phone calls); he did not know Abdullah or Benomrane (despite
meeting with them and asking them to help the two hijackers); neither he, the King Fahad
Mosque nor the Saudi Consulate rented more than one apartment at the Avalon Westside
apartments in Los Angeles (where they actually had extensive additional rentals and
where Thumairy arranged for the hijackers to stay upon their arrival);

ii. Bayoumi falsely stated that: he had only a random several minute
encounter with the hijackers at a Los Angeles restaurant (when witnesses said he had
lunch with them); after leaving the restaurant he tried to visit the King Fahad Mosque but
couldn't find it and returned home without ever visiting it (but a witness confirmed that
Bayoumi visited the mosque before and after going to the restaurant); he didn't know
where the hijackers stayed immediately following their arrival in San Diego (although
Bayoumi himself filled out an application form for the hijackers' apartment which stated
that the hijackers had been living with him since their arrival); following his initial
contacts with the hijackers, Bayoumi could recall only one occasion when he saw one of
the hijackers and it was by chance and from a distance (while Bayoumi lived next door to
the hijackers and a witness stated that he saw Bayoumi with the hijackers at their
apartment on numerous occasions); he did not tell Mohdar to provide assistance to the
hijackers (while Mohdar told authorities that Bayoumi asked him to drive the hijackers
around San Diego and help them enroll in classes); he did not have any relationship with
Basnan (but investigators concluded they were extremely close, with over 700 phone
calls exchanged between them); no one told him to help the hijackers (while Thumairy
and a superior in Washington, D.C. gave Bayoumi such instructions and Bayoumi's
phone records confirm those contacts);

iii. Basnan was found by the authorities to have an "utter lack of credibility
on virtually every material subject," and falsely claimed not to know Bayoumi (despite
their numerous contacts and phone calls); denied knowing Omar Bakarbashat, a friend
and supporter of the hijackers (despite the fact that Bakarbashat was Basnan's brother-in-
law); and, denied ever seeing the hijackers or saying that he did (yet boasted to a witness
that he provided more support to the hijackers than Bayoumi and lived across the street
from them for several months);

iv. Saleh al Hussayen faked a seizure during his interview with the
authorities, was taken to the hospital, where doctors found him in good health, and
thereafter Hussayen quickly fled the United States;

v. Omar Abdi Mohamed falsely stated that the WSRA "charity" was an
entity in name only, had never received funds and had no money (yet over $350,000 was
received into and sent out from WSRA's bank account) and failed to reveal that he had
been employed by Saudi Arabia's Ministry of Islamic Affairs for 10 years;

vi. Qudhaieen falsely stated that: he never got near the cockpit on the dry run
flight (while witnesses saw him try to enter and rattle the cockpit door on at least two

167
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 20 of 26

occasions); he did not know Thumairy (but later recanted and admitted that he knew
Thumairy); and,

vii. Shalawi said he was enrolled and present at Arizona State University
during the entire 2000-2001 academic year (but did not tell the authorities that he went to
an al Qaeda Afghan terrorist training camp in the fall of 2000);

r. several of the 19 hijackers and others who assisted in the September llth Attacks

were provided employment by Saudi Arabia, despite Saudi Arabia's knowledge that they were

associated with al Qaeda, including but not limited to:

i. Hani Hanjour, a hijacker who worked for the IIRO from 1989-1991 in
Pakistan and Afghanistan and likely received payments from Saudi Arabia to attend
schools in the United States at various times starting in 1992, including from December
2000 through and including September 11, 2001;

ii. Mohand Shehri, a hijacker who worked for the IIRO in logistics, moving
goods from Peshawar, Pakistan to Kabul, Afghanistan, starting in 1999, and;

iii. Wail al Shehri, a hijacker who worked for Saudi Arabia as a teacher on a
Saudi Arabia military base from 1999 through 2001, during which time he trained at al
Qaeda camps in Afghanistan;

iv. Omar Abdi Mohamed, an employee of Saudi Arabia's Ministry of Islamic

Affairs, who, pursuant to directions from a superior in the Ministry, fraudulently obtained
a visa to enter the United States and provided substantial funding for al Qaeda through
the WSRA charity, as detailed herein;

v. Omar al Bayoumi, an employee of Saudi Arabia who provided substantial

assistance to the hijackers, and who had an indicator in his Saudi Arabia passport of ties
to al Qaeda, as detailed herein;

vi. Fahad al Thumairy, a Saudi Arabia diplomat at its Los Angeles consulate,
who provided material assistance to the hijackers and was denied entry to the United
States after the September 11th Attacks because of his ties to terrorism;

vii. Osama Basnan, a Saudi Arabia employee and/or agent and frequent
contact of Bayoumi who was a known al Qaeda associate and/or operative;

viii. Hamdan Shalawi, a Saudi Arabia employee and al Qaeda operative who
attended Osama Bin Laden's main terrorist training camp in Afghanistan the late 1980s;
and,

168
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 21 of 26

ix. Mohamed Qudhaieen, a Saudi Arabia employee and known al Qaeda

associate.

s. prior to and including September 11, 2001, Saudi Arabia provided material

support and resources directly linked to the actual planning and execution of the September 11th

Attacks in additional ways, as will be determined through further investigation, disclosures and

discovery of Saudi Arabia.

III.
Saudi Arabia's domination and control of its charitable organizations

45. As set forth herein, at all relevant times prior to and on September 11, 2001, Saudi

Arabia used its charitable organizations to perform core governmental functions, and those

organizations acted as Saudi Arabia's alter-ego and/or agent.

46. At all relevant times prior to and on September 11, 2001, the MWL, IIRO and

Rabita Trust were each part of Saudi Arabia, alter-egos of Saudi Arabia and/or agents of Saudi

Arabia, and it would work a fraud or injustice to regard them as legal entities separate from

Saudi Arabia, as evidenced by the following:

a. in pleadings filed before this Court, the MWL and IIRO asserted they were

immune from suit because of their status as a foreign sovereign, namely Saudi Arabia;

b. the MWL, IIRO and Rabita Trust were founded by Saudi Arabia, and were

closely related organizations with shared employees, bank accounts and offices and their daily

operations were overseen by MWL's Secretary General, who was appointed and directed by

Saudi Arabia;

169
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 22 of 26

c. the Secretary General of the MWL was a Saudi Arabia Minister-level

appointment named by Royal Decree and served as the President of the IIRO, appointed the

Secretary General of the IIRO, and had the power to hire and fire IIRO employees;

d. the Rabita Trust was part of the MWL and the MWL ran the operations of the

Rabita Trust on a day-to-day basis and had the power to hire and fire Rabita Trust employees;

e. MWL, IIRO and Rabita Trust received directions from and sought the approval of

Saudi Arabia's King, Minister of Islamic Affairs and other senior officials of Saudi Arabia

regarding all aspects of their operations, including but not limited to personnel, finances, bank

accounts, donations, funding, travel and project decisions, such as:

i. the approval of the King was obtained for fund raising campaigns;

ii. the MWL sought approval from the Ministry of Islamic Affairs to make
trips to foreign countries;

iii. Saudi Embassy officials provided the IIRO with strict instructions
regarding making statements to the press;

iv. the Supreme Council of Islamic Affairs directed the MWL to provide
project aid, including for Burmese refugees in 1999;

v. the IIRO's Secretary General confirmed in a September 2000 letter that

the IIRO was overseen by the Dawa Committee of the Ministry of Islamic Affairs;

f. the existence of the MWL, IIRO and Rabita Trust was subject to the ongoing

approval of Saudi Arabia and could be terminated at any time by Saudi Arabia;

g. MWL's Secretary General from 1995-2000, Abdullah bin Saleh al Obaid,

confirmed under oath that he was appointed to his position by Royal Decree of Saudi Arabia and

that the MWL was "sponsored and financially supported by the Saudi Government";

h. Saudi Arabia's Minister of Islamic Affairs Saleh bin Abdulaziz Al Ash-Shaikh

described MWL as a "public" institution of Saudi Arabia;

170
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 23 of 26

i. the annual budget of the MWL, IIRO and Rabita Trust was funded almost

exclusively by Saudi Arabia and, for example, MWL's financial records for 2000-01 show that

98.5% of MWL's revenues were paid by Saudi Arabia;

J. the policies followed by MWL, IIRO and Rabita Trust were determined by a

Constitutive Council chaired by the Grand Mufti appointed by the King of Saudi Arabia;

k. the highest officers of the MWL, IIRO and Rabita Trust responsible for their

operations simultaneously held other positions as officials with Saudi Arabia, and reported to

higher ranking officials of Saudi Arabia, including but not limited to:

i. MWL's Secretary General was a member of Saudi Arabia's Supreme

Council of Islamic Affairs;

ii. MWL's Jurisprudence Council member was the Head of Saudi Arabia's
Shura Council;

iii. IIRO's Board Director was a member of the Shura Council;

iv. Rabita Trust's Secretary General was the Executive Director of Saudi
Arabia's SJRC;

v. MWL's Constituent Council Chair was Chair of the Senior Council of

Saudi Arabia's Ulema;

1. employees of the MWL, IIRO and Rabita Trust were simultaneously employed by

Saudi Arabia in another capacity, often as employees of a Saudi Arabia Embassy or other Saudi

Arabia agency, and reported on a day-to-day basis to more senior employees and officers of

Saudi Arabia;

m. lower level employees of the MWL, IIRO and Rabita Trust reported on a day-to-

day basis to more senior MWL, IIRO and Rabita Trust employees and officers who

simultaneously worked for Saudi Arabia in another capacity, often as employees of a Saudi

171
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 24 of 26

Arabia Embassy or other Saudi Arabia agency, and who in turn reported on a day-to-day basis to

even more senior employees and officers of Saudi Arabia;

n. MWL, IIRO and Rabita Trust officials and employees received Saudi Arabia

diplomatic passports and traveled in the name of and as representatives of Saudi Arabia;

o. the employees and officers of the MWL, IIRO and Rabita Trust considered

themselves to be employees and officers of Saudi Arabia subject to the exclusive control of

Saudi Arabia;

p. an MWL employee and Director of IIRO in Canada, testified in 1999 that the

MWL "is a fully government funded organization" and that "[i]n other words,Iwork for the

government of Saudi Arabia" and "am an employee of that government...."; that "the IIRO is the

relief branch of that organization [the MWL] which means that we are controlled in all of our

activities and plans by the government of Saudi Arabia..."; and, that the MWL and IIRO "has to

abide by the policy of the Government of Saudi Arabia..." and that "[i]f anybody deviates from

that, he would be fired; he would not work at all with IIRO or with the [MWL]...";

q. Saudi Arabia gave the employees of the MWL, IIRO and Rabita Trust the same

protections and privileges that it provided to its own employees working abroad;

r. Saudi Arabia's Embassies paid the salaries of MWL and IIRO employees and/or

had the MWL and IIRO pay the salaries of the employees of Saudi Arabia's embassies;

s. the MWL, IIRO and Rabita Trust shared offices that were provided by Saudi

Arabia, at locations chosen by Saudi Arabia, including but not limited to offices located inside

Saudi Arabia's embassies around the world, and, as an example, an MWL office in Pakistan

operated from the Saudi Arabia Ministry of Islamic Affairs office at the Saudi Embassy;

172
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 25 of 26

t. Saudi Arabia's Embassy bank accounts held the funds of the MWL and IIRO,

commingled Saudi Arabia's Embassy funds with the funds of the MWL and IIRO and used

Saudi Arabia Embassy bank accounts to receive and disburse MWL and IIRO funds;

u. Saudi Arabia's Embassies made purchasing decisions for the MWL and IIRO;

v. Saudi Arabia's Embassies provided the MWL and IIRO with supplies and

equipment and/or had the MWL and IIRO provide Saudi embassies with supplies and

equipment;

w. Saudi Arabia's Embassy officials reviewed and determined whether or not to

grant funding applications made by third parties to the MWL and IIRO;

x. Saudi Arabia's Embassy officials mediated disputes between the MWL and IIRO

and other Saudi Arabia charity organizations;

y. Saudi Arabia's Embassy officials contacted and lobbied foreign governments on

behalf of the MWL and IIRO and their employees, including allowing the MWL and IIRO to

maintain their presence in foreign countries, legal disputes and obtaining diplomatic license

plates;

z. Saudi Arabia authorized the MWL to provide loans to Saudi Arabia's Embassy

staff;

aa. the MWL had official Saudi Arabia clearance to view classified Saudi Arabia

documents from the Saudi Arabia Council of Ministers; and

bb. such additional facts as set forth herein or that may be determined through further

investigation and discovery.

47. At all relevant times prior to and on September 11, 2001, WAMY and BIF were

each part of Saudi Arabia, alter-egos of Saudi Arabia and/or agents of Saudi Arabia, and it would

173
 Case 1:17-cv-02003 Document 1-5 Filed 03/20/17 Page 26 of 26

work a fraud or injustice to regard them as legal entities separate from Saudi Arabia, as

evidenced by the following:

a. from its inception in 1972, WAMY was established and operated by Saudi Arabia

pursuant to a Royal Decree of Saudi Arabia;

b. BIF was established as a part of WAMY in 1987 and WAMY funded the

operations of BIF and had the power to hire and fire BIF employees;

c. the day-to-day operations of WAMY and BIF were subject to the control and

direction of Saudi Arabia's Ministry of Islamic Affairs, Embassies and top ranking officials;

d. the existence of WAMY and BIF were subject to the ongoing approval of Saudi

Arabia and could be terminated at any time by Saudi Arabia;

e. the annual budget of WAMY and BIF was funded by Saudi Arabia, and Mutaz

Saleh Abu Unuq, Financial Director of WAMY, confirmed in a 2003 affidavit that he reviewed

WAMY's finances from 1994 through and including September 11, 2001, and stated that Saudi

Arabia funded "a large portion" of WAMY's budget, including but not limited to grants to

WAMY from the Saudi Arabia Ministry of Finance upon the recommendation of the Saudi

Arabia Supreme Council of Islamic Affairs;

f. WAMY and BIF were governed by WAMY's President and that position was

held by Saudi Arabia's Minister of Islamic Affairs, including from 1999 through and including

September 11, 2001, when Saleh bin Abdulaziz Al Ash-Shaikh, simultaneously acted for Saudi

Arabia as WAMY's President and as Saudi Arabia's Minister of Islamic Affairs;

g. Saudi Arabia's Minister of Islamic Affairs and WAMY's President Saleh bin

Abdulaziz Al Ash-Shaikh described WAMY as a "public" charity of Saudi Arabia.

174
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 1 of 20

h. Saudi Arabia appointed WAMY's President, Secretary General and members of

WAMY's General Assembly, who, together with WAMY's President, directed WAMY and BIF;

i. WAMY and BIF received directions from and sought the approval of Saudi

Arabia's King, Minister of Islamic Affairs and other senior officials of Saudi Arabia regarding

all aspects of their operations, including but not limited to finances, personnel, donations,

funding, travel and project decisions, such as:

i. from 1999 through and including September 11, 2001, WAMY's

President was Saudi Arabia's Minister of Islamic Affairs;

ii. in February 2000, WAMY's Secretary General confirmed to the Saudi

government that WAMY operated in accordance with the instructions of Saudi Arabia's
Minister for Islamic Affairs;

iii. WAMY's annual report was submitted to and reviewed by a top ranking
official of Saudi Arabia;

iv. A top ranking official of Saudi Arabia instructed WAMY to provide

university placement for specific foreign students;

v. Saudi Arabia's Ministry of Islamic Affairs selected and appointed

WAMY's overseas employees;

vi. Saudi Arabia's Ministry of Islamic Affairs directed WAMY to provide

assistance to specific mosques and Islamic centers;

j. all of the officers of WAMY and BIF were appointed by Saudi Arabia and many

of those officers hold other positions as officials with Saudi Arabia, including but not limited to

Dr. Maneh el Johani, WAMY's Secretary General from 1987 through and including September

11, 2001, who also served as a member of Saudi Arabia's Shura Council and head of its Islamic

Affairs Committee and Abdullah Naseef, WAMY's vice-chairman and Vice-Chairman of the

Shura Council (who, as set forth herein, met with and assisted Osama Bin Laden to establish al

Qaeda);

175
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 2 of 20

k. employees of WAMY and BIF employees were simultaneously employed by

Saudi Arabia in another capacity, as employees of a Saudi Arabia Embassy or other Saudi Arabia

agency, and reported on a day-to-day basis to more senior employees and officers of Saudi

Arabia, for example, Abdullah bin Laden, Osama Bin Laden's nephew and Saudi Arabia's

Administrative Officer of its United States Embassy for nearly a decade, was at the same time

the Head of WAMY's branch office in the United States;

1. lower level employees of WAMY and BIF reported on a day-to-day basis to more

senior WAMY and BIF employees and officers who simultaneously worked for Saudi Arabia in

another capacity, as employees of a Saudi Arabia Embassy or other Saudi Arabia agency, and

who in turn reported on a day-to-day basis to even more senior employees and officers of Saudi

Arabia;

m. employees and officials of WAMY received Saudi Arabia diplomatic passports

and traveled in the name of and as representatives of Saudi Arabia;

n. employees and officers of WAMY and BIF considered themselves to be

employees and officers of Saudi Arabia subject to the exclusive control of Saudi Arabia;

o. Saudi Arabia gave the employees of WAMY and BIF the same protections and

privileges that it provided to its own employees working abroad;

p SaudiArabia's U.S. Embassy paid the salaries of WAMY employees, including

for example Abdullah Bin Laden and Mohamed Faris;

q. the offices of WAMY and BIF were provided by Saudi Arabia, at locations

chosen by Saudi Arabia, including but not limited to offices inside Saudi Arabia's embassies

around the world;

176
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 3 of 20

r. Saudi Arabia's Embassy bank accounts held the funds of the WAMY,

commingled Saudi Arabia's Embassy funds with the funds of the WAMY and used Saudi Arabia

Embassy bank accounts to receive and disburse WAMY funds;

s. Saudi Arabia's Embassies provided WAMY and BIF with supplies, services and

equipment and/or had WAMY and BIF provide Saudi Arabia's embassies with supplies, services

and equipment; and

t. such additional facts as set forth herein or that may be determined through further

investigation and discovery.

48. At all relevant times prior to and on September 11, 2001, the AHIF was part of

Saudi Arabia, an alter-ego of Saudi Arabia and/or an agent of Saudi Arabia, and it would work a

fraud or injustice to regard it as a legal entity separate from Saudi Arabia, as evidenced by the

following:

a. in 1988-89, Wael Jelaidan, then the Director of Saudi Arabia's SRC's Pakistan

office, directed an SRC employee, Aqeel Abdulaziz al Aqeel, to create the AHIF in Quetta,

Pakistan as a division of Saudi Arabia's SRC, and the AHIF was established as a division of the

SRC; in 1992 the AHIF established its headquarters office in Saudi Arabia's capital, Riyadh,

under the official patronage of a top ranking Saudi Arabia official and Saleh bin Abdulaziz Al

Ash-Shaikh, who was later appointed as Deputy and then Minister of Islamic Affairs;

b. AHIF was governed by AHIF's Chairman and that position was held by Saudi

Arabia's Minister of Islamic Affairs, including from 1999 through and including September 11,

2001, when Saleh bin Abdulaziz Al Ash-Shaikh simultaneously held positions for Saudi Arabia

as AHIF's Chairman and as Saudi Arabia's Minister of Islamic Affairs;

177
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 4 of 20

c. Saudi Arabia's Ministry of Islamic Affairs appoints AHIF's Board of Directors,

General Director and senior management; according to the affidavit testimony of AHIF's

Financial and Administrative Manager, Khalid bin Obaid Azzahri, "[AHIF] operates under the

supervision of the Saudi Minister of Islamic Affairs, who appoints its Board of Directors and

senior management personnel";

d. AHIF's General Director from AHIF's inception through and including

September 11, 2001, Aqeel Abdulaziz al Aqeel, confirmed that "we work under the supervision

of Saudi government" and U.S. government investigations showed that at least two Saudi Arabia

ministers supervised AHIF;

e. the annual budget of AHIF was funded by Saudi Arabia, and AHIF's General

Director Al Aqeel acknowledged that more than 95% of AHIF's funding came directly from

Saudi Arabia;

f. the day-to-day operations of AHIF were subject to the control and direction of

Saudi Arabia's Ministry of Islamic Affairs and Embassies;

g. the existence of AHIF was subject to the ongoing approval of Saudi Arabia and

could be terminated at any time by Saudi Arabia, and in or around June 2004 Saudi Arabia made

the decision to terminate AHIF and Saudi Arabia retained the assets of AHIF as its own;

h. AHIF received directions from and sought the approval of Saudi Arabia's King,

Minister of Islamic Affairs, Ministry of Islamic Affairs, the Islamic Affairs Bureaus within Saudi

Arabia's Embassies and other officials of Saudi Arabia regarding all aspects of their operations,

including but not limited to personnel decisions, finances, bank accounts, funding, travel and

project decisions;

178
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 5 of 20

i. many of AHIF's officers and employees held other positions as officials with

Saudi Arabia, including its Chairman, its accountant at AHIF's headquarters, Abdulaziz al

Shoumar, and AHIF's officer and President of its U.S. branch, Soliman al Buthe, and reported on

a day-to-day basis to more senior employees and officers of Saudi Arabia;

j. lower level employees of AHIF reported on a day-to-day basis to more senior

AHIF employees and officers who simultaneously worked for Saudi Arabia in another capacity,

often as employees of a Saudi Arabia Embassy or other Saudi Arabia agency, and who in turn

reported on a day-to-day basis to even more senior employees and officers of Saudi Arabia;

k. offices of the AHIF were provided by Saudi Arabia, at locations chosen by Saudi

Arabia, including but not limited to offices inside Saudi Arabia's embassies around the world

and at Saudi Arabia's embassies and the Ministry of Islamic Affairs, where the AHIF's

Administrative Board operated;

1. Saudi Arabia's embassies provided AHIF with supplies, services and equipment

and/or had AHIF provide Saudi Arabia's embassies with supplies, services and equipment;

m. employees of AHIF deemed themselves employees of Saudi Arabia bound to

follow policies and dictates set by Saudi Arabia;

n. after Saudi Arabia withdrew its Ambassador from the Saudi Arabia Embassy in

Kabul, Afghanistan, the Director of the AHIF in Afghanistan was instructed to take possession of

that Embassy, and the AHIF occupied that Embassy, as described herein;

o. Saudi Arabia Embassy officials offered to conceal AHIF documents from law

enforcement agencies; and

P. such additional facts as set forth herein or that may be determined through further

investigation and discovery.

179
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 6 of 20

49. At all relevant times prior to and on September 11, 2001, the SHC was part of

Saudi Arabia, an alter-ego of Saudi Arabia and/or an agent of Saudi Arabia, and it would work a

fraud or injustice to regard it as a legal entity separate from Saudi Arabia, as evidenced by the

following:

a. in a pleading previously filed before this Court, the SHC specifically asserted that

it was immune from suit because of its status as a foreign sovereign, namely Saudi Arabia;

b. according to affidavit testimony of the Minister of State of the Council of

Ministers of Saudi Arabia, Dr. Mutlib bin Abdullah al Nafissa, the SHC "is an arm of the Saudi

Arabian government" and "[a]ctions taken by the SHC properly are viewed as actions of the

Government of Saudi Arabia...";

c. according to affidavit testimony of Saud bin Mohammad al Roshood, Director of

the Executive Office of the SHC, the SHC was created by a decision of the President of the

Council of Ministers of Saudi Arabia, has been continuously headed by Prince (now King)

Salman, and SHC's Executive Committee and Supreme Commission of the SHC include Saudi

Arabia officials;

d. the Director of the SHC was a Saudi Arabia employee and member of the Saudi

Arabia civil service and reported to other Saudi Arabia employees;

e. Saudi Arabia provided all of the funding to operate the SHC; all of the fund

raising of the SHC was sanctioned by Saudi Arabia; and, Saudi Arabia was the largest source of

charity funding for the SHC;

f. the existence of the SHC was subject to the ongoing approval of Saudi Arabia and

could be terminated at any time by Saudi Arabia;

g. Saudi Arabia decided the recipients and amounts of grants made by the SHC;

180
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 7 of 20

h. employees of SHC were considered to be employees of Saudi Arabia and

members of the civil service of Saudi Arabia and deemed themselves employees of Saudi Arabia

bound to follow policies and dictates set by Saudi Arabia;

i. the SHC was staffed with civil servant employees of Saudi Arabia detailed from

other Saudi Arabia ministries and administrative organs, and such employees were paid by their

respective ministries and administrative organs, rather than by the SHC; and

j. such additional facts as set forth herein or that may be determined through further

investigation and discovery.

50. At all relevant times prior to and on September 11, 2001, the SJRC was part of

Saudi Arabia, an alter-ego of Saudi Arabia and/or an agent of Saudi Arabia, and it would work a

fraud or injustice to regard it as a legal entity separate from Saudi Arabia, as evidenced by the

following:

a. in a pleading previously filed before this Court, the SJRC specifically asserted

that it was immune from suit because of its status as a foreign sovereign, namely Saudi Arabia;

b. Dr. Abdulrahman al Swailem, President of the SJRC, provided affidavit testimony

that the SJRC was created in 1999 pursuant to a High Order issued by the King of Saudi Arabia

upon the recommendation of the Council of Ministers of Saudi Arabia and has "always

functioned as a political subdivision, agency, or instrumentality of the Kingdom of Saudi

Arabia";

c. the SJRC and its component organizations, the MWL, IIRO, WAMY, AHIF and

SRC, was directed and controlled by Saudi Arabia's Minister of Interior together with other high

ranking representatives of Saudi Arabia's Ministries;

d. Saudi Arabia provided all of SJRC's funding;

181
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 8 of 20

e. the existence of the SJRC was subject to the ongoing approval of Saudi Arabia

and could be terminated at any time by Saudi Arabia;

f. employees of SJRC were considered to be employees of Saudi Arabia and

deemed themselves employees of Saudi Arabia bound to follow policies and dictates set by

Saudi Arabia; and

g. such additional facts as set forth herein or that may be determined through further

investigation and discovery.

51. At all relevant times prior to and on September 11, 2001, the SRC was part of

Saudi Arabia, an alter-ego of Saudi Arabia and/or an agent of Saudi Arabia, and it would work a

fraud or injustice to regard it as a legal entity separate from Saudi Arabia, as evidenced by the

following:

a. in a pleading previously filed before this Court, the SRC specifically asserted that

it was immune from suit because of its status as a foreign sovereign, namely Saudi Arabia;

b. Abdulrahman al Swailem, President of the Saudi Arabian Red Crescent Society,

testified that he was appointed by Royal Order of Saudi Arabia's King, that he holds "Excellency

level status within the Saudi Arabian Government", and that Saudi Arabia "sponsors and

supervises the [SRC], and... appoints all of its directors."

c. the SRC requires that the directors of the SRC include members of Saudi Arabia's

Council of Ministers;

d. Saudi Arabia provided all of the SRC's funding;

e. the existence of the SRC was subject to the ongoing approval of Saudi Arabia and

could be terminated at any time by Saudi Arabia;

182
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 9 of 20

f. employees of SRC were considered to be employees of Saudi Arabia and deemed

themselves employees of Saudi Arabia bound to follow policies and dictates set by Saudi Arabia;

and

g- such additional facts as set forth herein or that may be determined through further

investigation and discovery.

FIRST CAUSE OF ACTION TO RECOVER

PERSONAL INJURY AND WRONGFUL DEATH DAMAGES
PURSUANT TO THE JASTA AND THE ANTI-TERRORISM ACT

52. Plaintiffs repeat and reallege all of the preceding paragraphs as if fully set forth

herein.

53. This action is brought pursuant to 18 U.S.C. 2333(a) for the injuries and deaths

suffered by U.S. nationals in the September 11th Attacks.

54. Those attacks constituted acts of international terrorism pursuant to 18 U.S.C.

2331 that violated federal and state laws against murder, kidnapping, assault and aircraft

hijacking, including but not limited to 18 U.S.C. 2332b (prohibiting terrorist acts of kidnapping,

assault and murder) and 49 U.S.C. 46502 (prohibiting aircraft hijacking), and at the time those

acts were committed, planned and authorized, al Qaeda was designated as a Foreign Terrorist

Organization under section 219 of the Immigration and Nationality Act, 8 U.S.C. 1189.

55. Pursuant to 18 U.S.C. 2333(a), (d), Saudi Arabia aided and abetted al Qaeda

through numerous acts detailed herein by knowingly providing it with substantial assistance to

prepare and carry out an act or acts of international terrorism.

56. Pursuant to 18 U.S.C. 2333(a), (d), Saudi Arabia conspired with al Qaeda and

others to provide it with substantial material support and resources, with the shared

183
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 10 of 20

understanding, knowledge and intent that said support and resources would be used by al Qaeda

to prepare and carry out an act or acts of international terrorism.

57. The others in the conspiracy currently known to plaintiffs are named herein, and

include Saudi Arabia's officials, employees and agents, Saudi Arabia's charity organizations,

Osama Bin Laden and al Qaeda operatives; the names of additional persons involved in the

conspiracy await discovery and further investigation.

58. Pursuant to 2333(a), Saudi Arabia committed an act or acts of international

terrorism, as defined in 18 U.S.C. 2331(1)(A), in violation of federal and state criminal laws, or

that would have been a criminal violation if committed within the United States or any state,

including but not limited to a violation of the following:

18 U.S.C. 2(a) Aiding, abetting, counseling, commanding, inducing or procuring a

federal crime;
18 U.S.C. 371 Conspiring to commit a federal crime;
18 U.S.C. 2332 Conspiring to attempt to kill or kill a U.S. national;
18 U.S.C. 2332a Conspiring to use a weapon of mass destruction;
18 U.S.C. 2332b Conspiring to commit an act of terrorism;
18 U.S.C. 2339A - Providing material support to terrorists;
18 U.S.C. 2339B - Providing material support or resources to designated foreign
terrorist organizations;
18 U.S.C. 2339C - Prohibitions against the financing of terrorism;
49 U.S.C. 46502 Conspiring to commit aircraft piracy;
N.J.S.A. 2C:2-6 Accomplice liability;
N.Y. Penal Law 20.00 - Criminal liability for conduct of another;
N.Y. Penal Law 115.00 - Criminal facilitation in the fourth degree;
Mass. Gen. Laws ch. 274, 2 Accessory or aiding in the commission of a felony;
18 Pa. C.S. 306 Accomplice liability; and
Va. Code Ann. 18.2-18 Accessory before the fact.

59. The Kingdom of Saudi Arabia's conduct amounted to a violation of 18 U.S.C.

2(a) because Saudi Arabia intentionally aided, abetted and counseled the commission of a

criminal act or acts of international terrorism by al Qaeda, including its hijackers and other

operatives, by providing the terrorist organization with material support, resources and funding

184
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 11 of 20

with the knowledge that al Qaeda would use such assistance to prepare for and commit such a

criminal act or acts.

60. Saudi Arabia's conduct amounted to a violation of 18 U.S.C. 371 because it

conspired with al Qaeda and others to provide it with substantial material support and resources

with the shared understanding, knowledge and intent that said support and resources would be

used by al Qaeda to prepare for and carry out a criminal act or acts of international terrorism.

61. Saudi Arabia's conduct amounted to a violation of 18 U.S.C. 2339A in that on

and prior to September 11, 2001, it provided material support or resources for al Qaeda and/or

conspired with al Qaeda and others to provide material support or resources for al Qaeda, with

the knowledge or intent that they would be used in preparation for, or in carrying out a violation

of the statutes specified in 18 U.S.C. 2339A, including 18 U.S.C. 2332b (prohibiting terrorist

acts of kidnapping, assault and murder) and 49 U.S.C. 46502 (prohibiting aircraft hijacking).

62. Saudi Arabia's conduct amounted to a violation of 18 U.S.C. 2339A in that on

and prior to September 11, 2001, it concealed or disguised the nature, location, source, or

ownership of al Qaeda's material support or resources and/or conspired with Saudi Arabia's

employees and agents, Saudi Arabia's charity organizations, al Qaeda, al Qaeda operatives and

sympathizers and others, known and unknown, to conceal or disguise the nature, location, source

or ownership of al Qaeda's material support or resources, with the knowledge or intent that they

would be used in preparation for, or in carrying out a violation of the statutes specified in 18

U.S.C. 2339A, including 18 U.S.C. 2332b (prohibiting terrorist acts of kidnapping, assault and

murder) and 49 U.S.C. 46502 (prohibiting aircraft hijacking).

63. Saudi Arabia's conduct amounted to a violation of 18 U.S.C. 2339B in that on

and prior to September 11, 2001, it knowingly provided material support or resources to al

185
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 12 of 20

Qaeda, and/or Saudi Arabia conspired to knowingly provide material support or resources to al

Qaeda with Saudi Arabia's employees and agents, Saudi Arabia's charity organizations, al

Qaeda, al Qaeda operatives and sympathizers and/or others, known and unknown, with the

knowledge that al Qaeda was a designated Foreign Terrorist Organization, has engaged or

engages in terrorist activity or has engaged or engages in terrorism.

64. Saudi Arabia's conduct amounted to a violation of 18 U.S.C. 2339C in that on

and prior to September 11, 2001, as detailed within, it provided or collected funds for al Qaeda

and/or conspired with Saudi Arabia's employees and agents, Saudi Arabia's charity

organizations, al Qaeda, al Qaeda operatives and sympathizers and others, known and unknown,

to provide or collect funds for al Qaeda, with the intention that such funds be used, or with the

knowledge that such funds were to be used, in full or in part, to carry out an act or acts of

international terrorism.

65. Saudi Arabia's conduct amounted to a violation of relevant state criminal laws on

facilitating, aiding and abetting a crime, and conspiracy, including but not limited to those cited

above, in that it:

a. intentionally aided, abetted and counseled al Qaeda by providing it with material

support, resources and funding with the knowledge that al Qaeda would use such assistance to

commit an act or acts of international terrorism; and/or

b. believing it was probably rendering aid in the form of material support or

resources and funds to al Qaeda to engage in a crime, provided al Qaeda with the means or

opportunity for the commission thereof and which in fact aided al Qaeda to commit the

September 11th Attacks; and/or

186
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 13 of 20

c. conspired with Saudi Arabia's employees and agents, Saudi Arabia's charity

organizations, al Qaeda, al Qaeda operatives and sympathizers and others known and unknown,

to violate relevant state criminal laws on facilitating and aiding and abetting a crime and

committing an act or acts of terrorism, including assault, hijacking, kidnapping and murder.

66. As detailed herein, the aforesaid act or acts of international terrorism:

a. involve a violent act or acts dangerous to human life, as demonstrated by the

known and foreseeable outcomes of injury and death resulting from providing substantial

assistance to al Qaeda terrorists;

b. were committed primarily outside the territorial jurisdiction of the United States

and also transcended national boundaries in terms of the means by which they were

accomplished, the persons they appear intended to intimidate or coerce, and the locales in which

their perpetrators operated; and

c. appeared to be intended to intimidate or coerce a civilian population; to influence

the policy of a government by intimidation or coercion; or, to affect the conduct of a government

by mass destruction, kidnapping or assassination.

67. The aforesaid acts of Saudi Arabia were not mere negligence, but each act

individually and/or in combination with one or more acts, constituted conduct that was

intentional, reckless, willful and/or grossly negligent and each of those acts individually and/or

in combination with one or more of those acts was a proximate cause of the September 11th

Attacks and the resulting injuries and deaths of plaintiffs' decedents.

68. The September 11th Attacks could not have occurred absent the knowing and

substantial assistance provided to al Qaeda by Saudi Arabia and those attacks and resulting

187
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 14 of 20

injuries and deaths were a natural, probable and reasonably foreseeable consequence of Saudi

Arabia's conduct.

69. As a result, the Kingdom of Saudi Arabia is liable to plaintiffs for all damages

resulting from the injuries and deaths in the September 11th Attacks.

70. Plaintiffs, the surviving family members of each decedent, the decedents and their

Estates have suffered and will continue to suffer past and future damages as a result of the

injuries and deaths sustained in the September 11th Attacks, including but not limited to:

personal injury damages, wrongful death damages, survival damages, economic damages,

pecuniary loss, non-economic damages, pain and suffering, torture, imprisonment, kidnapping,

fear of impending death, physical trauma, mental anguish, mental distress, grief, loss of

enjoyment of life, loss of earnings, financial support, services, companionship, care, guidance,

consortium, solatium, burial costs, medical and other expenses and other provable damages

allowed by law.

WHEREFORE, plaintiffs pray that judgment(s) for relief in the form of an award or

awards of monetary damages for personal injury, wrongful death, all recoverable losses under 28

U.S.C. 2333 and other appropriate relief be entered on their first cause of action in favor of the

plaintiffs individually and as estate representatives and against the defendant Kingdom of Saudi

Arabia, with separate awards for each plaintiff, where appropriate, plus interest, costs, punitive

damages, treble damages, attorney's fees, and such other relief as the Court deems just and

proper.

SECOND CAUSE OF ACTION FOR PERSONAL INJURY AND

WRONGFUL DEATH DAMAGES PURSUANT TO STATE TORT LAW

188
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 15 of 20

71. Plaintiffs repeat and reallege all of the preceding paragraphs as if fully set forth

herein.

72. On March 10, 2004, a class action complaint seeking damages for a class defined

as the spouses, children, parents, siblings and legal representatives of those individuals killed in

the September 11th Attacks (excluding the 19 hijackers) was timely filed against the Kingdom of

Saudi Arabia under the caption, O'Neill v. Kingdom of Saudi Arabia, et al, 04-CV-01922 (GBD),

and the O'Neill case currently remains pending before this Court.

73. O'Neill asserted state tort law claims against the Kingdom of Saudi Arabia for

causing the deaths of plaintiffs' decedents in the September 11th Attacks, including claims for

wrongful death, survival, aiding and abetting, conspiracy and negligence, including intentional,

knowing, reckless, willful, wanton, grossly negligent and/or negligent tortious acts and

omissions.

74. Plaintiffs herein include members of the class defined in O'Neill, but to date no

determination regarding class certification has been made by this Court.

75. This cause of action is brought before that determination and plaintiffs present

these state tort law claims to assert and protect their rights to pursue such claims, for example, in

the event that the O'Neill class is not certified by this Court.

76. Pursuant to the doctrine first declared by the Supreme Court in American Pipe &

Construction Co. v. Utah, 414 U.S. 538 (1974), the time for plaintiffs who are members of the

O 'Neill class to bring their state law claims has been tolled from the date the O'Neill action was

brought until this Court makes its determination on class certification.

77. For years prior to and including September 11, 2001, Saudi Arabia: participated

and associated with al Qaeda in its terrorist agenda as set forth herein; provided al Qaeda and its

189
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 16 of 20

hijackers with substantial material support, financing and resources; knew that it was assisting a

terrorist organization that had conducted and was actively planning attacks against the United

States; and committed tortious acts and omissions that were intentional, knowing, reckless,

willful, wanton, grossly negligent and/or negligent.

78. Saudi Arabia's conduct was a proximate cause of the deaths, injuries and resulting

damages suffered by plaintiffs, as it furnished the essential support networks, cover and funding

used by al Qaeda to successfully plan and execute the September llth Attacks.

79. Saudi Arabia tortiously aided and abetted al Qaeda by providing substantial

assistance in the form of funding, support and resources to al Qaeda and its hijackers with the

knowledge that they planned to use such assistance to prepare for and conduct terrorist attacks

against the United States and its citizens and/or with reckless disregard of the known probable

risk that such assistance would be used for those terrorist purposes.

80. Saudi Arabia tortiously conspired with al Qaeda and others to provide al Qaeda

and its hijackers with substantial material support and resources, with the shared agreement,

understanding, knowledge and intent that said support and resources would be used by al Qaeda

to plan and carry out terrorist acts against the United States.

81. For years prior to and including September 11, 2001, Saudi Arabia knew that its

officers, employees and agents and Saudi Arabia's charitable organizations were engaging in

illegal and/or criminal activity by using Saudi Arabia's offices, equipment and other resources to

provide substantial material support and resources to al Qaeda and, that Saudi Arabia's officers,

employees and agents, including but not limited to Adel Batterjee, Wael Jelaidan. Soliman al

Buthe, Aqeel al Aqeel, Abdelhamid al Mujil, Enaam Arnaout, Fahad al Thumairy, Omar al

Bayoumi, Omar Abdi Mohamed, Osama Basnan, Hamdan Shalawi, Mohamed al Qudhaieen,

190
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 17 of 20

Mohamed al Fakihi and others were al Qaeda operatives or sympathizers who were using their

government positions to provide substantial assistance to al Qaeda.

82. Despite such knowledge, Saudi Arabia intentionally and/or recklessly failed to

properly supervise its officers, employees and agents and Saudi Arabia's charitable organizations

to stop them from using Saudi Arabia's offices, equipment and other resources to provide

substantial assistance to al Qaeda despite the known and/or foreseeable risk that such assistance

was being used by al Qaeda to prepare and conduct a terrorist attack against the United States

and its citizens.

83. Moreover, Saudi Arabia intentionally and/or recklessly selected, hired and

retained as its officers, employees and agents various individuals, including Adel Batterjee, Wael

Jelaidan. Soliman al Buthe, Aqeel al Aqeel, Abdelhamid al Mujil, Enaam Arnaout, Fahad al

Thumairy, Omar al Bayoumi, Omar Abdi Mohamed, Osama Basnan, Hamdan Shalawi,

Mohamed Qudhaieen, Mohamed Fakihi and others, who Saudi Arabia knew were al Qaeda

operatives or sympathizers, despite the known and/or foreseeable risk that those employees and

agents would use and/or were using their government positions to provide substantial assistance

to al Qaeda to prepare and conduct a terrorist attack against the United States and its citizens.

84. The aforesaid intentional, criminal, knowing, reckless, willful, wanton, grossly

negligent and/or negligent acts and/or omissions of Saudi Arabia were individually and/or in

combination with one or more of those acts and/or omissions a proximate, substantial cause of

the September 11th Attacks and the plaintiffs' injuries, deaths and resulting damages.

WHEREFORE, plaintiffs pray that judgment(s) for relief in the form of an award or

awards of monetary damages for personal injury, wrongful death and other appropriate relief be

entered on their second cause of action in favor of the plaintiffs individually and as estate

191
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 18 of 20

representatives and against the defendant Kingdom of Saudi Arabia, with separate awards for

each plaintiff, where appropriate, plus interest, costs, punitive damages, treble damages,

attorney's fees, and such other relief as the Court deems just and proper.

THIRD CAUSE OF ACTION FOR

PERSONAL INJURY AND WRONGFUL DEATH
DAMAGES PURSUANT TO THE ALIEN TORT CLAIMS ACT

85. Plaintiffs repeat and reallege all of the preceding paragraphs as if fully set forth

herein.

86. O'Neill asserted claims under the Alien Tort Claims Act against the Kingdom of

Saudi Arabia for causing the deaths of plaintiffs' decedents in the September 11th Attacks based

on violations of international law resulting in injury and death in the September 11th Attacks.

87. Plaintiffs herein include members of the class defined in O'Neill, but to date no

determination regarding class certification has been made by this Court.

88. This cause of action is brought before that determination and plaintiffs present

these Alien Tort Claims Act claims to assert and protect their rights to pursue such claims, for

example, in the event that the O'Neill class is not certified by this Court.

89. The Alien Tort Claims Act, 28 U.S.C. 1350, allows aliens to sue for torts

committed in violation of the law of nations, international law or a treaty of the United States.

90. The conduct of Saudi Arabia as detailed herein to provide substantial material

support, resources and sponsorship for al Qaeda and its acts of international terrorism resulting in

the September llth Attacks constitutes a clear violation of the law of nations and international

law, which includes international legal norms prohibiting crimes against humanity, mass murder,

genocide, torture, extrajudicial killing, air piracy, financing of terrorism, and terrorism, which

192
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 19 of 20

can be found in and derived from, among other things, the following conventions, agreements,

U.N. declarations and resolutions, and other documents:

(1) Charter of the International Military Tribunal, Aug. 8, 1945, 59 Stat. 1544, 82
U.N.T.S. 279;
(2) Allied Control Council Law No. 10 (Dec. 20, 1945);
(3) Convention on the Prevention and Punishment of the Crime of Genocide, Dec. 9
1948, 78 U.N.T.S. 277;
(4) Geneva Convention (IV) Relative to the Protection of Civilian Persons in Time of
War, Aug. 12, 1949, 75 U.N.T.S. 287;
(5) Hague Convention for the Suppression of Unlawful Seizure of Aircraft (Hijacking),
Dec. 16, 1970, 22 U.S.T. 1641, 860 U.N.T.S. 105;
(6) International Convention for the Suppression of Terrorist Bombings, Dec. 15, 1997,
2149 U.N.T.S. 284 (entered into force May 23, 2001);
(7) International Convention for the Suppression of the Financing of Terrorism, Dec. 9,
1999, 2178 U.N.T.S. 229 (entered into force Apr. 10, 2002);
(8) U.N. Security Council Resolution 1267, U.N. Doc. S/RES/1267 (Oct. 15, 1999);
(9) U.N. Security Council Resolution 1373, U.N. Doc. S/RES/1373 (Sept. 28, 2001);
(10) Protocol Additional (I) to the Geneva Conventions of 12 August 1949, and Relating
to the Protection of Victims of International Armed Conflict, June 8, 1977, 1125
U.N.T.S. 3;
(11) Protocol Additional (II) to the Geneva Conventions of 12 August 1949, and Relating
to the Protection of Victims of Non-International Armed Conflicts, June 8, 1977,
1125 U.N.T.S. 609;
(12) Statute of the International Criminal Tribunal for the Former Yugoslavia (ICTY), in
Report of the Secretary-General pursuant to paragraph 2 of S.C. Res.808, May 3,
1993, U.N. Doc. 8/25704, adopted unanimously by S.C. Res. 827, U.N. SCOR, 48th
Sess., 3217th mtg., 16, U.N. Doc. S/PV.3217 (1993);
(13) The Convention on the Prevention and Punishment of Crimes Against International
Protected Persons, Including Diplomatic Agents, 28 U.S.T. 1975, T.I.A.S. No. 8532
(1977), implemented in 18 U.S.C. 1121;
(14) The General Assembly Resolutions on Measures to Prevent International Terrorism,
G.A. Res. 40/61 (1985) and G.A. Res. 42/159 (1987); and
(15) The Convention on the High Seas, April 29, 1958, arts. 14-22 (piracy), 13 U.S.T.
2312, 450 U.N.T.S. 11.

91. Saudi Arabia's conduct was a substantial cause of the September 11th Attacks and

the plaintiffs' injuries, deaths and resulting damages.

WHEREFORE, plaintiffs pray that judgment(s) for relief in the form of an award or

awards of monetary damages for personal injury, wrongful death and other appropriate relief be

entered on their third cause of action in favor of the plaintiffs individually and as estate

193
 Case 1:17-cv-02003 Document 1-6 Filed 03/20/17 Page 20 of 20

representatives and against the defendant Kingdom of Saudi Arabia, with separate awards for

each plaintiff, where appropriate, plus interest, costs, punitive damages, treble damages,

attorney's fees, and such other relief as the Court deems just and proper.

Dated: New York, New York

March 17, 2017

KREINDLER & KREINDLER LLP

By: /s/ James P. Kreindler

James P. Kreindler (JK7084)
Justin T. Green (JG0318)
Andrew J. Maloney, III (AM8684)
Steven R. Pounian (SP5795)
750 Third Avenue
New York, NY 10017
(212) 687-8181
(212) 972-9432 (Fax)

Barasch McGarry Salzman Penson & Lim

Michael Barasch, Esq.
11 Park Place, Suite 1801
New York, NY 10007
(212) 385-8000
(212) 385-7845 (fax)

Baumeister and Samuels, P.C.

Michel Baumeister, Esq.
One Exchange Plaza
New York, NY 10006
(212) 363-1200
(212) 363-1346 (fax)

Speiser Krause
Frank Granito, Esq.
800 Westchester Avenue, Suite S-608
Rye Brook, New York 10573
(914) 220-5333

Jonathan C. Reiter Law Firm PLLC

Jonathan C. Reiter, Esq.
350 Fifth Avenue, Suite 6400
New York, NY 10118
(212) 244-2000

194