Plaintiffs Nick Bassen, Isaac Daily, Andrew Merjil, Paul Rodriguez, Hunter Springer, and Derrick Wynne, on behalf of themselves and a class of similarly situated persons, bring this class action against Defendant United States of America (the “Government”) and allege as follows upon personal knowledge as to themselves and their own acts and experiences, and, as to all other matters, upon reasonable information and belief, including investigation conducted by their attorneys.

This is a military class action for backpay along with necessary ancillary relief for reinstatement, and/or points, and other relief for current and former members of the Air Force, Army, Navy, Marine Corps and Space Force (“Armed Services”) on active duty (“Active-Duty Service Members”) who were discharged, constructively discharged, and/or separated, and denied pay and benefits as a consequence of not being “fully
vaccinated” pursuant to Department of Defense (“DoD”) Secretary Lloyd Austin, III’s unlawful August 24, 2021 COVID-19 vaccine mandate and subsequent orders implementing the mandate (“DoD Mandate”). See Ex. 1, Aug. 24, 2021 SECDEF Mandate Memo.

PRESS RELEASE: DTR v. USA Feb 15, 2023

ECF 1: Complaint Bassen v. The United States of America

ECF 1- 1: Cover Sheet
ECF 1-2: Exhibit 1
ECF 1-3: Exhibit 2
ECF 1-4: Exhibit 3
ECF 1-5: Exhibit 4
ECF 1-6: Exhibit 5
ECF 1-7: Exhibit 6
ECF 1-8: Exhibit 7
ECF 1-9: Exhibit 8
ECF 1-10: Exhibit 9
ECF 1-11: Exhibit 10
ECF 1-12: Exhibit 11
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ECF 1-14: Exhibit 13
ECF 1-15: Exhibit 14
ECF 1-16: Exhibit 15
ECF 1-17: Exhibit 16
ECF 1-18: Exhibit 17