https://911digitalarchive.org/files/original/99c48f5f1f6ccb2a78dcc7e7e1a4cd46.pdf 2ae079ea1821e6f518c580a839155aed PDF Text Text Case 1:21-mc-00101-AKH Document 1473 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------- x : : : : IN RE SEPTEMBER 11 LITIGATION : : : ------------------------------------- x Filed 06/27/11 Page 1 of 4 No. 21 MC 101 (AKH) This document relates to : Bavis v. United Airlines Inc.et al., 02 CV 7154 DECLARATION OF MARY SCHIAVO IN SUPPORT OF PLAINTIFF’S MEMORANDUM OF LAW IN OPPOSITION TO THE MASSACHUSETTS PORT AUTHORITY’S MOTION FOR SUMMARY JUDGMENT MARY SCHIAVO declares as follows: 1. I submit this declaration under 28 U.S.C. §1746 in support of the motion of Plaintiff Mary Bavis on the applicable standard of care. 2. I am a member of Motley Rice LLC which represents Plaintiff Mary Bavis. 3. I attach as Exhibit 1 a copy of excerpts from the transcript of the Deposition of Joseph M. Lawless, dated March 30, 2007. 4. I attach as Exhibit 2 a copy of the Joseph M. Lawless memo to Virginia Buckingham, dated April 27, 2001. 5. I attach as Exhibit 3 a copy of excerpts from the transcript of the Deposition of Thomas J. Kinton, conducted on January 25, 2011. 6. I attach as Exhibit 4 a copy of excerpts from the transcript of the Deposition of Virginia Buckingham Lowey, conducted on December 15, 2006. 7. I attach as Exhibit 5 a copy of the letter from Virginia Buckingham Lowey and Thomas J. Kinton to Chip Barclay, dated September 25, 2001. �Case 1:21-mc-00101-AKH Document 1473 8. Filed 06/27/11 Page 2 of 4 I attach as Exhibit 6 a copy of the Report of the Special Advisory Task Force on Massport, presented to Governor Jane Swift, dated December 04, 2001. 9. I attach as Exhibit 7 a copy of the Federal Aviation Administration’s Recommended Security Guidelines for Airport Planning Design and Construction. 10. I attach as Exhibit 8 AVSEC Dep Exhibit 344, LAMCO Meeting Minutes, dated April 11, 2001, and various other Massport Logan International Airport, Security Consortium Meeting minutes. 11. I attach as Exhibit 9 a copy Counter Technology, Inc.’s Physical Security Assessment: Boston Logan International Airport, dated November 06, 2001. 12. I attach as Exhibit 10 a copy of the letter from Edward C. Freni to Ginny Buckingham, subject: Meeting with United Airlines, dated May 08, 2001. 13. I attach as Exhibit 11 a copy of an e-mail from Barbara Platt to Christopher Doria and Phillip Orlandella, subject: Update, dated Thursday, April 19, 2001. 14. I attach as Exhibit 12 a copy of the Memorandum for the Record, Interview with Joseph Lawless, dated November 05, 2003. 15. I attach as Exhibit 13 the letter from Edward C. Freni to Larry Aldrich, re: Customer Service Standards Program, dated March 02, 2001. 16. I attach as Exhibit 14 a copy of the Memorandum for the Record, Interview with Virginia Buckingham, dated November 05, 2003. 17. I attach as Exhibit 15 a copy of the transcript of the FOX News Report on Logan Airport, dated February, 2001. 2 �Case 1:21-mc-00101-AKH Document 1473 18. Filed 06/27/11 Page 3 of 4 I attach as Exhibit 16 a copy of the letter from Michael A. Canavan to Joseph M. Lawless, dated May 21, 2001 and Joseph M. Lawless’ letter response to Michael A. Canavan, dated June 04, 2001. 19. I attach as Exhibit 17 a copy of the letter from Joseph M. Lawless to Michael A. Canavan, dated June 04, 2001. 20. I attach as Exhibit 18 a copy of the Logan International Airport Terminal Lease between the Massachusetts Port Authority and United Airlines, Inc., dated December 01, 1998. 21. I attach as Exhibit 19 a copy of relevant pages from the Massport Airport Security Program. 22. I attach as Exhibit 20 excerpts of the 9/11 Commission Report. 23. I attach as Exhibit 21 an excerpt of the Security Briefing Agenda, MP103636. 24. I attach as Exhibit 22 a copy of the Federal Bureau of Investigation’s interview of Stephen Wallace, dated September 17, 2001. 25. I attach as Exhibit 23 excerpts from the transcript of the Deposition of Stephen J. Wallace, dated July 17, 2007. 26. I attach as Exhibit 24 a copy of the Federal Bureau of Investigation report on Theresa Spagnuolo, dated September 29, 2001. 27. I attach as Exhibit 25 a copy of excerpts from the transcript of the Deposition of James Miller, Jr., dated May 23, 2008. 28. I attach as Exhibit 26 a copy of “Hijackers’ Ringleaders Scouted out Airports,” Boston Herald, Dave Wedge, dated May 29, 2002. 29. I attach as Exhibit 27 relevant pages of the redacted and non-SSI Checkpoint Operations Guide, Standard Operating Procedures. 3 �Case 1:21-mc-00101-AKH Document 1473 30. Filed 06/27/11 Page 4 of 4 I attach as Exhibit 28 copy of the Memorandum for the Record, Interview with Thomas Kinton, dated November 06, 2003. 31. I attach as Exhibit 29 a collection of letters from Mary Carol Turano to Jack C. Bullard outlining violations of C.F.R. Air Carrier Standard Security Program. 32. I attach as Exhibit 30 an additional copy of excerpts from the transcript of the Deposition of Joseph M. Lawless, dated March 30, 2007. 33. I attach as Exhibit 31 AVSEC Dep Exhibit 221, Public Safety Staff Meeting Minutes, dated April 13, 2001. 34. I attach as Exhibit 32 14 C.F.R. §§107.1 – 107.3, §107.5, §107.9, §107.11, §§107.13 – 107.15, §107.17, §107.19, §107.20, §107.27, §107.29, and §107.31. I declare under penalty of perjury that the foregoing is true and correct. Dated: June 24, 2011 /s/Mary Schiavo__________ Mary Schiavo 4 � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Boston Federal Aviation Administration Filings Subject The topic of the resource litigation airport security Description An account of the resource These court filings provide evidence that the terrorists responsible for the September 11th attacks were observed assessing airport security prior to the events. For example, Mohammed Atta was spotted in May '01 taking still photographs, notes and video of the screening checkpoints at Logan. He was reported to law enforcement at the airport, but they failed to follow up. Contributor An entity responsible for making contributions to the resource Brian Sullivan, FAA Special Agent (Retired) Document A resource containing textual data. Note that facsimiles or images of texts are still of the genre text. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Declaration of Mary Schiavo in Support of Plaintiffs Memorandum of Law in Opposition To the Massachusetts Port Authority's Motion for Summary Judgement Description An account of the resource A Declaration of Mary Schiavo presenting evidence and exhibits on the FAA findings surrounding Boston International Airport before September 11th. This document is a listing of the exhibits presented to the Massachusetts Port Authority. Date A point or period of time associated with an event in the lifecycle of the resource June 27, 2011 Contributor An entity responsible for making contributions to the resource Brian Sullivan Rights Information about rights held in and over the resource Public Domain