N002555

Honeoye Falls, N.Y.
January 21, 2002

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

Dear Mr. Zwick:

We are writing in regard to the September 11th Compensation Fund of 2001. Our son,    , was killed as a result of American Airlines aircraft crashing into the North Tower of the World Trade Center. We believe we understand the rationale, purpose and logic of the creation of the fund. We have read the act, been to several meetings with Kenneth Feinberg, and followed the subject closely in the media. We have several comments regarding the guidelines of the Compensation Fund.

First and foremost, we believe the Airline Transportation Safety Act to be correct action to have taken. With that having been said, there are several ways in which the ruling falls short. We will spare you the horrible details of what our family has been through, as well as families of all the other victims, we're sure, in the greatest tragedy that the United States has suffered in this act of international terrorism. Please do not take those missing details lightly as, even though we are only one family in this international scandal, our son was central in our lives and had already contributed his worth to society albeit his youth.

When Congress enacted the bail out, it was first and foremost for the benefit of the airlines and, secondarily, for the victims' families. In doing so, in effect, it removed any practical means to recover both economic and non-economic loss through any other means, then through the Victims Compensation Fund because of limits on liability. By Kenneth Feinberg's own admissi0on, "This is a classic trade off between administrative speed and efficiency and rolling the dice in court and going for the proverbial pot of gold," as quoted in the N.Y. Times, 12/21/01. With this, we ask you to consider:
1.) Why should these awards be discounted from what would be awarded in an individual lawsuit where there are no liability limitations?

In determining non-economic loss, the special master has determined that $250K plus $50K per survivor is adequate citing that this figure conformed roughly with federal programs that compensate families for military personnel and police officers. This line of thinking is irrational:

2.) Did it ever occur to Mr. Feinberg that the vast number of victims were not firefighters and policemen? Although our son, as well as over 3,000 other victims, died on September 11, 2001, they did not contractually take on jobs to place themselves in the line of fire. Firefighters and police personnel seek employment choosing to place themselves in the line in danger, they are trained with public monies; and, they receive paychecks funded with public monies. Our son and 3000 others were dutifully employed and at their jobs as contracted by their individual employers. These 3,000 individuals never signed up, volunteered, nor were paid to do life threatening jobs. These individuals had no choice in surviving the events of that day. Therefore, we would suggest the non-economic award to be minimally $1 million per individual, similar for compensation paid in other airline disasters. Since this is an out-of-court settlement, documentable evidence is available for other airline out-of-court settlements.

In setting standards for economic loss, Mr. Feinberg has chosen to use national standards. These disasters happened primarily in our nation's largest cities of New York City and Washington, D.C. Therefore,
3.) Why not use standards that apply to big cities where the cost of living is high and commensurate with animal increases that are accelerated well beyond a rural environment? It is not fair, not just, to apply standards to this disaster that don't relate to the circumstances. If the victims fall outside the range of the charts provided, you must go and argue the case thus victimizing the victims. Why should the burden be on the victims? Given documented income levels, the award should be calculated with consistency.

Finally, we feel it unfair for families to walk away with nothing as a result of collateral offsets. There should be a minimum award established regardless of the offsets and there should be consistency in the way the award is granted.

4.) We support the view of     and     as to minimum awards and consistency in granting awards.

Thank you for your consideration.

Sincerely,

Individual Comment
Honeoye Falls, N.Y.

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