Fighting Mandates


Plaintiffs Jeremiah Botello, et al., 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 ancillary relief for compensation (points), reinstatement, and other relief owed to current and former active status members of the Air and Army National Guard (“National Guard” or “Guardsmen”) and Reserve component members of the Armed Forces (“Reserves”)1 who were dropped from active status and denied pay and benefits as a consequence of not being “fully vaccinated” pursuant to the Department of Defense’s unlawful (“DoD”) August 24, 2021 COVID-19 vaccine mandate (“DoD Mandate”), see Ex. 1, Aug. 24, 2021 SECDEF Mandate Memo, and the DoD’s November 30, 2021 supplemental directive for National Guard and Reserve. Ex. 2, Nov. 30, 2021 Supplemental Directive.

PRESS RELEASE: DTR v. USA Feb 15, 2023

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

ECF 1- 1: Cover Sheet
ECF 1-2: Exhibit 1
ECF 1-3: Exhibit 2
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ECF 1-18: Exhibit 17