CAMPBELL CAMPBELL EDWARDS & CONROY

PROFESSIONAL CORPORATION ONE CONSTITUTION PLAZA THIRD ROOR BOSTON, MASSACHUSETTS 02129 TEL: (617) 241-3000 FAX: (617) 241-5115

CAMPBELL
RICHARD P CAMPBELL (617)241-3061 rpc»mpb«ll@c«mpbell-tii»l-lawyers.com*

April 8, 2004 Via Federal Express Mr. John Raidt National Commission on Terrorist Attacks Upon the United States 301 7th Street SW, Room 5125 Washington, DC 20407 RE: Kean Commission Requests for Information from US Airways

Dear Mr. Raidt: As you know, we serve as counsel for US Airways, Inc. ("US Airways") in the September 11th Litigation and, hi that capacity, we have been asked to assist in the gathering of documents and information requested by the National Commission on Terrorist Attacks Upon the United States (the "Commission"). US Airways received document request No.l on March 8, 2004 and it received a supplemental request for information, via email, on March 11, 2004. As Kathy indicated during your telephone conversation on March 22, 2004, we had forwarded an index of responsive documents to Mr. Straus at the TSA. On March 19th , Mr. Straus contacted us and stated that various screening documents that we had identified contained Sensitive Security Information ("SSI") which the TSA would only authorize us to turn over after a non-disclosure agreement had been executed by the Commission. Mr. Straus further indicated that the non-disclosure agreement, and a letter authorizing the disclosure of these materials after receipt of the executed agreement, would be sent within the next week. Given that the expected turnaround time for the TSA documents was short, you concluded that US Airways should refrain from forwarding the non-SSI documents, and instead, send all of the materials together. At the end of March we received both the form non-disclosure agreement from the TSA and authorization to produce the SSI documents to the Commission upon receipt of executed copies of the agreement. Yesterday, we received the executed non-disclosure agreements and, therefore, US Airways is providing its responses to the Commission's requests. For your convenience, we have provided specific responses to each of the requests and identified the documents responsive to each request, to the extent such documents exist and are in our possession, custody and control.

CONNECTICUT

• MAINE • \S | • NEW HAMPSHIRE • NEW JERSEY • PENNSYLVANIA • RHODE ISLAND

John Raidt April 8, 2004 Page 2 U.S. AIRWAYS DOCUMENT REQUEST NO. 1 1.

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The passenger manifest for Colgan Air Flight No. 5930 on September 11,2001. A copy of the requested manifest is attached hereto and identified as US-Kean-000001.

2.

Documents sufficient to indicate whether Mohammad Atta and/or Abdul Aziz al Omari were designated as "selectees" by U.S. Airways using either the Manual Prescreening or the Computer-Assisted Passenger Prescreening System. US Airways is unable to provide documents sufficient to indicate whether Mohammed Atta and/or Abdul Aziz al Omari were designated as "selectees" by US Airways using either the manual prescreening or the Computer-Assisted Passenger Prescreening System. The Computer Assisted Passenger Prescreening System (CAPPS) was in use by US Airways for domestic travel itineraries on September 11,2001. As required by the program, CAPPS/APPS results must be purged when the customer's PNR is no longer accessible in our computerized reservation system. Since the PNR's for both individuals was purged in accordance with the CAPPS/APPS requirements, that information is no longer available. Further responding, US Airways states that a number of its employees at Portland International Jetport were interviewed by the Federal Bureau of Investigation (FBI) on or about September 11, 2001 and have information on this topic. These individuals, including but not limited to, those individuals listed in response to request no. 6 below, will be made available for interview by US Airways.

3.

Documents sufficient to indicate whether Atta and/or al Omari were subject to security questions or procedures (other than the manual or passive prescreening and checkpoint screening required by the FAA) prior to boarding Colgan Air Flight No. 5930. All US Airways passengers at Portland International Jetport on September 11,2001, would have been subject to the security questions or procedures outlined in the documents which are attached hereto and identified as US-Kean-000002-4. While US Airways does not have any documents to establish whether Atta and/or al Omari were subjected to these security questions or procedures, US Airways refers the Commission to the FBI reports of the interviews of the Portland personnel and its willingness to make these individuals available for interviews. Please note that these documents are copies of US Airways' procedures as they existed on September 11, 2001. These documents were printed from FOCUS, US Airways' electronic reference system. When FOCUS information is updated, Customer Service Systems copies the existing FOCUS "page" before uploading any changes. In September 2001, our process was to print hard copies of the existing page and make a note on that copy of the date it was changed as well as the name of the person who changed it. At the

John Raidt April 8, 2004 PageS

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bottom of each document is an "End of Text" notation followed by a line which includes two dates. The date on the left is the date when the information was originally loaded into FOCUS, while the date on the right is the date when the information was last updated. Finally, as you recall, US Airways sought clarification as to what the Commission was referring to when it used the term "passive prescreening" in this request. It is our understanding that the Commission wanted to determine whether US Airways was using a computerized prescreening system at Portland on September 11,2001. Based on this understanding, US Airways states that it has used computerized APPS (Automated Passenger Profiling System) al all US Airways airports since December, 1998 and, therefore, this computerized APPS would have been effect on September 11,2001 at Portland. 4. Documents sufficient to indicate U.S. Airways' method of handling and screening the checked baggage of "selectees" at Portland International Jetport station, including selectees for Colgan Air Flight No. 5930, including documents indicating whether hand searches of checked luggage were conducted, for prescreening or other purposes, by U.S. Airways at Portland International Jetport. US Airways' method of handling and screening the checked baggage of "selectees" at Portland International Jetport on September 11, 2001 are attached hereto and identified as US-Kean-000005 through US-Kean-000014. These documents are printed from FOCUS as well and, therefore, the comments with respect to US Airways' response to request no. 3 above, are also pertinent here. 5. Documents sufficient to indicate how the checked bags of "selectees" were marked and/or identified as such for handling and screening purposes, including a sample of any bag tags or other markings to provide such identification that were in use on September 11,2001 at Portland International Jetport. Documents describing US Airways' practice and procedure for marking/identifying the checked baggage of "selectees" for handling and screening purposes that were in use on September 11, 2001, including a sample bag tag, are attached hereto and identified as US-Kean-000012 through US-Kean-000015. 6. Documents sufficient to indicate the identity of the ticket agent who checked in Atta and al Omari for Colgan Air Flight No. 5930; the identity of the personnel responsible for screening the checked baggage of selectees for the flight; the identity of the Ground Security Coordinator assigned to the flight; and the identity of the checkpoint supervisor and screening personnel on duty before 6:45 a.m. (EDT) on September 11,2001. We have determined that the identity of the following US Airways' employees:

John Raidt April 8,2004 Page 4

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(a) Michael Tuohey - the ticket agent who checked in Atta and al Omari for Colgan Air Flight No. 5930; and (b) James Dillon and Diane Graney were the two Ground Security Coordinator's on duty at the tune the Colgan Air Flight departed on September 11 . None of these individuals are currently employed by US Airways, however, we have arranged to all of these individuals, as well as Chuck Severance, made available for telephone interviews. US Airways does not have documents which would identify the checkpoint supervisor and screening personnel on duty before 6:45 a.m. (EDT) on September 11, 2001. US Airways was not the lead airline for the security checkpoint at Portland, however, it believes that Globe Aviation Services, Inc. may possess the requested information. 7. Documents sufficient to determine whether the security checkpoint at Portland International Jetport on September 11,2001 possessed explosive trace detection equipment. US Airways was not the lead airline for the security checkpoint at Portland on September 11, 2001 and, therefore, it has no documents that would indicate whether or not the checkpoint possesses explosive trace detection equipment at that time. Supplemental Email Request for Information On March 11,2004, you forwarded, via email, additional requests for information that US Airways has responded to below: 1. The scheduled departure time for US Airways' Flights 29 and 45 which departed from BWI on September 11th. A copy of the document reflecting the scheduled departure of these flights is attached hereto and identified as US-Kean-000016. 2. The on-time departure rating that was posted for US Airways' Flights 29 and 45, which departed from BWI, during the summer of 2001. A copy of the statistical information requested for these flights during the time frame of June 1,2001 to September 11,2001 is attached hereto and identified as US-Kean000017. It is our understanding that the term "D:00" refers to the percent of departures that departued at scheduled depature time or earlier; "D:05" refers to the percent of departures that departed at scheduled depature time plus 5 minutes or earlier; and "A: 14" referes to the percent of arrivals that arrived at the scheduled arrival time plus 14 minutes or earlier.

John Raidt April 8, 2004 Page 5

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Please do not hesitate to contact either me or Kathy should you require any additional information from US Airways. Very truly yours,

Richard P. Campbell KMG:bko Enclosures cc: Kathleen M. Guilfoyle, Esquire

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US - KEAN - 000001

APPS ATO PROCEDURES

AGENT CHECK-IN SEQUENCE - CHECK PASSENGER ID - ASK SECURITY QUESTIONS

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****************QUESTION *HAS ANYONE UNKNOWN TO YOU ASKED YOU TO CARRY ITEM ON THIS FLIGHT*

IF ANSWER TO QUESTION 1 IS *NO*, PROCEED WITH QUESTION 2

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SUSPECT ITEM CLEARANCE ONE OF THE FOLLOWING METHODS AND IN THE FOLLOWING ORDER WILL CLEAR SUSPECT ITEM.

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^QUESTION 2******************** * HAVE ANY OF THE ITEMS YOU ARE TRAVELING WITH * * BEEN OUT OF YOUR IMMEDIATE CONTROL SINCE THE * * TIME YOU PACKED THEM *

US-KEAN-000002

IT*******************************

IF THE ANSWER TO BOTH OF THE SECURITY QUESTIONS IS *NO* / I 9/11 Closed by Statute | TO CONFIRM THAT THE REQUIRED PHOTO ID CHECKS AND SECURITY RELATED QUESTIONS HAVE BEEN COMPLETED.

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US - KEAN - 000003

****************

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NOTE**

U . S . INTERNATIONAL GATEWAY PROCEDURES FOR SELECTEE PASSENGER REMAIN UNCHANGED. SEE FOCUS REFERENCE -F *DPT/APPS/INTL

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US - KEAN - 000004

APPS DOMESTIC SELECTEE CHECKED BAGGAGE WHEN THE DESTINATION OF THE FIRST FLIGHT SEGMENT IS WITHIN THE CONTINENTAL U.S. TERRRITORIES AND AND COMMONWEALTHS SJU/STT/STX THE CHECKED BAGGAGE BELONGING TO A PASSENGER IDENTIFIED AS A SELECTEE SHALL BE CLEARED USING ONE OF THE FOLLOWING PROCEDURES AND IN THIS ORDER

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290CT98

END OF TEXT PIT7MS 05JANOO

US - KEAN - 000005

APPS DOMESTIC SELECTEE CHECKED BAGGAGE POSITIVE BAG MATCH PROCEDURES

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GATE AND RAMP MUST COMMUNICATE CONCERNING STATUS OF SELECTEE BAGS ON EVERY PLIGHT EVERY DAY. THE FOLLOWING PSGR/RAMP SERVICES COMMUNICATION

US - KEAN - 000006

MUST OCCUR BETWEEN THE INSIDE AGENT AND THE ASSIGNED TRIP CREW/AND RAMP AGENT ** CONVERSATION TO LOAD SELECTEE STANDBY BAGS **

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01DEC98

END OF TEXT PIT7MS 26JUN01

US - KEAN - 000007

APPS CTX SERIES X-RAY PROCEDURES

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Closed by Statute

US - KEAN - 000008

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US - KEAN - 000009

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US - KEAN - 000010

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ALWAYS REMEMBER YOUR CUSTOMER SERVICE SKILLS

04NOV99

END OF TEXT PITPSC 09AUGOO

US - KEAN - 000011

APPS INTERRUPT MESSAGE AND REVERSE VIDEO BAG TAG CUSTOMER SERVICE AGENT PROCEDURES
*****************i

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US - KEAN - 000012

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US - KEAN - 000013

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28JULOO

END OF TEXT PIT7MM 20FEB01

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