Ground Zero

A Sea of Paper

By David Horrigan

BEFORE September 11, 2001, when most people thought of the World Trade Center, they thought money -- brokers, traders, investment analysts. All that changed at 8:45 a.m. and 9:03 a.m. E.D.T.

Within minutes, the ground itself bore witness to the reality that this place also was home to the legal community -- lawyers, paralegals, legal secretaries, and other professionals working in New York City's two towering icons. The tools of their trades -- pleadings, interrogatories, legal memoranda, and legal research printouts -- snowed to the streets. The two towers were no more.

Within the hour, American Lawyer Media pooled all available editorial personnel to cover the story. From our midtown offices, Monica Bay and I were sent downtown to find lawyers.

We walked because the streets were now the province of vehicles with sirens. Approaching the intersection of Park Place and Church Street, we saw firefighters try to save 7 World Trade Center. The area was eeriely quiet and calm.

As Monica shot photos, I stood in a sea of documents and began to take notes. I noticed a sheet of letterhead from Fried, Frank, Harris, Shriver & Jacobson, where my law school classmate, Angela Grinstead, worked. I was glad she had been transferred to the firm's London office, especially when I noticed an empty woman's shoe.

We wondered how so many documents remained intact. An answer came from my friend, Renée Mangalo, an associate with Pattison & Flannery. As she escaped from the attack (breaking a bone in the process), she noticed the papers before the towers collapsed. The impact of the planes shattered windows; many papers flew away before the implosions.

A medical corporation's charred and ripped S.E.C. Form 10-K may have been from a broker, but a lawyer reviewed it. A paralegal probably obtained some of the data. A legal secretary may have typed it. An office services staff member most likely made sure the copies were collated.

Some documents, once urgent, were not so urgent anymore. A law firm's fax was marked, "RUSH." A deposit slip for a payroll account was ready for the bank.

Then there were the Lexis and Westlaw printouts. I thought about the many times I had rushed to a partner's office, marking these printouts at the last minute.

But these printouts were different. They came from a computer that now blew through the wind as ash, a printer on which we may have been standing, and a file that no longer existed.

As for the partner for whom these documents were intended -- and the associate or law clerk who researched and found them -- we could only hope that they had left these erstwhile important things behind and made it out alive.

We found remnants of pleadings. One insisted that an opposing party's testimony was "nothing more than the rankest of speculation." Another was damaged so badly that all that could be deciphered was that the author believed the opposing party's conduct violated Connecticut's unfair trade laws.

David Horrigan at Park Place and Church St.

I visualized once-combatant lawyers crossing paths in smoke-filled stairwells, saying, "If we make it out of here alive, let's grab a drink and settle this damn thing." Priorities change.

A Consent to Change Attorney form, for the Supreme Court in Queens, blew through the air. I thought about calling the lawyer; but I looked around at the mountains of paper, the snow banks of soot, and the burned buses. This counselor had more pressing problems.

A briefcase found its way into a trashcan. It was hinged -- the type used by trial lawyers, airline pilots and college debate teams. We hoped that its owner was healthy enough to be concerned about its loss.

Other items at the intersection could have come from any firm -- a checkbook, a pair of shoes, instructions on how to import to Lotus 1-2-3 and dBASE.

Perhaps the most poignant document was not from a law firm or a broker. It was a single sheet of paper from the Port Authority's offices in the World Trade Center.

Entitled, New York Airport Traffic Flows, it contained a chart of flight paths from LaGuardia, Newark, J.F.K., and Teterboro, making reference to the "complex New York area airspace."

David Horrigan is contributing editor of The National Law Journal and editor of American Lawyer Media's ABC News Trial Bulletin.

Photos by Monica Bay, Sept. 11, 2001, 11 a.m. to 2:30 p.m., most shot at Church St. and Park Place. More photos: www.caseshare.com/groundzero/gz.ppt (Powerpoint file).