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This is a scanned/photographed page from a legal court filing — page 5 of 9 of Document 79 in Case 1:25-cv-04316-RJL, filed 04/27/26. It is a legal brief arguing that an assassination attempt against the President ("the attack on Saturday night") proves a court injunction blocking construction of a White House ballroom should be dissolved. The text cites a prior court opinion (ECF 72) that had found no "national security justification" for the ballroom, and argues the attack disproves that finding by showing D.C. lacks a secure space for high-profile events with the line of succession present. It also cites a footnote listing bipartisan public statements of support for the ballroom project from Senators John Fetterman, Tim Sheehy, Lindsey Graham, and Representative Randy Fine, each with an X (Twitter) post quote, date, and a perma.cc archive link.

Text in image: Case 1:25-cv-04316-RJL Document 79 Filed 04/27/26 Page 5 of 9 ¶¶ 15-16, 20-21. 3. The attack confirms that this Court's injunction is intolerable and unsustainable as a matter of equity and Law. In addition to the multiple classified declarations to the contrary, the attack on Saturday night is proof positive that this wrongful injunction should be dissolved. In its most recent opinion, the Court stated that there is no "national security justification" for why a secure ballroom must be constructed "immediately." ECF 72, at 6 (emphasis removed). Those assertions were wrong then, and they are indefensible now. The fact that an assassin came mere seconds from shooting the President—along with his family, the bulk of his Cabinet, his senior staff, and the Washington press corps—lays bare that D.C. does not have a secure space for large high-profile events, or one able to "accommodate an event with the line of succession for the U.S. government."¹ What he did on Saturday night could not have taken place in this new and highly secure facility! After the attack, a bipartisan chorus of legislators, analysts, and media pundits have vocally expressed support for completion of the ballroom project. See, e.g., n.1. This group includes Democrat Senator John Fetterman, and Senator Rand Paul. In addition, in the long and storied history of the White House dating back to 1791, Congress has never dictated or tampered with the zoning, permitting, or architectural aspects of any Project, especially one being given FREE OF CHARGE AS A GIFT TO THE COUNTRY! Without such a location, the President is thus put ¹ Senator John Fetterman (@SenFettermanPA) ("[D]rop the TDS and build the White House ballroom."), X, (Apr. 26, 2026, 9:13 AM), https://perma.cc/FLL3-F6KT; Senator Tim Sheehy (@TimSheehyMT) ("A President of any party should be able to host events in a secure area without attendees worrying about their safety."), X, (Apr. 26, 2026, 3:33 PM), https://perma.cc/5YUE-9HES; Senator Lindsey Graham (@LindseyGrahamSC) ("[The ballroom] will provide adequate security for this president and future presidents for events like the White House Correspondents Diner."), X, (Apr. 26, 2026, 1:04 PM) https://perma.cc/L3NX-LXBS; Representative Randy Fine (@RepFine) ("[T]he lawsuits attempting to stop [the ballroom] …are nonsense."), X, (Apr. 26, 2026, 2:34 PM) https://perma.cc/8SM9-UE44. 5

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A screenshot of page 6 of a federal court filing (Document 79) in Case 1:25-cv-04316-RJL, filed 04/27/26. The page is a legal brief arguing that a court injunction blocking construction of a secure facility (referred to elsewhere as a "ballroom" project) at or near the White House should be dissolved. The text argues the President's safety outweighs a single plaintiff's "visual preference" objections, citing case law including Trump v. United States, National Trust for Historic Preservation in the United States v. NPS, and Winter v. NRDC.

Text in image: Case 1:25-cv-04316-RJL Document 79 Filed 04/27/26 Page 6 of 9 to the choice of risking his safety by attending events in unsecure venues—be it the tents on the White House lawn, or places like the Washington Hilton (which is now home to two attempted presidential assassinations)—or forgoing those events entirely—to the detriment of his constitutional responsibility to "speak[] to and on behalf of the American people," Trump v. United States, 603 U.S. 593, 617-618 (2023). Forcing a President to make such a choice is intolerable, all the more so when one accounts for the supposed "harms" on the other side of the ledger. Once more, the Trust is suing on behalf of a single person who walks her dog in the vicinity of the White House, once a month, and expects to dislike this Project without ever having seen it. ECF 2-3, at 5. A more lopsided balance is inconceivable. See National Trust for Historic Preservation in the United States v. NPS, 2026 WL 980554, at *8 (D.C. Cir. 2026) (Rao, J., dissenting). The "current safety of the President, as well as his family and staff, plainly outweighs future [visual preference] harms to the Trust." Id. That should have doomed this injunction months ago, under on-point Supreme Court precedent. Winter v. NRDC, 555 U.S. 7, 23-24, 33 (2008) (holding injunction unjustified because national-security interests "plainly outweighed" the "plaintiffs' ecological, scientific, and recreational interests in marine mammals"). But the balance of the equities is inescapable now: The passing visual gripes of a wandering pedestrian cannot possibly justify delaying the construction of a secure facility for the President to do his job. On that score, this weekend makes clear why this Court's injunction must be dissolved "immediately." ECF 72, at 6. In its prior opinion, this Court stated that the Defendants would likely not suffer short-term irreparable harm, because a complete ballroom is still "months" or "years" away from being finished. Id. However, that misses the entire point. As Defendants have detailed, and as this weekend painfully confirms, all current and future Presidents need a secure 6

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A scanned/photographed page from a legal court filing, page 7 of 9, with a blue header stamp reading case number, document number, filing date, and page number. The body text is a legal argument (apparently from a brief related to a White House ballroom construction project and an injunction against it) arguing that a court injunction preventing construction should be dissolved, invoking a "Saturday night attempted assassination" as justification, and defending Donald J. Trump by name.

Text in image: Case 1:25-cv-04316-RJL Document 79 Filed 04/27/26 Page 7 of 9 large-event space now. Even if that space cannot be conjured with a finger snap, the injunction "inevitably extends the time during which" the ballroom remains unavailable, and "the President's residence remains less secure." National Trust, 2026 WL 980554, at *7 (Rao, J., dissenting). "Every additional day of White House vulnerability harms the government." Id. That is so, because every additional day of court-manufactured delay is yet another day that the lives of the President, his family, his Cabinet, and his staff, and those of future Presidents, are being subject to avoidable hazard. If any other President had the ability, foresight, or talents necessary, to build this ballroom, which will be one of the greatest, safest, and most secure structures of its kind anywhere in the World, there would never have been a lawsuit. But, because it is DONALD J. TRUMP, a highly successful real estate developer, who has abilities that others don't, especially those who assume the Office of President, this frivolous and meritless lawsuit was filed. Again, it's called TRUMP DERANGEMENT SYNDROME. On top of everything else, this project is a gift to our Country from President Trump, and other Donors. It is free of charge to the American Taxpayer. Who could ever object to that? This Court should never have enjoined this Project, but now, after the Saturday night attempted assassination, which could have never taken place in the new facility, reasonable minds can no longer differ — The injunction must be dissolved. This Court should immediately issue an indicative ruling that it will dissolve the injunction, and put an end to this frivolous lawsuit, which greatly endangers the lives of all Presidents, current and future. 7

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A screenshot of a scanned legal court filing document, page 8 of 9, from a case docketed in a U.S. District Court. The header shows case number, document number, filing date, and page number in blue text. The body is a signature/closing page of a legal brief, listing the submitting date and signature block of DOJ attorneys representing the defendants, including a printed name with "/s/" electronic signature notation, titles, and the U.S. Department of Justice address, email, and phone number. The page number "8" appears centered at the bottom.

Text in image: Case 1:25-cv-04316-RJL Document 79 Filed 04/27/26 Page 8 of 9 Dated: April 27, 2026 Respectfully submitted, TODD BLANCHE Acting Attorney General R. TRENT MCCOTTER Principal Associate Deputy Attorney General /s/ Stanley E. Woodward, Jr. STANLEY E. WOODWARD, JR. Associate Attorney General U.S. Department of Justice 950 Pennsylvania Avenue, N.W. Washington, DC 20530 stanley.woodward@usdoj.gov (202) 514-2000 Counsel for Defendants 8

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