The Catch.A permanent record of checked claims
RECORDSAVED COPY

Saved copy of

September 18 declaration of Charles Matthew Floca

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

Back to source details

The saved file is a PDF document of 0.2 MB. What follows is the text taken from it, which is the text the story quotes.

Jump to the cited passage
<!-- page 1 -->
Case 1:25-cv-04480-CRC          Document 89-3         Filed 09/18/26      Page 1 of 2




                       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.


             DECLARATION OF CHARLES MATTHEW (“MATT”) FLOCA

In accordance with the provisions of 28 U.S.C. § 1746, I, Charles Matthew Floca, state as follows,
under penalty of perjury, pertinent to the above-styled and numbered case:

   1. I currently serve as the Executive Director and Chief Operating Officer of the John F.
      Kennedy Center for the Performing Arts (“the Center”). In this capacity, I exercise
      operational authority over all institutional departments, managing a complex integration of
      both trust and federal functions, including all elements of the Center’s physical footprint. I
      represent the executive management of the Center before its Board of Trustees. In my
      employment, I report to the Board of Trustees (“Board”).

   2. The matters set forth in this Declaration are true and correct from my own personal
      knowledge and from information made available to me in the course of my official duties.
      I make this Declaration in support of Defendants’ Renewed Motion for Partial Summary
      Judgment and Motion to Dissolve the Preliminary Injunction

   3. On August 13, the Board of Trustees conducted a meeting at which it adopted a resolution
      that the Center should close for two years to conduct necessary repairs and renovations
      pursuant to congressional appropriation. A true and correct copy of the preliminary minutes
      of that meeting, which contains the referenced resolution, appears on the docket of this
      litigation at ECF No. 68-3. I attended that meeting and can attest to the authenticity of the
      documents discussed at that meeting, several of which are discussed further below.

   4. On August 11, the Center provided to trustees a meeting packet containing certain
      documents that were discussed at the August 13 Board meeting. As relevant to this filing,
      that packet contained a presentation developed by the Delta Consulting Group entitled
      “Construction Program Assessment.” A true and correct copy of that presentation appears
      under seal on the docket in this litigation at ECF No. 65-2. The meeting packet also
      contained a report developed by JLL, a construction management firm, entitled

---

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




   “Comprehensive Project Development Plan.” A true and correct copy of that report appears
   under seal on the docket in this litigation at ECF No. 65-1.

5. On August 31, 2026, the Center distributed to trustees a report developed by Delta
   Consulting Group and entitled “Construction Program Assessment Report.” A true and
   correct copy of that report and certain of its appendices is attached to this declaration as
   Exhibit A. Exhibit A includes appendices relied upon by the Delta Consulting Group to
   reach its determinations. Appendices included in Exhibit A are those appendices that do
   not already appear in the record. Excluded also are appendices that contain sensitive
   architectural drawings.1

6. On September 13, 2026, the Center distributed to trustees a packet of materials developed
   by Center management for discussion at a September 15 Board meeting. A true and correct
   copy of that packet of materials is attached to this declaration as Exhibit B. I attended the
   September 15 Board meeting and can attest to the authenticity of the documents discussed
   and to events that occurred at that meeting.

7. On September 15, 2026, the Board met again to discuss an array of documents compiled
   by an independent consultant and by Center management. At the conclusion of the meeting,
   the Board adopted a resolution reaffirming its prior decision to close the Center for repairs
   in light of, among other things, the additional materials provided to the Board subsequent
   to the August 13 meeting and due to the risk to the public and employees if the building is
   not closed for renovations. That resolution followed prior resolutions making clear it would
   only do so by all legal means, which includes the dissolution of the preliminary injunction
   currently in place.

8. Attached as Exhibit C is a true and correct copy of the preliminary minutes of the
   September 15, 2026 Board meeting, which includes the resolution the Board adopted at
   that meeting. The minutes are preliminary because they have not yet been presented to the
   Board for approval. However, from my own observation of the September 15 meeting, the
   preliminary minutes accurately reflect the discussions and content of that meeting.

9. Attached as Exhibit D is a true and correct copy of an addendum to the Delta Consulting
   Group’s “Construction Program Assessment Report” signed on September 15, 2026, by the
   report’s principal author, Darin Buchalter.

Executed in Washington, DC, on Friday, September 18, 2026.




                                                 __________________________________
                                                 Charles Matthew Floca


   1
       Omitted appendices include: Appendix C, Appendix N, and Appendix P.
Source reader

Source