A scanned page from a legal court filing (Case 1:25-cv-04316-RJL, Document 79-1, page 4 of 6, filed 04/27/26). The page contains numbered paragraphs 12–16 discussing White House Complex security measures, Secret Service screening procedures, and a section titled "THE EAST WING MODERNIZATION PROJECT" describing the purpose of the modernization and the permanent nature of a proposed ballroom structure.
Text in image: Case 1:25-cv-04316-RJL Document 79-1 Filed 04/27/26 Page 4 of 6
12. Facilities at the White House Complex incorporate physical security measures, secure queuing areas, integrated technology, and established procedures that are unique to the Complex and cannot be replicated to the same extent in temporary, off-site settings. The Secret Service conducts this screening at facilities removed from the physical presence of the President and other protectees, purpose-built with standoff, screening technologies, and blast considerations incorporated, unlike the screening areas at public events which are limited by the venue layout and often require screening to take place in less-than-ideal conditions and locations.
13. In addition, the physical environment of the White House Complex allows the Secret Service to manage lines of approach to event spaces, restrict access to critical areas, and coordinate protective operations without having to accommodate unrelated commercial activity, as is the case in a hotel or other public venue.
14. As a result, securing a large event such as the White House Correspondents' Association Dinner on the White House Complex—in a suitable, purpose-built facility—would provide security advantages over securing the same event at an off-site venue.
THE EAST WING MODERNIZATION PROJECT
15. The purpose of the East Wing Modernization Project includes an event space for hosting large-scale official events involving the President and other Secret Service protectees, such as state dinners, diplomatic receptions, and other significant gatherings that now frequently require either the use of off-site venues or the erection of temporary structures—such as tents—on the White House Complex.
16. The ballroom, as presently designed, is a permanent structure—its physical characteristics, such as walls, doors, windows, and service areas, are designed and
4
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Image 2document
Screenshot of a scanned legal court filing document, page 5 of 6, from a case docketed as "Case 1:25-cv-04316-RJL," filed 04/27/26, document 79-1. The page is a numbered declaration (paragraphs 17-20, continuing from an unnumbered paragraph) discussing Secret Service security planning. It covers a permanent secure facility vs. a hotel ballroom or temporary tent, an upcoming State Dinner for King Charles III and Queen Camilla's UK State Visit to be held in the White House East Room, security limitations of temporary tent structures on the White House complex (citing "Prior Declarations" and Quinn Declarations from Jan. 15, 2026 and Apr. 13, 2026), and a new section titled "IMPACT OF THE APRIL 25, 2026 INCIDENT ON SECURITY ASSESSMENT" describing "The attempted attack on the President and other Secret Service protectees, as well as the hundreds of guests, staff, and other personnel at the Washington Hilton on April 25," (text cut off at bottom of page).
Text in image: Case 1:25-cv-04316-RJL Document 79-1 Filed 04/27/26 Page 5 of 6
constructed in accordance with strict security requirements. This is fundamentally different from attempting to adapt a commercial ballroom in a hotel, or a temporary tent structure, to protective needs that were not part of the original design.
UPCOMING STATE DINNER AND TEMPORARY STRUCTURES
17. The United States is actively hosting a State Visit by His Majesty the King of the United Kingdom. As part of that visit, there will be a State Dinner honoring the King and Queen to be held indoors, in the East Room which affords the existing available security infrastructure of the White House complex. (https://www.whitehouse.gov/briefings-statements/2026/04/president-donald-j-trump-and-first-lady-melania-trump-to-welcome-his-majesty-king-charles-the-iii-of-the-united-kingdom-of-great-britain-and-northern-ireland-and-her-majesty-queen-camilla-for-a-state/). This event is expected to be of significant size and prominence and requires careful planning by the Secret Service.
18. As noted in the Prior Declarations, hosting events of this scale in temporary structures, such as large tents erected on the White House Complex, poses additional security challenges. See Jan. 15, 2026 Quinn Decl. ¶ 10; Apr. 13, 2026 Quinn Decl. ¶¶ 9–10.
19. Temporary tents cannot provide the same level of physical protection, structural resilience, and integrated security as a permanent facility designed with protective requirements in mind. The Secret Service must adapt its protective posture to whatever temporary environment is available, often with constrained time to construct, configure, and test the venue and its security features.
IMPACT OF THE APRIL 25, 2026 INCIDENT ON SECURITY ASSESSMENT
20. The attempted attack on the President and other Secret Service protectees, as well as the hundreds of guests, staff, and other personnel at the Washington Hilton on April 25,
5
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Image 3document
This is a scanned page from a court filing document, page 6 of 6, in Case 1:25-cv-04316-RJL, Document 79-1, filed 04/27/26. The page header shows case metadata in blue hyperlink-style text. The body contains the final paragraph of numbered paragraph 20 and all of paragraph 21 from what appears to be a declaration, discussing security risks at off-site presidential events and justifying the "East Wing Modernization Project" as providing a secure venue for large events like the White House Correspondents' Association Dinner. Below the text is a perjury declaration statement, an execution date, a handwritten cursive signature, and a printed signature block identifying the signer as Matthew C. Quinn, Deputy Director, United States Secret Service. Page number "6" appears at the bottom center.
Text in image: Case 1:25-cv-04316-RJL Document 79-1 Filed 04/27/26 Page 6 of 6
2026, highlights the inherent risks and security challenges associated with large-scale events held in off-site, commercial venues that are not owned, designed, and controlled by the United States government for protective purposes. Moreover, a security incident at a Presidential event—even if it does not result in physical harm to any attendees—can cause the event to be canceled, interfering with the President's ability to perform his duties pursuant to Article II of the Constitution.
21. The planned East Wing Modernization Project is a key component of providing a secure environment for the President to fulfill his duties. It would enable the President to host large events, including those that historically have taken place at off-site hotels, such as the White House Correspondents' Association Dinner, in a venue that benefits from all the permanent security infrastructure and access controls of the White House Complex.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on April 27, 2025.
Matthew C. Quinn
Deputy Director
United States Secret Service
6
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Image 4document
A screenshot of a U.S. federal court document — a "[Proposed] Order" filed in the U.S. District Court for the District of Columbia in the case National Trust for Historic Preservation in the United States v. National Park Service, et al. (Case No. 25-cv-04316-RJL). The header shows case filing metadata (Case 1:25-cv-04316-RJL, Document 79-2, Filed 04/27/26, Page 1 of 1). The order states that if the D.C. Circuit Court of Appeals were to remand the case, the Court would dismiss the action to ensure completion of a facility protecting the President, First Lady, Cabinet members, and senior staff for gatherings, and grants the motion. It is signed by Richard J. Leon, United States District Judge (unsigned/typed name only, no handwritten signature visible).
Text in image: Case 1:25-cv-04316-RJL Document 79-2 Filed 04/27/26 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
NATIONAL TRUST FOR HISTORIC
PRESERVATION IN THE UNITED STATES,
)
)
)
Plaintiff, )
)
v. ) Case No. 25-cv-04316-RJL
)
NATIONAL PARK SERVICE, et. al., )
)
Defendants. )
)
[PROPOSED] ORDER
Upon consideration of the Motion of the United States, it is hereby ORDERED that were
the United States Court of Appeals for the District of Columbia Circuit to remand this case to
this Court, given the events of the last 48 hours, the Court would dismiss the instant action to
ensure the completion of a facility that would protect the President, the First Lady, members of
the President's Cabinet and senior staff for gatherings of the same; accordingly it is
ORDERED that the Motion is GRANTED.
________________________
RICHARD J. LEON
United States District Judge
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Post from Truth Social
Image 1 document
A scanned page from a legal court filing (Case 1:25-cv-04316-RJL, Document 79-1, page 4 of 6, filed 04/27/26). The page contains numbered paragraphs 12–16 discussing White House Complex security measures, Secret Service screening procedures, and a section titled "THE EAST WING MODERNIZATION PROJECT" describing the purpose of the modernization and the permanent nature of a proposed ballroom structure.
Text in image: Case 1:25-cv-04316-RJL Document 79-1 Filed 04/27/26 Page 4 of 6 12. Facilities at the White House Complex incorporate physical security measures, secure queuing areas, integrated technology, and established procedures that are unique to the Complex and cannot be replicated to the same extent in temporary, off-site settings. The Secret Service conducts this screening at facilities removed from the physical presence of the President and other protectees, purpose-built with standoff, screening technologies, and blast considerations incorporated, unlike the screening areas at public events which are limited by the venue layout and often require screening to take place in less-than-ideal conditions and locations. 13. In addition, the physical environment of the White House Complex allows the Secret Service to manage lines of approach to event spaces, restrict access to critical areas, and coordinate protective operations without having to accommodate unrelated commercial activity, as is the case in a hotel or other public venue. 14. As a result, securing a large event such as the White House Correspondents' Association Dinner on the White House Complex—in a suitable, purpose-built facility—would provide security advantages over securing the same event at an off-site venue. THE EAST WING MODERNIZATION PROJECT 15. The purpose of the East Wing Modernization Project includes an event space for hosting large-scale official events involving the President and other Secret Service protectees, such as state dinners, diplomatic receptions, and other significant gatherings that now frequently require either the use of off-site venues or the erection of temporary structures—such as tents—on the White House Complex. 16. The ballroom, as presently designed, is a permanent structure—its physical characteristics, such as walls, doors, windows, and service areas, are designed and 4
Described automatically. The words above are a machine's reading of the picture, not Trump's.
Image 2 document
Screenshot of a scanned legal court filing document, page 5 of 6, from a case docketed as "Case 1:25-cv-04316-RJL," filed 04/27/26, document 79-1. The page is a numbered declaration (paragraphs 17-20, continuing from an unnumbered paragraph) discussing Secret Service security planning. It covers a permanent secure facility vs. a hotel ballroom or temporary tent, an upcoming State Dinner for King Charles III and Queen Camilla's UK State Visit to be held in the White House East Room, security limitations of temporary tent structures on the White House complex (citing "Prior Declarations" and Quinn Declarations from Jan. 15, 2026 and Apr. 13, 2026), and a new section titled "IMPACT OF THE APRIL 25, 2026 INCIDENT ON SECURITY ASSESSMENT" describing "The attempted attack on the President and other Secret Service protectees, as well as the hundreds of guests, staff, and other personnel at the Washington Hilton on April 25," (text cut off at bottom of page).
Text in image: Case 1:25-cv-04316-RJL Document 79-1 Filed 04/27/26 Page 5 of 6 constructed in accordance with strict security requirements. This is fundamentally different from attempting to adapt a commercial ballroom in a hotel, or a temporary tent structure, to protective needs that were not part of the original design. UPCOMING STATE DINNER AND TEMPORARY STRUCTURES 17. The United States is actively hosting a State Visit by His Majesty the King of the United Kingdom. As part of that visit, there will be a State Dinner honoring the King and Queen to be held indoors, in the East Room which affords the existing available security infrastructure of the White House complex. (https://www.whitehouse.gov/briefings-statements/2026/04/president-donald-j-trump-and-first-lady-melania-trump-to-welcome-his-majesty-king-charles-the-iii-of-the-united-kingdom-of-great-britain-and-northern-ireland-and-her-majesty-queen-camilla-for-a-state/). This event is expected to be of significant size and prominence and requires careful planning by the Secret Service. 18. As noted in the Prior Declarations, hosting events of this scale in temporary structures, such as large tents erected on the White House Complex, poses additional security challenges. See Jan. 15, 2026 Quinn Decl. ¶ 10; Apr. 13, 2026 Quinn Decl. ¶¶ 9–10. 19. Temporary tents cannot provide the same level of physical protection, structural resilience, and integrated security as a permanent facility designed with protective requirements in mind. The Secret Service must adapt its protective posture to whatever temporary environment is available, often with constrained time to construct, configure, and test the venue and its security features. IMPACT OF THE APRIL 25, 2026 INCIDENT ON SECURITY ASSESSMENT 20. The attempted attack on the President and other Secret Service protectees, as well as the hundreds of guests, staff, and other personnel at the Washington Hilton on April 25, 5
Described automatically. The words above are a machine's reading of the picture, not Trump's.
Image 3 document
This is a scanned page from a court filing document, page 6 of 6, in Case 1:25-cv-04316-RJL, Document 79-1, filed 04/27/26. The page header shows case metadata in blue hyperlink-style text. The body contains the final paragraph of numbered paragraph 20 and all of paragraph 21 from what appears to be a declaration, discussing security risks at off-site presidential events and justifying the "East Wing Modernization Project" as providing a secure venue for large events like the White House Correspondents' Association Dinner. Below the text is a perjury declaration statement, an execution date, a handwritten cursive signature, and a printed signature block identifying the signer as Matthew C. Quinn, Deputy Director, United States Secret Service. Page number "6" appears at the bottom center.
Text in image: Case 1:25-cv-04316-RJL Document 79-1 Filed 04/27/26 Page 6 of 6 2026, highlights the inherent risks and security challenges associated with large-scale events held in off-site, commercial venues that are not owned, designed, and controlled by the United States government for protective purposes. Moreover, a security incident at a Presidential event—even if it does not result in physical harm to any attendees—can cause the event to be canceled, interfering with the President's ability to perform his duties pursuant to Article II of the Constitution. 21. The planned East Wing Modernization Project is a key component of providing a secure environment for the President to fulfill his duties. It would enable the President to host large events, including those that historically have taken place at off-site hotels, such as the White House Correspondents' Association Dinner, in a venue that benefits from all the permanent security infrastructure and access controls of the White House Complex. I declare under penalty of perjury that the foregoing is true and correct. Executed on April 27, 2025. Matthew C. Quinn Deputy Director United States Secret Service 6
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Image 4 document
A screenshot of a U.S. federal court document — a "[Proposed] Order" filed in the U.S. District Court for the District of Columbia in the case National Trust for Historic Preservation in the United States v. National Park Service, et al. (Case No. 25-cv-04316-RJL). The header shows case filing metadata (Case 1:25-cv-04316-RJL, Document 79-2, Filed 04/27/26, Page 1 of 1). The order states that if the D.C. Circuit Court of Appeals were to remand the case, the Court would dismiss the action to ensure completion of a facility protecting the President, First Lady, Cabinet members, and senior staff for gatherings, and grants the motion. It is signed by Richard J. Leon, United States District Judge (unsigned/typed name only, no handwritten signature visible).
Text in image: Case 1:25-cv-04316-RJL Document 79-2 Filed 04/27/26 Page 1 of 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA NATIONAL TRUST FOR HISTORIC PRESERVATION IN THE UNITED STATES, ) ) ) Plaintiff, ) ) v. ) Case No. 25-cv-04316-RJL ) NATIONAL PARK SERVICE, et. al., ) ) Defendants. ) ) [PROPOSED] ORDER Upon consideration of the Motion of the United States, it is hereby ORDERED that were the United States Court of Appeals for the District of Columbia Circuit to remand this case to this Court, given the events of the last 48 hours, the Court would dismiss the instant action to ensure the completion of a facility that would protect the President, the First Lady, members of the President's Cabinet and senior staff for gatherings of the same; accordingly it is ORDERED that the Motion is GRANTED. ________________________ RICHARD J. LEON United States District Judge
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