Saved copy of
Declaration of Bridget Kennedy-Bailey
U.S. District Court for the District of Columbia · 2026-09-16
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Case 1:25-cv-04480-CRC Document 84-1 Filed 09/16/26 Page 1 of 4
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
JOYCE BEATTY,
Plaintiff,
v.
No. 25-CV-4480 (CRC)
DONALD J. TRUMP et al.,
Defendants.
DECLARATION OF BRIDGET KENNEDY-BAILEY
I, Bridget Kennedy-Bailey, pursuant to 28 U.S.C. § 1746, hereby declare as follows:
1. I am a staff member at the Washington Litigation Group, counsel for Plaintiff
Congresswoman Joyce Beatty in this matter. I have personal knowledge of the facts stated herein
except where stated otherwise.
2. I visited the John F. Kennedy Center for the Performing Arts (the “Kennedy
Center” or “Center”) on September 16, 2026. According to the Center’s website, the opening hours
for visitors on this day start at 10 a.m.
3. I arrived at the Center at approximately 10:12 a.m. I walked up to the front door
and saw that it was an automatic sliding door, but it did not open for me because it appeared to be
locked. I believe the door was locked.
4. I could see a security guard standing in the entryway, so I tapped on the glass of the
door to get her attention.
5. She walked up to the door and scanned her badge on a panel off to the side, after
which the door slid open. I started speaking with her at approximately 10:14 a.m.
6. I asked if I could come into the Center, and she stated, “No, we’re closed.”
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Case 1:25-cv-04480-CRC Document 84-1 Filed 09/16/26 Page 2 of 4
7. I asked the security guard if the Center was going to open later today or if they were
closed for the whole day. She stated that it would be closed for the whole day.
8. At 10:21, a man came out of the building wearing a button-down shirt and khakis.
We shook hands, and he told me his name is Shateik. The badge he had on his lanyard said,
“Shateik Jones, Security Operations Specialist.”
9. I asked Mr. Jones if the Center would be opening today, and he stated they were
closed for the day and that the order came from “higher-ups.”
10. I asked Mr. Jones how long the Center was going to be closed, and he stated he did
not know.
11. I asked Mr. Jones if he knew why the Center was closed, and he stated he was just
responding to orders and did not know why it was closed or when it will reopen. Mr. Jones stated
that he was told to keep the doors locked.
12. I asked him if the Center will be open if I come back tomorrow, and he stated that
he did not know.
13. I left the Kennedy Center at approximately 10:48 a.m.
14. I returned to the Kennedy Center at approximately 11:47 a.m.
15. When the car I was riding in drove up to the area where I had arrived earlier this
morning, a security guard stopped the car and told the driver that he could not pull into the same
drop-off area.
16. When I got out of the car, I saw that black metal gates had been placed in front of
the building since I left. The gates appeared to be around forty feet away from the building itself.
The gates lined up with the fountains on the east side of the building.
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Case 1:25-cv-04480-CRC Document 84-1 Filed 09/16/26 Page 3 of 4
17. I walked around to both the north and south sides of the building and saw that the
gates wrapped all around there, too, and blocked all the staircases leading to the building.
18. I also saw that there were four gates blocking the main walkway to the building.
19. I saw that the door under the scaffolding on the east side of the building was open,
but it appeared that workers were waiting for more gates to arrive to close it. Later, I saw that they
closed off that gap with gates.
20. While I was standing outside the gates, I saw forklifts bringing more gates to the
front of the building. These gates were white and orange and looked like those used on construction
sites.
21. I also saw that they had placed traffic cones in the area where cars had previously
been able to pull into earlier.
22. At approximately 11:58 a.m., I spoke to another woman outside the gates. She told
me her name is Patricia Haynes and that she works in security for the Kennedy Center. She stated
that the gates are for “public safety” because they are doing construction inside the building.
23. I also spoke to a man who introduced himself to me as “PJ.” He told me that he
works in public relations for the Kennedy Center, that the building is closed for these repairs, and
that staff are not allowed in without a hard hat.
24. I asked him if the construction was occurring today, and he stated that he was not
sure but that it “seems like it.”
25. I asked him when the Center will reopen, and he stated that he does not know and
that he had no more information about it.
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Case 1:25-cv-04480-CRC Document 84-1 Filed 09/16/26 Page 4 of 4
26. Afterward, I saw a forklift carrying what appeared to be a more permanent form of
fencing drive over to the north side of the building. I saw the forklift run into and hit the pillars on
the building several times.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this 16th day of September, 2026.
/s/ Bridget Kennedy-Bailey
Bridget Kennedy-Bailey
Washington Litigation Group
1717 K Street, NW, Suite 1120
Washington, D.C. 20006
(202) 521-8760
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