1) “Transportation Security Administration (TSA) be served with [have prior access to] all requests for party and non-party discovery,”
2) “defendants and non-parties submit all proposed discovery responses that may contain ‘sensitive security information’ (SSI) to the TSA prior to releasing such material to plaintiffs,” and
3) “TSA have the necessary opportunity to review such material and to withhold ‘sensitive security information’ ” [from victim-family attorneys].

One victim family plaintiff - speaking off the record - told Scoop Media that family members and their attorneys have not yet sought internal memos, electronic mail, facsimiles, and documents which would shed public light upon what had to be extraordinary legal maneuverings. However, added high stakes related to the publicly undisclosed contents of the controversial August 6, 2001 Presidential intelligence briefing prior to the attacks, and a secret July, 2001 FBI memo -- said to be "50 times more significant than the August 6 briefing," by a Congressional investigator (New York Times, 5-18-2002), will only serve to heighten the importance of the June 20 letter.