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Case 1:18-cv-00011-DAD-EPG Document 1 Filed 01/08/18 Page 5 of 13

service. She was also stripped of her commission in the Air Force Reserves with an "undesirable" discharge on August 17, 1955.
16. Ms. James went back home, but she never told anyone about what happened to her in the military. She felt ashamed. The school where she had worked as a teacher before entering the Air Force offered her the opportunity to return to a full-time teaching position, but the school required that she provide a copy of her discharge papers before she could be rehired. She knew that the school would never take her back if they saw what was in her military records. Instead, she went to work on a tobacco farm.
17. Later, Ms. James decided to go back to school to get a degree in physical therapy. She attended the University of Pennsylvania. Other students in her program were also veterans, but they were able to pay for their studies with benefits received under the GI Bill. With an "undesirable" discharge, Ms. James was not eligible for such benefits. She had to borrow money and work nights as an usher in a theatre to pay for education. During this time, she felt depressed, angry, and alone. She had trouble sleeping and suffered nightmares and flashbacks from her days in the military.
18. After graduation from the program in 1956, Ms. James moved far away from everybody and everything in her past. She moved to Los Angeles, California and worked as a physical therapist. After about ten years, Ms. James went again back to school, this time on a scholarship, to earn an advanced degree in physical therapy at Stanford University.
19. While at Stanford, a friend of Ms. James, who was also an attorney, helped her appeal her "undesirable" discharge to the AFBCMR. In 1968, the AFBCMR upgraded Ms. James' discharge status to "general under honorable conditions" for her military service both in the Air Force and Reserves. (Copies of Ms. James' certificates of military service reflecting her "general" discharge are attached hereto as Exh. A.)
20. In 1969, Ms. James graduated from Stanford University with a master's degree in physical therapy. In 1972, she was offered a faculty position at the California State University at

4  Case No.
COMPLAINT