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nal. One of the military investigators said the F.B.I. was being generous to Blackwater in characterizing any of the killings as justifiable.
Anne E. Tyrrell, a Blackwater spokeswoman, said she would have no comment until the F.B.I. released its findings.
Although investigators are confident of their overall findings, they have been frustrated by problems with evidence that hampered their inquiry. Investigators who arrived more than two weeks after the shooting could not reconstruct the crime scene, a routine step in shooting inquiries in the United States.
Even the total number of fatalities remains uncertain because of the difficulty of piecing together what happened in a chaotic half-hour in a busy square. Moreover, investigators could not rely on videotapes or photographs of the scene, because they were unsure whether bodies or vehicles might have been moved.
Bodies of a number of victims could not be recovered. Metal shell casings recovered from the intersection could not be definitively tied to the shootings because, as one official described it, "The city is littered with brass."
In addition, investigators did not have access to statements taken from Blackwater employees, who had given statements to State Department investigators on the condition that their statements would not be used in any criminal investigation like the one being conducted by the F.B.I.
An earlier case involving Blackwater points to the difficulty the Department of Justice may be facing in deciding whether and how to bring charges in relation to the Sept. 16 shootings. A Blackwater guard, Andrew J. Moonen, is the sole suspect in the shooting on Dec. 24 of a bodyguard to an Iraqi vice president.
Investigators have statements by witnesses, forensic evidence, the weapon involved and a detailed chronology of the events drawn up by military personnel and contractor employees.
But nearly 11 months later, no charges have been brought, and officials said a number of theories had been debated among prosecutors in Washington and Seattle without a resolution of how to proceed in the case.
Mr. Moonen's lawyer, Stewart P. Riley of Seattle, said he had had no discussions about the case with federal prosecutors.
Some lawmakers and legal scholars said the Sept. 16 case dramatized the need to clarify the law governing private armed contractors in a war zone. Workers under contract to the Defense Department are subject to the Military Extraterritorial Jurisdiction Act, or MEJA, but many, including top State Department officials, contend that the law does not apply to companies like Blackwater that work under contract to other government agencies, including the State Department.
Representative Price's bill would extend the MEJA legislation to all contractors operating in war zones. The bill passed the house 389 to 30 last month and is now before the Senate.
He said it cannot be applied retroactively to the Sept. 16 case, but he said that the guards who killed the Iraqis must be brought to justice, under the War Crimes Act or some other law.
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