DEPARTMENT OF HOMELAND SECURITY 

BOARD FOR CORRECTION OF MILITARY RECORDS 

 
Application for the Correction of 
the Coast Guard Record of: 
 
                                                                                BCMR Docket No. 2006-071 
 
Xxxxxxxxxxxxxxxxxxxxxx 
  xxxxxxxxxxxxxxxxxxxx 

 

 
 

FINAL DECISION 

 
AUTHOR:  Andrews, J. 
 
 
This  proceeding  was  conducted  according  to  the  provisions  of  section  1552  of 
title 10 and section 425 of title 14 of the United States Code.  The Chair docketed the 
case on March 17, 2006, upon receipt of the application.   
 
 
members who were designated to serve as the Board in this case. 
 

This final decision, dated January 31, 2007, is signed by the three duly appointed 

APPLICANT’S REQUEST AND ALLEGATIONS 

 

The applicant asked the Board to correct her military record to show that she was 
evaluated  by  a  medical  board,  processed  under  the  Coast  Guard’s  Physical  Disability 
Evaluation System (PDES), and separated because of a physical disability.  She alleged 
that at the time of her release from active duty on May 1, 2000, she was not fit for duty 
because of pain and numbness in her back and leg. 

 

SUMMARY OF THE RECORD 

 
 
On January 2, 1997, the applicant enlisted in the Coast Guard Reserve to attend 
Officer  Candidate  School.    On  May  2,  1997,  she  was  commissioned  an  ensign  in  the 
Reserve and began three years of extended active duty (EAD).  On November 2, 1998, 
the applicant was promoted to lieutenant junior grade. 

 
On January 11, 2000, the applicant requested retention on active duty following 
the  termination  of  her  EAD  contract  on  May  1,  2000.    Her  command  endorsed  her 
request with a very strong recommendation for retention. 

 
On  January  29,  1999,  the  applicant  had  a  lump  of  “irregular  musculoadipose 
tissue”  removed  from  her  right  calf.    Microscopic  inspection  indicated  that  it  was  a 
“benign vascular malformation.” 

 
On June 30, 1999, the applicant began a series of eight sessions of physical ther-
apy  for  a  lumbosacral  strain  that  began  when  her  left  foot  slipped  and  she  caught 
herself so as not to fall. 

 
On January 28, 2000, the applicant began undergoing physical therapy for a “dull 
ache”  with  numbness  and  tingling  in  her  lower  back  and  left  leg.    The  applicant 
reported that she had hurt her pelvic rim in May 1999 and that she took Tylenol and 
Motrin  to  alleviate  the  pain.    The  physical  therapist  reported  that  her  lumbar  flexion 
and extension were within normal limits but that she did complain of pain during for-
ward flexion and extension. 

 
On February 1, 2000, a health service specialist noted that a physician had ques-
tioned  whether  the  applicant  was  medically  eligible  to  remain  in  the  Coast  Guard 
because of her many medical complaints. 

 
On  February  4,  2000,  the  applicant  consulted  a  plastic  surgeon  concerning  a 
“keloid on her left shoulder associated with multiple attempts at removal of a dermato-
fibroma,” another keloid on her right thigh, and a “hypertrophic scar on her right ankle 
associated with some sort of cyst excision.”  He recommended against excision of the 
ankle scar but stated that the “other two lesions are amenable to excision with definite 
risk of recurrence of the keloids.” 

 
On  February  9,  2000,  the  applicant  had  an  MRI  of  her  lumbar  spine  after  she 
complained  of  pain  radiating  to  her  left  leg.    The  MRI  showed  “no  evidence  of  disc 
herniation or far lateral abnormality.  There is no stenosis involving the lateral recesses, 
the neural foramina or the canal.  There are minor facet spurs that have no effect on the 
roots.  IMPRESSION:  Normal.”   

 
On  February  16,  2000,  Dr.  R  noted  the  applicant  had  a  “completely  normal” 
range of motion in her back although she “says there is a fair amount of pain when she 
moves at all.  There is no obvious compromise in her strength at this point either.”  The 
doctor placed the applicant on limited duty for 90 days.  On February 17, 2000, Dr. R 
noted that the applicant might be suffering from piriformis syndrome and referred her 
for a neurological examination. 

 
On March 10, 2000, the Coast Guard Personnel Command (CGPC) informed the 
applicant that the Reserve Officer Extension Board had approved her request for reten-
tion on active duty past the expiration of her EAD extension contract.   

 
On March 16, 2000, the applicant submitted a letter to CGPC in which she asked 
to  be  allowed  to  resign  her  commission  “to  attend  graduate  school  and  care  for  my 
newborn children.”  However, contrarily, she noted that she desired to have a commis-
sion in the Reserve.   

 
On March 17, 2000, a neurologist reported that the applicant’s lumbar and lower 
thoracic  spine  were  “[t]ender  to  both  mild  and  deep  palpation,”  but  “[t]here  was  no 
evidence  of  paraspinal  spasm,  nor  was  there  punch  tenderness  over  the  vertebrae.”  
However,  the  applicant’s  gait  was  normal,  she  did  not  complain  of  tripping,  and 
although she complained of a lack of sensation on the left side of her back, her sensation 
was “intact throughout.”  The neurologist further reported the following: 

 
Motor examination – There was normal tone, symmetric bulk and power that was 5/5.  
Examination of the left hip flexors resulted in back pain on the left and examination of 
the  left  foot  inverters  was  5/5,  but  there  was  give-away  weakness  after  a  good  effort 
without  apparent  associated  pain.  …  Straight  leg  raising  was  positive  on  the  left  with 
associated pain going down into the region of the toes. 
 
I  documented  a  normal  neurologic  examination  with  respect  to  power,  deep  tendon 
reflexes  and  sensation.    There  was,  however,  evidence  of  low  back  pain  and  a  positive 
straight-leg-raising examination.  I note the results of the MRI studies of the lumbar spine 
(I have reviewed these films) and I agree that they demonstrated no abnormalities sug-
gestive of disc herniation, impingement at the nerve roots or stenosis. 
 
I have difficulty making a diagnosis of a piriformis syndrome.  In general, sciatic nerve 
entrapment is a rare event and this particular syndrome, even in the past, was difficult to 
establish  and  has,  to  a  large  degree,  fallen  into  obscurity.    Further,  I  have  no  electro-
physiologic techniques that can distinguish entrapment at the level of the thigh or sciatic 
notch. …  Overall, I find that [the applicant’s] neurologic physical examination shows no 
signs of impairment and I believe that she would probably benefit from a more extensive 
course [of] physical therapy, both in terms of length and in terms of the consideration of 
other medications (i.e., gabapentin, tricyclic antidepressants) … . 
 
On  March  24,  2000,  the  applicant  informed  CGPC  that  she  intended  to  be 

released from active duty rather than accept the offer of an extension.   

 
On March 28, 2000, the applicant sent an email to Dr. R stating that the neurolo-
gist did not determine the cause of her pain and numbness but recommended physical 
therapy.  She asked to be referred to a particular physical therapist recommended by 
her brother in law.  She noted that her “contract is up on the 1st of May, and I would like 
to be able to make that date if possible.  Please let me know what I need to do in order 
to  make  this  happen,  and  yet  get  some  much  needed  relief  beforehand.”    Dr.  R 
responded  the  same  day  and  instructed  her  to  get  an  appointment  with  a  physical 
therapist through the health services specialist. 

 

On April 13, 2000, the applicant’s physical therapist noted that the applicant was 
taking Tylenol and Motrin for lower back pain that radiated to her buttocks as well as 
pain in her mid back.  The physical therapist noted that the applicant rotation and lat-
eral flexion were normal but that her lumbar flexion and extension were each 75%.  The 
applicant reported that her pain was 7 out of 10, that her ability to function was 4 out of 
10,  and  that  her  ability  to  manage  her  condition  was  poor.    The  physical  therapist 
reported that she expected the applicant to gain full recovery through physical therapy. 

 
On April 21, 2000, the applicant underwent a physical examination in prepara-
tion for being released from active duty.  On her Report of Medical History, the appli-
cant wrote, “Present Health – Good.  Chief complaints:  associated pain and numbness 
from back injury while pregnant; also continued pain from mass excision of right lower 
calf.”    The  only  medications  she  listed  were  vitamins  and  birth  control  pills.    Dr.  R 
noted  that  the  applicant  was  undergoing  physical  therapy  for  myofascial  syndrome1 
and a limited ROM in her right ankle due to the excision of the mass from her right calf 
in 1999.  However, Dr. R found her to be physically qualified for discharge. 
 
 
Reserve. 
 

On May 1, 2000, the applicant was released from active duty (RELAD) into the 

By October 1, 2004, the applicant had received a 50% combined disability rating 

from the Department of Veterans’ Affairs (DVA) with the following separate ratings: 

 
•  20% for chronic lumbar strain with radiation to the left leg; 
•  10% for depressive disorder secondary to her chronic lumbar strain; 
•  10% for left shoulder impingement; and  
•  20%  for  the  keloid  scar  resulting  from  the  excision  of  a  cyst  from  her  right 

ankle.  

 

The DVA noted that the xrays showed that the applicant has mild scoliosis in her 

lumbar spine. 
 

 

VIEWS OF THE COAST GUARD 

On July 14, 2006, the Judge Advocate General (JAG) of the Coast Guard submit-
ted an advisory opinion in which he recommended that the Board deny the applicant’s 
request.  The JAG adopted the findings and recommendation in a memorandum on the 
case prepared by the Coast Guard Personnel Command (CGPC). 

 
CGPC stated that the application was not timely and that the applicant did not 

justify her delay in seeking relief. 

                                                 
1 Myofascial pain syndrome is caused by sustained muscle spasm in specific parts of the body. 

 
CGPC stated that the applicant’s release from active duty was voluntary as she 
was granted an extension of her EAD contract but then asked to resign her commission 
and then decided to seek release from active duty instead of resigning.  CGPC stated 
that  the  applicant  underwent  a  physical  examination  prior  to  her  release  from  active 
duty and was found fit for separation.  Although the applicant was receiving medical 
treatment for pain and numbness in her back and leg in 2000, CGPC argued, “there is 
no indication that the condition met the requirements of [the PDES Manual] to initiate 
medical  board  proceedings  and  there  is  no  indication  that  [she]  disagreed  with  the 
medical findings” of the physician who conducted her physical examination. 

 
CGPC  stated  that,  while  the  applicant  has  physical  ailments,  the  DVA  “is  the 

appropriate venue for disposition of her case.” 

 

APPLICANT’S RESPONSE TO THE COAST GUARD’S VIEWS 

 
On September 18, 2006, the Board received the applicant’s response to the views 
of the Coast Guard.  The applicant alleged that while on active duty, she was not prop-
erly diagnosed.  She questioned how she could have been found qualified for separa-
tion  when  she  had  several  impairments  and  was  having  severe  pain.  The  applicant 
stated that she was also depressed due to her pain but could not take antidepressants 
because she was nursing.  The applicant stated that since her RELAD she has been fol-
lowing the procedures she knew of at the DVA and that no one mentioned the BCMR to 
her until 2005.  

 
The applicant alleged that prior to her RELAD, she thought she was going to be 
evaluated by a medical board and had discussed PDES processing with Dr. R.  How-
ever, on February 17, 2000, Dr. R tricked her by telling her that to undergo evaluation 
by a medical board she would have to accept being extended on active duty indefinitely 
until the medical board process was completed and so he convinced her to RELAD and 
get help from the DVA instead.  She alleged that Dr. R did so “in order for the burden 
of my medical problems to be off their shoulders.”  The applicant stated that she did not 
mention her medical problems in her request to RELAD because she was told it would 
be easier to return to active duty if she did not. 

 
The  applicant  also  alleged  that  the  neurologist’s  report  dated  March  17,  2000, 
contains several errors.  She stated that during the examination she told him that she 
lacked sensation in one area of her left side while he was testing her and he admitted to 
her when he palpated her back that he could feel her spasms.  Yet he reported that her 
sensation was intact throughout and that she had no paraspinous spasms.  The appli-
cant also alleged that she complained to him that she stumbled frequently and yet he 
reported that she did not. 

 

The applicant stated that she was not given a chance to disagree to anything and 
asked “what would I have disagreed to” since she was in pain.  The applicant alleged 
that her pain has continued and increased since her RELAD and her “physical limita-
tions prevent [her] from standing, walking or sitting for more than 5 – 10 minutes with-
out pain and numbness.”  She alleged that walking up or down stairs is not “next to 
impossible” and she is “constantly tripping or stumbling s [her] left foot/leg gives out.”  
She stated that she walks like a “decrepit old lady.”  The applicant stated that a radiolo-
gist for the DVA stated that she is in pain because her spine is curved with scoliosis and 
her pelvis is twisted. 
 

SUMMARY OF APPLICABLE LAW 

 
Disability Statutes 
 
 
Title 10 U.S.C. § 1201 provides that a member who is found to be “unfit to per-
form the duties of the member’s office, grade, rank, or rating because of physical dis-
ability incurred while entitled to basic pay” may be retired or discharged by reason of 
physical disability.  If the disability is “at least 30 percent under the standard schedule 
of  rating  disabilities  in  use  by  the  Department  of  Veterans  Affairs  at  the  time  of  the 
determination,” the member is retired.  If the disability is rated at only 10 or 20 percent 
under the schedule, the member is discharged with severance pay. 10 U.S.C. § 1203.   
 
Provisions of the Medical Manual (COMDTINST M6000.1B) 

 
Article 3.F.1. of the Medical Manual provides that members with medical condi-
tions that “are normally disqualifying” for retention in the Service shall be referred to 
an  Initial  Medical  Board  or  a  waiver  shall  be  requested  by  their  commands.    Article 
3.F.13.  identifies  the  following  conditions  of  the  spine  that  may  be  disqualifying  for 
retention on active duty: 

 
a. Congenital anomalies. 

(1)  Spina  bifida.  Demonstrable  signs  and  moderate  symptoms  of  root  or  cord 

involvement. 

(2) Spondylolysis or spondylolisthesis. With more than mild symptoms resulting 

in repeated hospitalization or significant assignment limitation. 
b. Coxa vara. More than moderate with pain, deformity, and arthritic changes. 
c.  Herniation  of  nucleus  pulposus.  More  than  mild  symptoms  following  appropriate 
treatment  or  remediable  measures,  with  sufficient  objective  findings  to  demonstrate 
interference with the satisfactory performance of duty. 
d.  Kyphosis.  More  than  moderate,  or  interfering  with  function,  or  causing  unmilitary 
appearance. 
e. Scoliosis. Severe deformity with over two inches of deviation of tips of spinous proc-
esses from the midline. 
 

Article  3.F.15.n.(1)  states  that  neuralgia  (pain  radiating  along  the  course  of  a 
nerve) may be disqualifying “[w]hen symptoms are severe, persistent, and not respon-
sive to treatment” may be disqualifying for retention.”   

 
Article 3.F.16.c. states that recurrent major depression or depression “associated 
with suicide attempt, untreated substance abuse, requiring hospitalization, or requiring 
treatment (including medication, counseling, psychological or psychiatric therapy) for 
more than 6 months” may be disqualifying for retention.” 

 
Article 3.B.6. provides that “[w]hen a member has an impairment (in accordance 
with section 3-F of this Manual) an Initial Medical Board shall be convened only if the 
conditions listed in paragraph 2-C-2.(b) [of the PDES Manual] are also met.  Otherwise 
the member is suitable for separation.” 
  
Provisions of the PDES Manual (COMDTINST M1850.2C)  
 
 

(a) 

Chapter 2.C.2. states the following: 
 
b. 
The law that provides for disability retirement or separation (10 U.S.C., chapter 
61)  is  designed  to  compensate  members  whose  military  service  is  terminated  due  to  a 
physical disability that has rendered him or her unfit for continued duty.  That law and 
this disability evaluation system are not to be misused to bestow compensation benefits 
on those who are voluntarily or mandatorily retiring or separating and have theretofore 
drawn  pay  and  allowances,  received  promotions,  and  continued  on  unlimited  active 
duty status while tolerating physical impairments that have not actually precluded Coast 
Guard service.  The following policies apply. 
 
   (1) 
Continued performance of duty until a service member is scheduled for separa-
tion or retirement for reasons other than physical disability creates a presumption of fit-
ness for duty.  This presumption may be overcome if it is established by a preponderance 
of the evidence that: 
 
 
adequately in his or her assigned duties; or 
 
 
acute,  grave  illness  or  injury,  or  other  deterioration  of  the  member’s 
physical condition occurred immediately prior to or coincident with processing for sepa-
ration or retirement for reasons other than physical disability which rendered the service 
member unfit for further duty. 
 
    (2)  A  member  being  processed  for  separation  or  retirement  for  reasons  other  than 
physical disability shall not be referred for disability evaluation unless the conditions in 
paragraphs 2.C.2.b.(1)(a) or (b) are met. 
 
c. 
If a member being processed for separation or retirement for reasons other than 
physical  disability  adequately  performed  the  duties  of  his  or  her  office,  grade,  rank  or 
rating, the member is presumed fit for duty even though medical evidence indicates he 
or she has impairments. 

the  member,  because  of  disability,  was  physically  unable  to  perform 

(b) 

•  •  • 

f. 
The following standards and criteria will not be used as the sole basis for making 
determinations that an evaluee is unfit for continued military service by reason of physi-
cal disability. 
 
   (1) 
geographic location and under every conceivable circumstance. … 
 
   (2) 

Inability to perform all duties of his or her office, grade, rank or rating in every 

Inability to satisfy the standards for initial entry into military service … . 

 

•  •  • 

Inability to qualify for specialized duties requiring a high degree of physical fit-

Pending  voluntary  or  involuntary  separation,  retirement,  or  release  to  inactive 

   (4) 
ness, such as flying … . 
 
   (5) 
The presence of one or more physical defects that are sufficient to require referral 
for evaluation or that may be unfitting for a member in a different office, grade, rank or 
rating. 
 
   (6) 
status. 
 
The existence of a physical defect or condition that is ratable under the standard 
i. 
schedule for rating disabilities in use by the [DVA] does not of itself provide justification 
for, or entitlement to, separation or retirement from military service because of physical 
disability.    Although  a  member  may  have  physical  impairments  ratable  in  accordance 
with the VASRD, such impairments do not necessarily render him or her unfit for mili-
tary duty … Such a member should apply to the [DVA] for disability compensation after 
release from active duty. 
 

Provisions of the Personnel Manual  
 
 
Article 12.B.6.a. provides that “[b]efore discharge ..., retirement, or release from 
active duty …, every enlisted member … , shall be given a complete physical examina-
tion.  …    the  examination  results  shall  be  recorded  on  Standard  Form  88.”    Article 
12.B.6.b. provides that “[w]hen the physical examination is completed and the member 
is found physically qualified for separation, the member will be advised and required to 
sign a statement on the reverse side of the Chronological Record of Service, CG-4057, 
agreeing  or  disagreeing  with  the  findings.”    Article  12.B.6.c.  provides  that  when  “a 
member objects to a finding of physically qualified for separation, the Standard Form 88 
together with the member’s written objections shall be sent immediately to Commander 
(CGPC-epm-1) for review.  If necessary the member may remain in service beyond the 
enlistment expiration date.”  
 

FINDINGS AND CONCLUSIONS 

 
 
The  Board  makes  the  following  findings  and  conclusions  on  the  basis  of  the 
applicant's military record and submissions, the Coast Guard's submissions, and appli-
cable law: 
 

1. 
§ 1552.   
 
2. 

The  Board  has  jurisdiction  concerning  this  matter  pursuant  to  10  U.S.C. 

An  application  to  the  Board  must  be  filed  within  three  years  after  the 
applicant discovers the alleged error in her record. 10 U.S.C. § 1552.  The applicant was 
released  from  active  duty  without  PDES  processing  on  May  1,  2000.    She  knew  or 
should  have  known  about  her  lack  of  PDES  processing  and  disability  rating  on  that 
date.  Therefore, her application was untimely. 

 
3. 

Pursuant to 10 U.S.C. § 1552(b), the Board may excuse the untimeliness of 
an application if it is in the interest of justice to do so.  In Allen v. Card, 799 F. Supp. 158, 
164 (D.D.C. 1992), the court stated that to determine whether the interest of justice sup-
ports a waiver of the statute of limitations, the Board "should analyze both the reasons 
for  the  delay  and  the  potential  merits  of  the  claim  based  on  a  cursory  review."    The 
court further instructed that "the longer the delay has been and the weaker the reasons 
are  for  the  delay,  the  more  compelling  the  merits  would  need  to  be  to  justify  a  full 
review."  Id. at 164, 165.   See also Dickson v. Secretary of Defense, 68 F.3d 1396 (D.C. Cir. 
1995).   
 
4. 

The applicant alleged that she did not timely apply to this Board because 
she did not know about the BCMR until 2005.  The applicant’s explanation for her delay 
is not compelling. 

 
5. 

A cursory review of the merits of this case indicates that the applicant vol-
untarily ended her active duty upon the expiration of her EAD contract on May 1, 2000, 
even  though  the  Coast  Guard  authorized  her  retention  on  active  duty  and  her 
command wanted her to remain on active duty.  On March 16, 2000, the applicant asked 
to resign her Reserve commission but also asked to have a Reserve commission upon 
her release from active duty.  On March 24, 2000, she corrected the error by informing 
CGPC that she did not want the offered extension of her EAD contract. 

 
6. 

Although  the  applicant  alleged  that  she  was  tricked  into  leaving  active 
duty by Dr. R, the record shows otherwise.  The applicant stated that on February 17, 
2000, Dr. R explained to her that PDES processing took time (in fact, it can take up to a 
year) and would require her retention on active duty past May 1, 2000, until such time 
as the PDES processing was complete.  He apparently explained to her that if she did 
not want to be retained on an “indefinite extension,” she would be released from active 
duty  and  could  seek  treatment  from  the  DVA.    The  applicant  did  not  want  to  be 
retained past May 1, 2000, and so asked to be released from active duty upon the expi-
ration of her EAD contract on March 16, 2000, and again on March 24, 2000.  She reaf-
firmed  her  choice  on  March  28,  2000,  when  she  wrote  to  Dr.  R  in  an  email  that  her 
“contract is up on the 1st of May, and I would like to be able to make that date if possi-
ble.”  

 
7. 

Chapter 2.C.2.b. of the PDES Manual states that the “law that provides for 
disability  retirement  or  separation  (10  U.S.C.,  chapter  61)  is  designed  to  compensate 
members  whose  military  service  is  terminated  due  to  a  physical  disability  that  has 
rendered him or her unfit for continued duty.  That law and this disability evaluation 
system are not to be misused to bestow compensation benefits on those who are volun-
tarily or mandatorily retiring or separating and have theretofore drawn pay and allow-
ances, received promotions, and continued on unlimited active duty status while toler-
ating  physical  impairments  that  have  not  actually  precluded  Coast  Guard  service.”  
Although the applicant had physical impairments at the time of her RELAD, she was 
found fit for duty during her RELAD physical examination and she continued to per-
form active duty until her contract expired.   
 

8. 

Under  Chapter  2.C.2.b.(2)  of  the  PDES  Manual,  a  “member  being  proc-
essed for separation or retirement for reasons other than physical disability shall not be 
referred for disability evaluation unless the conditions in paragraphs 2.C.2.b.(1)(a) or (b) 
are met.”  Those paragraphs state that PDES processing may only be started if “(a) the 
member,  because  of  disability,  was  physically  unable  to  perform adequately  in  his  or 
her  assigned  duties;  or  (b)  acute,  grave  illness  or  injury,  or  other  deterioration  of  the 
member’s  physical  condition  occurred  immediately  prior  to  or  coincident  with  proc-
essing  for  separation  or  retirement  for  reasons  other  than  physical  disability  which 
rendered  the  service  member  unfit  for  further  duty.”    Although  the  applicant  sought 
treatment for back pain and numbness during her last four months on active duty, her 
Coast Guard medical records do not support a finding that she was unable to perform 
her  duties  adequately  or  that  she  incurred  “an  acute,  grave  illness  or  injury  or  other 
deterioration  of  her  condition.”    Chapter  2.C.2.i.  expressly  states  that  “[a]lthough  a 
member may have physical impairments ratable in accordance with the VASRD, such 
impairments  do  not  necessarily  render  him  or  her  unfit  for  military  duty  …  Such  a 
member should apply to the [DVA] for disability compensation after release from active 
duty.” 
 

9. 

The only significant error in the applicant’s record is the lack of a CG-4057 
showing whether the applicant accepted or rejected Dr. R’s finding that she was quali-
fied for separation during her RELAD physical examination.  The preponderance of the 
evidence in the record, however, shows that the applicant was eager to be RELAD on 
May 1, 2000, and did not want an indefinite extension on active duty so that she could 
be evaluated by medical boards and fully processed under the PDES.  The preponder-
ance  of  the  evidence  indicates  that  the  applicant  would  have  signed  the  CG-4057  to 
accept Dr. R’s finding. 
 

10.  Accordingly,  the  applicant’s  request  should  be  denied  for  untimeliness 
because of the lack of a compelling reason for her delay and the lack any apparent merit 
in her claim that she was unjustly denied PDES processing.   

[ORDER AND SIGNATURES APPEAR ON NEXT PAGE]

 
 

The application of xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx, USCGR, for correction of 

ORDER 

 

                                                             
 

 

 

 

 

 

 

 Bruce D. Burkley 

her military record is denied.  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

 
 
 

 
 
 

 
 
 

 
 

 
 

 
 

 
 

 
 
 
 

 
 

 
 
 

 

 
 Harold C. Davis, M.D. 

 

 

 

 

 
 George A. Weller