Sergeant David Haynes, Corporal Matthew Batten and Lance Corporal Benjamin Lieberman (hereafter the” plaintiffs”) requested to participate in the FY16 Voluntary Early Enlisted Release Program as of the 14th of January 2015. All procedures pursuant to MARADMIN 020/15 were adhered to while the plaintiffs completed the necessary paperwork; this included the Administrative Action (AA) Form and a II MHG Recommendation Checklist as stipulated by the local commander. A summary of events follows:
13 JANUARY 2015 – MARADMIN 020/15 released
14 JANUARY 2015 – plaintiffs prepared necessary paperwork and submitted to the platoon sergeant, Sergeant Kobe. Upon receipt, Sergeant Kobe requested copies of the plaintiffs’ BIRs, LESs.
15 JANUARY 2015 – plaintiffs received an all-hands e-mail from Master Sergeant Plant, a member of their chain of command, expressing his opinion on the VEERP and its prospective applicants. Please find the transcript attached.
22 JANUARY 2015 – the company gunnery sergeant (Staff Sergeant Peternell) of Co. C, 2nd Radio BN, the parent unit of the plaintiffs, informed Sergeant Kobe of several outstanding requirements:
A previously scheduled TRS/TAMPS date
II MHG FY16 Recommendation Sheet
An updated AA Form
22 JANUARY 2015 – Sergeant Kobe furnished Staff Sergeant Peternell with the requested information; Lance Corporal Lieberman had a previously scheduled TRS date (prior to deployment), but Sergeant Haynes and Corporal Batten did not. Staff Sergeant Peternell informed Sergeant Kobe that this requirement could be fulfilled through Radio Battalion’s career planner, Staff Sergeant Bargerstock, or through himself. Sergeant Kobe sent the appropriate information to Staff Sergeant Peternell while Corporal Batten called the career planner, who acknowledged the issue and verbally informed Corporal Batten that it would be handled at a later date.
23 JANUARY 2015 – plaintiffs resubmitted updated AA forms to Sergeant Kobe but were limited by the...