Case Document 24-1 Filed 08/20/18 Page 1 of 3 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA LUCAS CALIXTO, et al., Plaintiffs, v. Civil Action No. The Honorable Ellen Segal Huvelle UNITED STATES DEPARTMENT OF THE ARMY, et a1., Defendants. DECLARATION OF LIN H. ST. CLAIR Pursuant to 28 U.S.C. 1746, Ihereby declare as follows: 1. I make this declaration in response to the District Court?s Order on August 13, 2018. This Declaration responds to the Court?s inquiries regarding: (1.) the status of the Army?s policy relating to administrative procedures applicable to members of the Delayed Entry Program (DEP) and Delayed Training Program (DTP), including updates that resulted from Mr. Marshall Williams? July 20, 2018 memorandum (ECF No. 22-1 at Ex. (2.) the number of MAVNIS who received a discharge order from the US. Army Recruiting Command (USAREC) and/or the US. Army Reserve Command (USARC) and whose discharge order(s) have been revoked and/or whose involuntary separation is under review as a result of the July 20, 2018 memorandum; and (3.) the Army?s timeline for implementation of any new policy and expected time when the Army will resume involuntary separations against any DEP or DTP member in accordance with this policy. 2. I am currently the Assistant Deputy for Recruiting, Of?ce of the Assistant Secretary of the Army (Manpower Reserve Affairs). In this capacity, I serve as the Senior Case Document 24-1 Filed 08/20/18 Page 2 of 3 Advisor on all matters relating to military accessions and retention for the Assistant Secretary of the Army for Manpower and Reserve Affairs, the Principal Deputy, and the Deputy Assistant Secretary of the Army for Military Personnel. I have oversight responsibilities for the Army?s of?cer and enlisted accessions and retention programs across all components. In this capacity, I serve as the action of?cer oversight for non-citizen recruiting (MAVNI and Lawful Permanent Residents). I have previously submitted a declaration in this case. See ECF 22-1. 3. On July 20, 2018, the Acting Assistant Secretary of the Army for Manpower Reserve Affairs suspended processing of all involuntary separation actions pertaining to members of the DEP and DTP who were recruited through the MAVNI Pilot Program. On August 15, the Deputy Chief of Staff G-l forwarded recommendations for consideration and approval. Those recommendations, including the use of redeveloped unfavorable MS SD memorandums, are being assessed for legal, regulatory and operational feasibility. If approved for use, the redeveloped unfavorable MS SD memorandums will specify the separation procedures and separation authority for members of the DEP and DTP who receive unfavorable The memorandums are being redeveloped and are estimated to be completed, reviewed, and submitted for approval prior to the next bi-weekly status report due on September 4, 2018. The remainder of the operational feasibility assessments, including a determination on manpower and resource requirements to implement the new policy, can take up to sixty days. Once approved, and as ordered, a description of the Army?s policy relating to the administrative separation procedures applicable to members of the DEP and DTP who receive unfavorable MS SDs will be ?led with the Court at least 14 days prior to initiating any separation proceedings. Case Document 24-1 Filed 08/20/18 Page 3 of 3 4. As of August 17, 2018, USAREC has reinstated, in the DTP, 32 members of the MAVNI program, and USARC has revoked discharge orders for 6 members of the MAVNI program, including the named plaintiffs. In total, including those MAVNI members whose orders have been revoked, the separation proceedings for 149 MAVNIS have been suspended and are under review pursuant to the July 20, 2018 memorandum. 5. Given the recommendations, if they are operationally feasible, it can be up to sixty days before the policy and procedures are ?nalized. After these procedures have been approved and ?nalized, it can be up to another thirty to sixty days before noti?cation packets can be built and separation proceedings can be initiated. I declare under penalty of perjury that the foregoing is true and correct. Executed on August 20, - 9/38; ff xi era-r1 Liza?; H. ST. CLAIR 2018.