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A screenshot of a scanned legal filing document — page 1 of a federal court motion. Header in blue text reads case metadata; below is the court caption block naming the parties, followed by the motion title and body text of the first paragraph.

Text in image: Case 1:25-cv-04316-RJL Document 79 Filed 04/27/26 Page 1 of 9 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA NATIONAL TRUST FOR HISTORIC PRESERVATION, Plaintiff, v. Case No. 1:25-cv-04316-RJL NATIONAL PARK SERVICE, et al., Defendants. DEFENDANTS' RULE 62.1 MOTION FOR AN INDICATIVE RULING DISSOLVING THE COURT'S INJUNCTION "The National Trust for Historic Preservation" is a beautiful name, but even their name is FAKE because when they add the words "in the United States" to the National Trust for Preservation, it makes it sound like a Governmental Agency, which it is not. In fact, the United States refused to continue funding it in 2005 because they strongly disagreed with their mission and objectives. They are very bad for our Country. They stop many projects that are worthy, and hurt many others. In this case, they are trying to stop one that is vital to our National Security, and the Safety of all Presidents of the United States, both current and future, their families, staff, and Cabinet members. They were asked by the United States Military not to bring this suit because of the Top Secret nature of the important facility being built. They were shown detailed plans and specifications of this knitted, unified, and cohesive structure by Top Officers and Leaders in both the Military and Secret Service. But this did not deter them because they suffer from Trump Derangement Syndrome, commonly referred to as TDS, as noted by Democrat Senator John Fetterman, of Pennsylvania, and are represented by the lawyer for Barack Hussein Obama, Gregory Craig. The lower section of the building does not work without the upper section and, likewise, the upper section of the building does not work without the lower. It is all one highly 1

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A screenshot of a page from a court filing document. The header reads "Case 1:25-cv-04316-RJL Document 79 Filed 04/27/26 Page 2 of 9" in blue text. The body is a legal brief paragraph describing a building's integrated systems (venting, electrical, plumbing, security, HVAC, elevator, structural steel/concrete, bulletproof windows, drone-proof roof), arguing these would have prevented a described assassination attempt at the Washington Hilton during a White House Correspondents' Dinner, referencing prior attempts including one in Butler, Pennsylvania where a bullet hit "the President's ear." It argues for dissolving a court injunction blocking a construction project, disputing standing of "a woman walking her dog" to oppose it, and notes defendants asked "the Trust" whether it opposes the motion, which it does. Page number "2" appears at bottom center.

Text in image: Case 1:25-cv-04316-RJL Document 79 Filed 04/27/26 Page 2 of 9 integrated unit! As an example, one venting system, one electrical system, one plumbing system, one security system, one air conditioning and heating system, one elevator connector and, very importantly, one structural steel and enforced concrete system — and more. Even the bullet proof windows and glass, and the heavy steel, drone proof roof, protect what is below. With such a facility, it would have been impossible for an attack like that which took place last Saturday evening in D.C. when an attempted assassin, armed with a shotgun, pistol, and knives, charged through a security checkpoint at the Washington Hilton in an attempt to assassinate President Donald J. Trump, First Lady Melania Trump, and members of the President's Cabinet and senior staff, during the White House Correspondents' Dinner. The Secret Service fortunately neutralized the assassin before he could reach the ballroom. However, Saturday's narrow miss—which marks the third assassination attempt on President Trump since 2024—confirms what should have already been obvious: Presidents need a secure space for large events, that currently does not exist in Washington, D.C., and this Court's injunction stalling this Project cannot defensibly continue, for the sake of the safety of President Trump, future Presidents, and their families, Cabinets, and staff. Defendants thus request that this Court issue an indicative ruling under Rule 62.1 that it will dissolve its injunction. Three assassination attempts—including the attempt in Butler, Pennsylvania, where an assassin's bullet hit the President's ear—is enough. There is absolutely no argument that a woman walking her dog in the vicinity of the White House has STANDING to stop such a desperately needed structure for the people of the United States of America, as it will provide Presidents, current and future, a secure space to do their jobs. The day after this assassination attempt, Defendants asked the Trust whether they oppose this motion and still seek to stop this Project by continuing their dangerous lawsuit. The "Trust" refused to heed their request, and responded that it opposes this motion. 2

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A scanned page from a legal court filing. The header reads "Case 1:25-cv-04316-RJL Document 79 Filed 04/27/26 Page 3 of 9" and the page is numbered "3" at the bottom. The body text is numbered paragraphs 1 and 2 of what appears to be a legal brief/motion, discussing an appeal of a preliminary injunction related to "the Project," citing Federal Rule of Civil Procedure 62.1 and case law (Coinbase, Inc. v. Bielski; Amarin Pharms. Ir. Ltd. v. FDA; Index Newspapers LLC v. City of Portland). Paragraph 2 describes an assassination attempt in which an "assassin" traveled by train with firearms and knives intending to kill "the President," "the First Lady," and senior administration officials, citing a New York Post article about a "White House Correspondents' Dinner suspect Cole Allen's full anti-Trump manifesto." The text describes the suspect identifying the WHCD as his "first real opportunity" to target the President, and claims he checked into the Washington Hilton as a guest and bragged about walking in with multiple weapons.

Text in image: Case 1:25-cv-04316-RJL Document 79 Filed 04/27/26 Page 3 of 9 1. Defendants have appealed this Court's preliminary injunction regarding the Project. ECF 74. That appeal divests this Court of jurisdiction over its injunction. See Coinbase, Inc. v. Bielski, 599 U.S. 736, 740 (2023). Even so, Federal Rule of Civil Procedure 62.1 provides that "[i]f a timely motion is made for relief that the court lacks authority to grant because of an appeal that has been docketed and is pending, the court may … state either that it would grant the motion if the court of appeals remands for that purpose or that the motion raises a substantial issue." Fed. R. Civ. P. 62.1(a)(3). An indicative ruling is especially appropriate where it would "obviat[e] the need for the appeal." Amarin Pharms. Ir. Ltd. v. FDA, 139 F. Supp. 3d 437, 447 (D.D.C. 2015). To that end, where, as here, a change in circumstances warrants dissolving the underlying injunction on appeal, that is a paradigmatic example of when a district court should issue such a ruling. See, e.g., Index Newspapers LLC v. City of Portland, 2022 WL 72124, at *1 (D. Ore. 2022). 2. Earlier this week, an assassin traveled by train across the Country with multiple firearms and knives planning to kill the President, the First Lady, and senior ranking officials within the Administration. See Steven Nelson and Chris Nesi, Read White House Correspondents' Dinner suspect Cole Allen's full anti-Trump manifesto, New York Post (Apr. 26, 2026), https://nypost.com/2026/04/26/us-news/read-whcd-gunman-cole-allens-full-anti-trump-manifesto. The timing was not coincidental: as stated in his "sprawling manifesto," the assassin identified the White House Correspondents' Dinner as his "first real opportunity" to target the President. Id. That is so, because the assassin understood what Defendants have been saying for months: The President lacks a secure space for large events. The Washington Hilton is no exception. Indeed, the assassin himself seems to have bragged that he was able to check into the hotel as a guest, and "walk in with multiple weapons" without anyone dealing with him as a "threat." Id. Further, he believed that come Saturday, he would be able to exploit the venue's

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A scanned page from a legal court filing (page 4 of 9). The header reads "Case 1:25-cv-04316-RJL Document 79 Filed 04/27/26 Page 4 of 9". The body text is legal argument discussing an assassination attempt, referencing a "Quinn Decl." (declaration by U.S. Secret Service Deputy Director Quinn) describing how an assailant ran through a security checkpoint and opened fire on a Secret Service agent before being apprehended, and citing constraints of off-site venues versus proposed security improvements at the White House Complex, including construction of a fortified structure with missile-resistant steel columns, military-grade venting, drone-proof ceilings, and bullet/ballistic/blast-proof glass, along with bomb shelters and medical facilities. Page number "4" is printed at the bottom center.

Text in image: Case 1:25-cv-04316-RJL Document 79 Filed 04/27/26 Page 4 of 9 security defects, and make his way up to the President—willing to "go through most everyone [there] to get to" him. Id. The assassin came horrifically close, as U.S. Secret Service Deputy Director Quinn's declaration ("Quinn Decl.," attached) explains. During the event, the assassin was able to run through a security checkpoint and open fire on a Secret Service agent, before he was apprehended. Quinn Decl. ¶¶ 6-7. While the Secret Service was able to be as effective as realistically possible that night, "as demonstrated by the prompt apprehension" of the assassin, they were nonetheless limited by the "inherent constraints" that come with available "off-site venues" that are outside the White House Complex, such as a hotel with more than a thousand rooms like the Washington Hilton. Id. ¶¶ 8-10. By contrast, having events at the White House Complex will allow for major improvements in safety, and significantly increase the ability of the Secret Service to protect the President and guests from threats. Id. ¶¶ 11-14. As the undisputed evidence demonstrates, the Project is required for National Security. It will shield the now-exposed East Room of the Executive Mansion and provide best in class, modern security to the President and his family, his Cabinet, his staff, and visitors. This "fixed structure"—constructed using "threat-resistant materials" including missile resistant steel columns, Military-grade venting, drone-proof ceilings, and bullet, ballistic, and blast proof glass—will form "a fortified structural buffer" protecting "both the main White House and West Wing." Third Quinn Decl. ¶ 10. Together, the ballroom and secure facilities throughout the Project—bomb shelters, a state of the art hospital and medical facilities, Top Secret military installations, structures, and equipment, protective partitioning, and other features—are a single integrated, complex unit that is vital for the National Security of the United States. Id. This Project will ensure that events like the horrific attack on Saturday night do not happen again. See Quinn Decl. 4

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