Viewing page 12 of 30

This transcription has been completed. Contact us with corrections.

Case 1:18-cv-00011-DAD-EPG Document 1 Filed 01/02/18 Page 12 of 13

(1) Order the Defendant, through the AFBCMR, to upgrade Ms. James' discharge 
status to "honorable" and to correct the narrative reasons for separation;
(2) In the alternative, order Defendant, through the AFBCMR, to complete its 
consideration of Ms. James' 2016 application within fourteen days under 5 U.S.C § 706 of the
Administrative Procedure Act;
(3) In the alternative, issue a writ of mandamus ordering Defendant, through the AFBCMR, to complete its consideration of Ms. James' 2016 application within fourteen days under 28 U.S.C § 1651.
(4) Award reasonable attorneys' fees and costs; and
(5) Grant such other and further relief this Court deems just and proper.

















                                             11            Case No.
                                           COMPLAINT