Federal defendant indicated within the March 14, 2008 motion that "the identities of the airplanes hijacked in the September 11 attacks was never in question" and that "there were no records generated" responsive to plaintiff's Amended Complaint.

However, plaintiff's complaint specifically sought "documentation revealing the process by which wreckage recovered by defendant, from the aircraft used during the terrorist attacks of September 11, 2001, was positively identified by defendant (with the aid of the National Transportation Safety Board), as belonging to the said aircraft"

As indicated by 2002 public statements offered by Carol Carmody, Vice-Chairman National Transportation Safety Board and Marion C. Blakey, Chairman National Transportation Safety Board, FBI director Robert Mueller requested NTSB assistance with 9/11 aircraft wreckage identification and that the NTSB did perform 9/11 aircraft wreckage identification analysis.

Plaintiff therefore has reasonable cause to believe that federal defendant agency records responsive to plaintiff's request do exist and have been withheld.

"I ... assured FBI Director Mueller that we would assist in any way we could ... he called and said, "Could you send us some people to help find the black boxes and help identify aircraft parts."

"Over 60 Safety Board employees worked around the clock in Virginia, Pennsylvania, New York, and at our headquarters in Washington, D. C., assisting with aircraft parts identification".

Plaintiff believes that an incorrect interpretation by federal defendant of plaintiff's request for responsive agency records has resulted in negative search results.

Plaintiffs request referenced a presumed use of wreckage serial number data as just one possible means of wreckage or "aircraft parts" identification. Plaintiff's reference to a presumed use of serial number data does not represent a parameter by which other identification methods are to be excluded from consideration as being responsive to Plaintiff's complaint.

Such documentation that plaintiff believes to be within the scope of requested records and thus subject to release are:

- Unreleased recorded images (documentation) of all material believed to be or indicated to be aircraft wreckage from each aircraft crash scene and/or any wreckage examination or storage facilities. Recording of such images (documentation) represents a "process by which wreckage recovered by defendant, from the aircraft used during the terrorist attacks of September 11, 2001, was positively identified by defendant."

- Unreleased records regarding the time and location at which each Flight Data Recorder and/or Cockpit Voice Recorder (wreckage) was recovered and "positively identified by defendant".

The terrorist attacks of September 11, 2001 are collectively one of the most significant events in world history. And because of the absence of complete information regarding various aspects of this event, many scenarios contrary to the U.S. government's account of events, have evolved within a large percentage the collective public's imagination.