BRAC Commission Material - Litigation Complaint - Rell vs. Rumsfeld (Connecticut) Page: 62 of 210
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retirement of the aircraft assigned to the 103rd Fighter Wing of the Bradley Air National
Guard in the manner proposed in the DOD and BRAC Commission Reports.
66. The Plaintiffs request that the Court enjoin the BRAC Commission,
Chairman Principi, and the BRAC Commissioners from including the recommendation
to realign the 103rd Fighter Wing in their final report and recommendations to be
transmitted to the President on or before September 8, 2005.
PRAYER FOR RELIEF
WHEREFORE, the Plaintiffs respectfully request that this Court:
(1) Issue an order declaring that the realignment of the 103rd Fighter Wing of
the Bradley Air National Guard as proposed by Secretary Rumsfeld and the BRAC
Commission without the consent of the Governor of the State of Connecticut is
prohibited by federal law;
(2) Issue an order declaring that portions of the DOD and BRAC Commission
Reports that recommends realignment of the 103rd Fighter Wing of the Bradley Air
National Guard are null and void;
(3) Enjoin Defendant Rumsfeld and any other officer or employee of DOD
from mandating, implementing, overseeing or directing the realignment of the 103rd
Fighter Wing of the Bradley Air National Guard in the manner proposed in the DOD and
BRAC Commission Reports;
(4) Enjoin the BRAC Commission, Chairman Principi, and the BRAC
Commissioners from including the recommendation to realign the 103rd Fighter Wing in14
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BRAC Commission Material - Litigation Complaint - Rell vs. Rumsfeld (Connecticut), legal document, March 30, 2006; (https://digital.library.unt.edu/ark:/67531/metadc25922/m1/62/: accessed April 19, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.