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Defendants’ renewed motion for partial summary judgment

U.S. District Court for the District of Columbia · 2026-09-18

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Case 1:25-cv-04480-CRC          Document 89        Filed 09/18/26       Page 1 of 3




                      IN THE UNITED STATES DISTRICT COURT
                          FOR THE DISTRICT OF COLUMBIA


 JOYCE BEATTY,

                      Plaintiff,

       v.                                                   Civil Action No. 25-4480 (CRC)

 DONALD J. TRUMP, et al.

                      Defendants.


                        DEFENDANTS’ RENEWED MOTION FOR
                          PARTIAL SUMMARY JUDGMENT

       Pursuant to Rule 56(a) of the Federal Rules of Civil Procedure, Defendants respectfully

move for summary judgment on all remaining claims raised in Plaintiff’s amended complaint, ECF

No. 12. Specifically, Defendants seek summary judgment on Plaintiff’s claims regarding the

closure of and construction at the John F. Kennedy Memorial Center for the Performing Arts:

Count Two, those relevant portions of Count Four, those relevant portions of Count Five, and those

relevant portions of Count Seven. A memorandum of law in support, a Declaration of Charles

Matthew (“Matt”) Floca and exhibits thereto, and a proposed order are filed as attachments to this

motion.

Dated: September 18, 2026                          Respectfully submitted,

                                                   BRETT A. SHUMATE
                                                   Assistant Attorney General, Civil Division

                                                   ERIC J. HAMILTON
                                                   Deputy Assistant Attorney General

                                                   BRANTLEY MAYERS
                                                   Counsel to the Assistant Attorney General

                                                   STEPHEN M. ELLIOTT
                                                   Assistant Branch Director

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Case 1:25-cv-04480-CRC   Document 89   Filed 09/18/26     Page 2 of 3



                                 CHRISTOPHER M. LYNCH
                                 Chief Litigation Counsel

                                 /s/ William S. Jankowski
                                 WILLIAM S. JANKOWSKI
                                 D.C. Bar No. 90021524
                                 Trial Attorney
                                 U.S. Department of Justice
                                 Civil Division, Federal Programs Branch
                                 1100 L Street NW
                                 Washington, DC 20530
                                 (202) 353-7578
                                 william.s.jankowski@usdoj.gov

                                 Counsel for Defendants

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Case 1:25-cv-04480-CRC          Document 89       Filed 09/18/26       Page 3 of 3




                               CERTIFICATE OF SERVICE

       I, William S. Jankowski, hereby certify that on September 18, 2026, I electronically filed

the foregoing, and all its attachments, using the Court’s CM/ECF system, which automatically

serves this document upon all counsel of record, in keeping with LCvR 5.4(d).



                                                   /s/ William S. Jankowski
                                                   William S. Jankowski

                                                   Counsel for Defendants