I, George E. Moose, declare under penalty of perjury and pursuant to 28 U.S.C. § 1746 that the following is true and correct:
8. Through reports I had previously received from members of my team, I had learned that the building has been essentially abandoned for many weeks. From these reports, I had understood that during the period that defendants were responsible for the building, there were only a few security guards on site, with no perimeter patrols.
9. That is consistent with what I personally observed during my return to the building. When my team and I arrived, the only persons in the building were two security guards and a small cleaning crew. In my experience, that level of staffing is woefully insufficient to properly protect and maintain the building.
10. On May 22, members of my staff, including our chief of security and our contract building engineer, spent the day surveying and documenting the condition of the building, to include photographs. Based on their reports, I understand that this failure to maintain and secure the building has impacted USIP’s premises. Among other things, they reported evidence of rats and roaches in the building. Vermin were not a problem prior to March 17, 2025, when USIP was actively using and maintaining the building.
Lambert here: Indeed not!
11. Staff have reported to me other deficiencies in the maintenance of the building, including the failure to maintain vehicle barriers and the cooling tower, water leaks, damage to the garage door, and missing ceiling tiles in multiple places in the building (which I have been told suggest likely water damage).
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