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Case 1:18-cv-00011-DAD-EPG Document 1 Filed 01/02/18 Page 3 of 13


          FACTUAL ALLEGATIONS 
   5.  Helen Grace James was born on January 30, 1927 in Scranton, Pennsylvania 
   6. Ms. James' father was a World War I veteran and he inspired her to enlist in the Air Force. After earning a Bachelor of Science degree in Health Education at East Stroudsburg State College in Pennsylvania and teaching for several years, Ms. James enlisted in the Air Force in 1952, when she was 25 years old. She was concurrently enlisted in the Air Force Reserves.
   7. Ms. James completed her basic training at Lackland Air Force Base in Sab Antonio, Texas. She was then assigned to Kessler Air Force Base in Biloxi, Mississippi where she trained as a radio operator. Following training, she was stationed at Roslyn Air Force Base in New York. At Roslyn, Ms. James continued to work as a radio operator helping to ensure that our borders along the Atlantic were secure. She also played on and coached softball and basketball teams with other airmen. Ms. James loved the new experiences and challenges she experienced in the military.
   8. Ms. James consistently received positive performance evaluations and had no disciplinary problems. She was promoted from radio operator to crew chief and had achieved the rank of Airman Second Class at the time of her discharge. During her time at Roslyn, she was also commissioned as a Second Lieutenant in the Reserves. 
  9. About a year after she was stationed at Roslyn, Ms. James learned that gay and lesbian services members were considered by the military to be a threat to national security. The Office of Special Investigations ("osi") investigated airmen who were rumored to be homosexual, and Ms. James soon learned that OSI investigators had already arrived at her base.
  10. Ms. James' life in the military abruptly changed. She became fearful, anxious and depressed. She also had a lot of trouble sleeping and she used alcohol to cope with her escalating fears. 


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           COMPLAINT 






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