A005537

ADL
Anti-Defamation League

December 13, 2001

Kenneth L. Zwick, Director
Office of Management Programs
U.S. Department of Justice
Civil Division
Main Building, Room 3140
950 Pennsylvania Avenue, NW
Washington, DC 20530

Re: September 11 Victim Compensation Program

Dear Mr. Zwick:

We write in response to the Department's November 5, 2001 request for public comments regarding the Department's forthcoming regulations for implementing and administering the "September 11 Victim Compensation Fund" (the "Fund") established by the Air Transportation Safety and System Stabilization Act ("the Act"). The Fund was created to compensate all those injured in the attack and all the surviving relatives of those who died.

We urge the Department to promulgate regulations that provide aid to all surviving family members, including committed partners and non-biological children of gay and lesbian victims. The terrorist who perpetrated this terrible act made no distinctions amongst their victims, nor should the United States. Simply, we argue that the regulations should define who is awarded aid based on the reality of their loss not the legal status of their family.

It is clear that the Act intended the Fund to compensate all those who suffered specific, enumerated types of economic harm. These include burial costs, loss of earnings, physical and emotional pain and suffering. See 402(5) and 402(7). The Act does not distinguish amongst family type or marital status and neither should the Department of Justice.

Now is a time when America must draw together to help all those who need aid and protection following the devastation of September 11. We have been united in the face of terror and we must remain so. No American family, however constituted, should be excluded. We hope the regulations promulgated by the Department will reflect that belief.

Best regards,

Comment by:
Anti-Defamation League
New York, NY

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