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Mass. Vat. Guard

Case 1:11-cv-11905-RGS Document 16

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No, 5095

P. 1

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS Civil Action No.1:11-cv-11905-RGS

MAJ SHANNON MCLAUGHLIN, Plaintiff, v. LEON E. PANETTA, in his official capacity as Secretary of Defense; ERIC H. HOLDER, JR., in his official capacity as Attorney General; ERIC K. SHINSEKI, in his official capacity as Secretary of Veterans Affairs; UNITED STATES OF AMERICA, Defendants.

DECLARATION OF MAJOR SHANNON MCLAUGHLIN Major Shannon McLaughlin hereby declares, pursuant to 28 U.S.C. 1746, as follows: 1. I am a Major in the United States Army, currently stationed in Milford,

Massachusetts. I am a Military Dual Status Technician, pursuant to 10 U.S.C. 10216, and I must retain my military guard status under Title 32 in order to maintain my fulltime federal employment. Accordingly, I am a member of both the United States Army and a member of the Massachusetts National Guard. 2. My military service began in April of 1998 when I joined the Navy Reserves. I

was about to enter law school at Boston College, In the Navy I was assigned to the Mobile Inshore Undersea Warfare United, 202 out of Newport, Rhode Island. During my third year of law school, I was activated for service in the wake of the September 11 terrorist attacks. I was deployed in November of that year and I was stationed in Souda Bay, Crete. I returned home

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after ten months and finished law school, I then transferred into the California National Guard so I could become a JAG officer. The National Guard offered me a position as a First Lieutenant, and I received my commission in July of 2004. I then transferred into the Massachusetts National Guard in 2005, where I served on active duty for two years. I was promoted to Captain in 2005 and was promoted to Major in October of 2010. 3. I always felt a calling to military service. I have always felt that this is a way to

serve the country that I love. 4. I have received several commendations for my service. My awards include the

Meritorious Service Medal, Army Commendation Medal (with two Oak Leaf Clusters), the Navy and Marine Corps Achievement Medal (with a Gold Star); the National Defense Service Medal Global War on Terrorism Expeditionary Medal, the Global War on Terrorism Service Medal, the Armed Forces Reserve Medal with Mobilization Device, the Navy and Marine Corps Overseas Service Ribbon, the Coast Guard Team Commendation Medal with Operational Distinguishing Device, the Meritorious Unit Commendation Award, and the United Nations Medal for the Former Yugoslavia. 5. I met my wife Casey in 1998. We dated for a few months, and then went our

separate ways. In December of 2008, we became reacquainted and fell in love. 6. In December.2009, I married Casey in the Foxborough town hall in Foxborough,

Massachusetts. 7. On October 19, 2011 at approximately 3:15 p.m., I went to the Administration

Office of the Massachusetts National Guard, located at Joint Force Headquarters in Milford, Massachusetts. I signed in and was greeted by a sergeant serving as a receptionist. I told her that I had a question about entering my spouse into DEERS. I asked for the Non-Commissioned

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Officer In-Charge of DEERS eligibility, and she told me that person was Sergeant First Class Robertson. I then asked if she could introduce me to him. He greeted me and 1 told him that wanted to enter my same-sex legal spouse into DEERS. He said "no, ma'am." He clarified that this was "official policy" that could not be helped. 8. Through these efforts, we intended to obtain the same benefits that heterosexual

married servicemembers receive: a military dependent ID card for Casey, enrollment for Casey in TRICARE, life insurance for Casey under the Servicemembers' Group Life Insurance program (SGLI), dental care for Casey, and, in the event 1 die while serving my country, the spousal death benefit. 9. These benefits are critical to me and to Casey and to our future together. Being

safe and secure in the knowledge that Casey is cared for and will benefit from my service will make me a more focused servicemember, will help alleviate the anxieties I experience while on the job, will improve my morale, will provide us with an improved standard of living and sense of stability, and will allow us to plan our futures together the way opposite-sex couples can.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on November 16, 2011.

Major Shannon McLaughlin

TOWN OF FOX ilotvoutou 40 South Street Case 1:11-cv-11905-RGS Document 16-1 Filed 11/21/11 Page 1 of 1
Fosborough, Massachusetts 02035 I Robert E Cutler, the undersigned. hereby certify that I hold the Office of Town Clerk of the Tow* of F os borough In the County of Norfolk, the Commonwealth of Massachusetts, and that the Records of Rath', Marriages and Deaths are in my custody. The following Is a true copy of sold records.

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DEPARTMENT OF PUISL1C. HEALTH REGISTRY Of VITAL RECORDS AND STATISTICS

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