The 259-page complaint, modeled after a case against the Libyan government over the 1988 in-flight bombing of Pan Am Flight 103, seeks to freeze and recover assets of those who have bankrolled Bin Laden's Al-Qaida network.

The lead plaintiffs in the suit are Thomas and Beverly Burnett of Northfield, Minn., whose son, Thomas Burnett Jr., was among the passengers who overpowered hijackers and forced the crash of United Airlines Flight 93 in Pennsylvania before it could hit the White House or U.S. Capitol.

Thomas Burnett Sr., a retired Richfield High School teacher, said he instigated the suit late last year because he was determined to find a way to "get those rotten people."

South Carolina attorney Ron Motley, who is spearheading the 15-count suit, said it targets more institutions than those pursued by the U.S. Treasury Department, which since Sept. 11 has frozen more than $100 million in assets of businesses, charities and individuals allegedly linked to terrorism.

The nearly 100 defendants in the suit include figures and entities in Saudi Arabia, which the administration considers a strategic U.S. ally.

While the Bush administration has delicately managed its relationship with Saudi Arabia, Motley declared: "That kingdom sponsors terrorism. . . . It pays so-called martyrs to kill people."

The suit alleges that "Saudi money has for years been funneled to encourage radical anti-Americanism, as well as to fund the Al-Qaida terrorists."

A spokesman for Saudi Arabia's embassy could not be reached for comment.

Joined by more than 30 family members at a news conference to announce the filing of the suit in federal court in Washington, Motley said it also will allow families of many of the thousands of victims "to ventilate - to publicly air the facts as we learn them."

Burnett, his son's widow, Deena Burnett of Little Rock, Ark., and several others choked back tears as they shared their grief and motives for signing onto the suit.

"We will move terrorist financing schemes out of the shadows and into the light of day," said Burnett, 72. "We will expose for the world the shady underbelly behind the atrocities of 9/11, leaving those with evil intentions nowhere to hide and no place to escape accountability."

Recalling his son's final words in a parting cell phone conversation with his wife, Burnett said, "Today, we're going to do something."

Financiers `more wrong'

Matt Sellitto, whose 23-year-old son was among nearly 700 employees of the bond-trading firm of Cantor Fitzgerald who died in the World Trade Center, said the financiers "are more wrong" than the terrorists.

They "have the blood of my son on their hands, and the blood of more than 3,000 irreplaceable people on their hands," he said.

The suit says it seeks to respond "to this act of barbarism . . . with the collective voice of civilization."

Motley, who is nationally known for his legal triumphs over the asbestos and tobacco industries, said the suit will focus first on the alleged financiers' U.S. assets.

He said the case was aided by intelligence services from France and four other foreign governments, but with no help from the Justice Department. Motley is being assisted by Allan Gerson, who broke legal ground in pursuing the Libya case, a consortium of 10 law firms and Jean-Charles Brisard, who wrote exhaustively on the Bin Laden financial network for the French Parliament.

While the suit does not name the Saudi government, it names as defendants Saudi princes Muhammad al-Faisal; Turki al-Faisal, the former Saudi intelligence chief; and Sultan bin Abdul Aziz al Saud, the Saudi defense minister who also chairs Saudi Arabian Airlines, which does business in the United States. It also names Khalid bin Salim bin Mahfouz of the Saudi-based National Commercial Bank, the Faisal Islamic Bank and a web of banks, charities and individuals in several countries, many with alleged ties to terrorists.

The suit alleges that in 1995, under Turki, the Saudi Secret Services decided to give a large amount of financial support to the Taliban radical Islamic movement in Afghanistan and Pakistan. Citing a "nonpublished French intelligence report," it says that Saudi princes and business leaders met in Paris in 1996 and agreed to continue sponsoring Bin Laden's network.

And in July 1998, it says, at a meeting attended by Turki in Kandahar, Afghanistan, a deal was cut: Bin Laden and his followers would not subvert the Saudi government and, in return, the Saudis would "provide oil and generous financial assistance" to the Taliban in Afghanistan and Pakistan. After the meeting, the suit says, 400 new pickup trucks bearing Saudi license plates arrived in Kandahar for the Taliban.

Since 1994, it alleges, Sultan has donated at least $6 million to Islamic charities that were sponsoring Bin Laden and Al-Qaida.

Motley noted that in the hours after the Sept. 11 attacks, members of the Bin Laden family were whisked out of the United States while all air traffic was grounded.

"My point is that they are protected by the Bush administration," Motley said. Asked why, he replied: "Oil."

"I give not a damn what George Bush thinks about this lawsuit," he said, noting that Bush "may find himself being deposed" over an investment he accepted in his Texas oil business from Saudi banker Mahfouz.

A White House spokesman offered no response to Motley's remarks.

The suit also names:

- The Al-Rajhi Banking & Investment Corp., a Saudi Arabian bank that allegedly funneled money to several Islamic terrorist groups and held an account for one of the Sept. 11 hijackers. Several members of the Al-Rajhi family hold U.S. investments in the giant Al-Watania Poultry, Mar-Jac Poultry, Inc., Mar-Jac Investments, Inc., and Piedmont Poultry, it says.

- Al-Barakaat Exchange LLC, a money-transfer operation based in Dubai, United Arab Emirates, which the suit calls a conduit to Bin Laden. The Treasury Department shut down the firm's offices in the Twin Cities and four other U.S. cities last year.

- A long list of charities as "fronts for terror," including Al-Haramain, which the Treasury Department has called a terrorist group. The Treasury Department has said Al-Haramain's Somalia office funneled money to the alleged terrorist group Al-Itihaad al-Islamiya, disguising the funds as "intended for orphanage projects or Islamic school and mosque construction," the suit said.

Gerson, a George Washington University law professor, said the suit is more than an academic exercise, noting that settlement negotiations have gone on for months in the Pan Am 103 case. He said the Tripoli government offered $2.7 billion to families of the 270 people killed in the blast over Lockerbie, Scotland, but attached conditions that the United States and United Nations end sanctions against Libya.

Gerson predicted that many of those targeted in the Sept. 11 suit will hire lawyers and defend the case in court.

He recalled that when the judge in the Libya case asked whether Moammar Gadhafi's Libyan government would pay if it lost the case, lawyers for the Arab nation said: "Of course. We're not going to make a charade out of U.S. justice."

"We expect these people to do the same thing," Gerson said. "If they don't pay, they're going to get hurt themselves, because they have business interests in the United States, and they'll never be able to do business again in the United States, and probably Europe."

Motley said that after he was first contacted by Thomas Burnett Sr., he flew to San Francisco last December to meet with the family and quickly resolved to "get head-over-heels involved."

"I was just so compelled by their story of Tom Burnett's heroism," Motley said. "They just have such courage and conviction."

Burnett predicted success because "we have justice and morality on our side."

The suit also includes as plaintiffs the sisters of Thomas Burnett Jr., Mary Jurgens and Martha O'Brien, and was filed on behalf of his estate and his three daughters.

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- Greg Gordon is at ggordon@mcclatchydc.com.

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THE ALLEGATIONS

- That Saudi princes agreed to fund Osama bin Laden and the Taliban, while Bin Laden agreed not to subvert the Saudi government.

- That charitable and financial institutions, including Al-Barakaat Exchange LLC, a United Arab Emirates-based money transfer firm, funnel money to Bin Laden. U.S. officials shut down its operations in several cities, including Minneapolis, last fall.

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WHAT'S NEXT

- Sept. 11 survivors and victims' families hope to freeze and then recover damages from Saudi and other groups' assets in the United States.

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BURNETT FAMILY STATEMENT

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Statement by Thomas Burnett, of Northfield, Minn., at Thursday's news conference:

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"Our son, Thomas E. Burnett Jr., was a hero on Flight 93. He was drafted unknowingly as one of the first citizen soldiers in the war on terrorism, and he served his country with calm, with decisiveness, with leadership and with courage. Thanks to the extraordinary character shown by him and his fellow passengers, hundreds and perhaps thousands of lives were saved in Washington, D.C.

"It is with Tom's leadership, courage and patriotism in mind that I stand here to announce that my wife and I, along with many other family members and survivors of September 11th, are taking unprecedented legal action against those whose money financed the unspeakable evil that occurred on that tragic day.

"In taking this action, we will move terrorist financing schemes out of the shadows and into the light of day, exposing for the world the underbelly behind the atrocities of 9/11 and leaving those with evil intentions nowhere to hide and no place to escape accountability.

"We will succeed because we have the facts and the law on our side, because we have an unparalleled legal and investigative team representing the best talent and expertise in the area of international law and finance on our side. And because we have justice and morality on our side.

"Nothing could be a greater tribute to Tom's memory. Tom's last words were, `We're going to do something.' And today we are doing something."