in its order preliminarily approving the parties’ settlement agreement , by sending the Notice of

Summary

A notice of compliance filed by the defendants on June 25, 2024 as Document 282 in U.S. Navy SEALs 1-3, et al. v. Lloyd J. Austin, III, et al., Case No. 4:21-cv-01236-O, in the U.S. District Court for the Northern District of Texas, Fort Worth Division. The defendants, including the Secretary of Defense and the Secretary of the Navy, state that they complied with the court's preliminary approval order (ECF No. 280) by sending each class member the notice of proposed class action settlement and hearing, with the settlement agreement and attachments, on or before June 17, 2024. The notice refers to supporting declarations of Andrew E. Carmichael and Captain Gareth J. Healy and is signed /s/ by Carmichael for the Justice Department's Federal Programs Branch.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION

U.S. NAVY SEALs 1-3; on behalf of
themselves and all others similarly situated;
U.S. NAVY EXPLOSIVE ORDNANCE
DISPOSAL TECHNICIAN 1, on behalf of
himself and all others similarly situated; U.S.
NAVY SEALS 4-26; U.S. NAVY SPECIAL
WARFARE COMBATANT CRAFT
CREWMEN 1-5; and U.S. NAVY DIVERS
1-3,

Plaintiffs,

v.

LLOYD J. AUSTIN, III, in his official
capacity as United States Secretary of
Defense; UNITED STATES
DEPARTMENT OF DEFENSE; CARLOS
DEL TORO, in his official capacity as
United States Secretary of the Navy,

Defendants.

Case No. 4:21-cv-01236-O

NOTICE OF COMPLIANCE
Defendants respectfully provide notice that they have complied with the Court’s direction,
in its order preliminarily approving the parties’ settlement agreement, by sending the Notice of
Proposed Class Action Settlement and Hearing to Approve Proposed Settlement together with a
copy of the Settlement Agreement and appropriate Attachments, to each class member, by the
means previously agreed upon by the parties, on or before June 17, 2024.  See Order of Preliminary
Approval of Settlement, ECF No. 280.  A declaration from Defendants’ counsel attesting to such
service is attached to the appendix supporting this notice.  See Declaration of Andrew E.
Carmichael (App001-003); see also Declaration of Captain Gareth J. Healy (App004-007).
Case 4:21-cv-01236-O   Document 282   Filed 06/25/24    Page 1 of 2   PageID 8117

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Dated: June 25, 2024

Respectfully submitted,

BRIAN M. BOYNTON
Principal Deputy Assistant Attorney General

ALEXANDER K. HAAS
Director, Federal Programs Branch

LAUREN A. WETZLER
Deputy Director
Federal Programs Branch

/s/ Andrew E. Carmichael
ANDREW E. CARMICHAEL
AMY E. POWELL
Senior Trial Counsel
LIAM HOLLAND
Trial Attorney
United States Department of Justice
Civil Division, Federal Programs Branch
1100 L Street, N.W.
Washington, DC 20005
Tel: (202)-514-3346
Email: andrew.e.carmichael@usdoj.gov

Counsel for Defendants

Case 4:21-cv-01236-O   Document 282   Filed 06/25/24    Page 2 of 2   PageID 8118

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