IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION
KAITLYN SAMUELS, and CAPTAIN MARK SAMUELS, USNR, and JENNIFER SAMUELS, as conservators and guardians of KAITLYN SAMUELS, Plaintiffs, v. U.S. DEPARTMENT OF DEFENSE 1400 Defense Pentagon Washington, DC 20301, DEFENSE HEALTH AGENCY 7700 Arlington Boulevard, Suite 5101 Falls Church, VA 22042 and CHUCK HAGEL United States Secretary of Defense 1000 Defense Pentagon, Room 3E880 Washington, DC 20301, Defendants. Case No. __________
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF
Plaintiffs Kaitlyn Samuels, and Captain Mark Samuels and Jennifer Samuels, as Kaitlyn’s conservators and guardians, file this Complaint for Injunctive and Declaratory Relief against Defendants the Defense Health Agency
(DHA) and Chuck Hagel, United States Secretary of Defense, in his official capacity, alleging as follows:
On October 1, 2013, the Department of Defense established the Defense Health Agency (DHA) to manage the activities of the Military Health System. These activities include those previously managed by TRICARE Management Activity (TMA), which was disestablished on the same date. Because TMA was administering the Military Health System when Kaitlyn’s benefits were denied, the Complaint will refer to TMA rather than DHA.
Case 3:14-cv-02948-K Document 1 Filed 08/15/14 Page 1 of 16 PageID 1