From the motion to dismiss: Based upon the initial reports provided by the Department of the Interior (“DOI”) and the USS. Park Police (“USPP”), the United States Attorney’s Office for the District of Columbia (“USAO-DC’) presented the grand jury with evidence that damage to the Reflecting Pool was caused by vandals, including the defendant in this case, David Hearn, However, it was not until after the return of the indictment, that the DOI provided additional documents to the USAO-DC indicating that damage to the Lincoln Memorial Reflecting Pool in June 2026 was the result of flawed installation by the contractor, Atlantic Industrial Coatings (“AIC”), and the rush to complete the project prior to events associated with the America 250 celebration in the weeks surrounding Independence Day 2026.