IN THE CASE OF: BOARD DATE: 19 May 2021 DOCKET NUMBER: AR20200008848 APPLICANT REQUESTS: * removal of the U.S. Army Criminal Investigation Command (CID) Report of Investigation (ROI) from his file * removal of his name from the titling block of the CID ROI APPLICANT'S SUPPORTING DOCUMENTS CONSIDERED BY THE BOARD: * DD Form 149 (Application for Correction of Military Record under the Provisions of Title 10, U.S. Code, Section 1552), 1 June 2020 * Enlisted Record Brief * U.S. Government Identification * Letter from Attorney for the Applicant, 2 June 2020 * Rebuttal/Self-Authored Letter, 3 June 2020 * Enclosure 1 – Coast Guard Housing Form * Enclosure 2 – Bank Statement * Enclosure 3 – Check * Enclosure 4 – General Officer Memorandum of Reprimand (GOMOR), 11 December 2014 * Enclosure 5 – GOMOR Revocation * Enclosure 6 – GOMOR, 8 February 2015 * Enclosure 7 – Information on Permanent Change of Station (PCS) * Enclosure 8 – Law Enforcement Report (LER), CID ROI (with notes from Applicant) * Enclosure 9 – DA Form 4833 (Commander's Report of Disciplinary or Administrative Action) (with notes from Applicant) * Enclosure 10 – Titling Action Determination * Enclosure 11 – Army Regulation 15-6 (Procedures for Administrative Investigations and Boards of Officers) Findings and Recommendations * Enclosure 12 – Letter of Support from Approving Authority * Enclosure 13 – DA Form 2823 (Sworn Statement) * Enclosure 14 – GOMOR Rebuttal, 16 February 2015 * Enclosure 15 – GOMOR Rebuttal, 29 December 2014 * Enclosure 16 – Army Regulation 15-6 Investigation * Enclosure 17 – Documents Sent and Received from U.S. Army Crime Records Center (CRC) * DD Form 149 (Application for Correction of Military Record under the Provisions of Title 10, U.S. Code, Section 1552), 20 March 2020 * Enclosure 1 – Legal Brief * Enclosure 2 – Self-Authored Letter, 26 March 2020 * Enclosure 3 – CID Rebuttal * Tab A – Department of Defense (DOD) Instruction (DODI) 5505.07 (Titling and Indexing Subjects of Criminal Investigations in the DOD) * Tab B – Response to Request for Release of Information and LER, CID ROI * Tab C – Army Regulation 15-6 Investigation * Additional Rebuttal Information, 10 November 2020 * Statement of Support (2) * DA Form 268 (Report to Suspend Favorable Personnel Actions (Flag)), 27 October 2014 FACTS: 1. The applicant did not file within the 3-year time frame provided in Title 10, U.S. Code, section 1552(b); however, the Army Board for Correction of Military Records (ABCMR) conducted a substantive review of this case and determined it is in the interest of justice to excuse the applicant's failure to timely file. 2. In a self-authored 15-page rebuttal, 3 June 2020, and a second self-authored, 3-page affidavit, 26 March 2020, the applicant states the reasons his name must be removed from the CID titling for both offenses of larceny and fraud are because he took actions that negate the element of intent, the investigating officer (IO) found that he did not commit any wrongdoing, the GOMOR was withdrawn, and the ROI is based on false statements/information. The applicant highlights legal errors and injustices. He further states: a. On 25 June 2013, he obtained U.S. Coast Guard quarters. On the U.S. Coast Guard Northern California Housing (NORCALHSG) Form 042 (Coast Guard Assignment and Termination of Coast Guard Government Quarters for DOD Personnel), he checked the box to terminate his basic allowance for housing (BAH) effective 2400 on the date prior to his signature. He was not very familiar with BAH and the process of living in on-post housing. He always intended to fix the problem, but his uncertainty with the process led to some delay. b. In August 2013, he noticed he was still receiving BAH. In anticipation of self- correction by the Defense Finance and Accounting Service (DFAS), he placed the BAH in a separate account. c. In October 2013, he spoke with his unit administrator (UA) and attempted to terminate his BAH by submitting a DA Form 5960 (Authorization to Start, Stop, or Change Basic Allowance for Quarters (BAQ), and/or Variable Housing Allowance (VHA)). d. His discussion with the UA and other leaders within his chain of command prompted an investigation into wrongfully issued BAH throughout the battalion, which uncovered that several individuals were accused of committing BAH fraud. e. In November 2013, he was still receiving BAH. He contacted the finance office and informed his commander about the issue, but no one could fix the problem. He continued submitting DA Forms 5960. Once he was allowed to pay back the BAH overpayment, he did. f. In June 2014, an Army Regulation 15-6 investigation was initiated to investigate an allegation that a handful of service members had committed larceny and fraud. He was included in this investigation because his BAH had never been terminated. The IO found he committed no wrongdoing. The issuing authority went as far as writing a letter of support to explain that he was found favorable during the investigation. g. On 11 December 2014 despite the IO making a favorable determination, he was issued a GOMOR for wrongfully appropriating BAH. After his rebuttal, the GOMOR was subsequently withdrawn and he was cleared of any wrongdoing. h. On 8 February 2015, he was served with another GOMOR by a new commanding general for fraud vice wrongful appropriation. He submitted his rebuttal, but had already left his command before the new commanding general determined to have the GOMOR locally filed. The local file was used as the basis for the titling action. Since he had left the command already, he had no local file with the command. i. Sometime in 2019, he discovered he had been titled by CID because the ROI stated he committed the offenses of larceny and fraud when he submitted paperwork requesting BAH. This statement is false because he submitted paperwork to terminate his BAH. j. To add to the confusion, the DA Form 4833 stated he was given nonjudicial punishment (NJP) under the provisions of Article 15, Uniform Code of Military Justice (UCMJ). That information is completely false as he was never given NJP. It is unjust, deceitful, and reckless that the ROI falsely states there was an NJP finding against him. k. The titling action was triggered by the improper creation and filling of the second GOMOR. Also the titling action was justified based on a false statement in the LER, an improperly completed DA Form 4833, and a non-existent legal review. 3. The 15-page legal brief submitted by the attorney for the applicant, 23 March 2020, states: a. There are procedural defects in this case: (1) the underlying basis of the titling was procedurally defective at the time of the ROI; (2) the Army Regulation 15-6 investigation found the applicant not guilty because the charge was legally insufficient; and (3) the titling decision is inequitable now. The titling decision is also in material error. The applicant's ROI and titling are inequitable and have served their purpose. b. The applicant should not have been titled by the CID. DODI 5505.07, section 6.5, states, "Titling an individual or entity is an operational rather than legal decision. The acts of titling and indexing are administrative procedures and shall not connote any degree of guilt or innocence." The applicant believes that a mistake was made at the time of the titling and indexing, and at that time there was no credible information even existed indicating the applicant committed a crime. Per DODI 5505.07, section 4(b)(2), this is an exception and the titling should be removed. c. The substantive error is that there was insufficient proof that the applicant committed any offense. He has never been found guilty of any offenses and the charges remain unsubstantiated. He was not ever criminally charged with or convicted of any offense. The applicant did not act with criminal intent. The applicant was honest and worked with his chain of command to repay the BAH. d. Although the applicant was given due process rights in responding to his charges, he was not ultimately found guilty of the allegation. The command found the applicant not guilty after being presented with direct evidence. He merely received a GOMOR in connection with allegations of larceny of Government property and fraud. The GOMOR was locally filed and ultimately dismissed. e. The chain of command's actions are also indicative of a finding of "not guilty." The chain of command supported the applicant by filing the GOMOR locally. In addition, there was never any NJP or punitive action taken. The applicant has been allowed to continue to serve and continues to be a valuable asset to the U.S. Military. f. The titling does not serve a further purpose and is in material error. The events that took place are no longer relevant as the applicant has continued to serve honorably. There is no valid equitable purpose in leaving the titling in place. The following should be taken into consideration when reviewing material error: (1) Larceny. For there to be a finding of larceny, the staff judge advocate must opine that there is probable cause to believe that a crime has been committed. In this case, the applicant would have to be shown to have the intent to steal. This was demonstrably false and was proven by the IO who initially investigated the case. The applicant did not have an intent to steal from the U.S. Government. He put the money aside and attempted to stop the BAH. He also involved his administrative noncommissioned officer and command in trying to stop his BAH. He did what was expected of someone trying to fix a financial matter. (2) Fraud. The applicant was receiving BAH prior to moving into U.S. Coast Guard housing. Fraud would require the applicant to receive something he was not already getting. In this case he was already entitled to BAH. (3) There was never any UCMJ action directed toward the applicant. This shows the command did not believe the titling action was proper. (4) The total loss stated was $11, 488.20. That was the figure in the original GOMOR written by General C____ and redacted by General E____. The redaction of the GOMOR identified a figure of $4,922.00. The dates on the paperwork are before the issuance of the new GOMOR, which shows there was no consideration of the rebuttal paperwork. 4. On 12 April 2013, the applicant executed a DA Form 5960. He elected to change his BAQ to "BAQ with dependents" as a result of marriage. 5. On 25 June 2013, the applicant executed a NORCALHSG-042, showing he was assigned to Government family housing. Section II of the form specifically states the applicant understood the "U.S. Coast Guard does not process my military pay records; therefore, it is my responsibility to ensure my Basic Allowance for Housing (BAH) is stopped or started on the appropriate date. I agree I will promptly (within 48 hours) submit a copy of this form to my servicing personnel/pay office to facilitate the proper processing of my pay allowances and to avoid any overpayments of BAH." 6. On 16 June 2014, an Army Regulation 15-6 investigating officer (IO) was appointed to conduct an informal investigation into the allegations of misconduct by multiple persons, including the applicant. The investigation would address whether the applicant received BAH while living in unspecified Government quarters. 7. On 25 June 2014, the applicant rendered a sworn statement wherein he stated, "in November of 2013 I spoke with MSG [Master Sergeant] B____ about my situation. He is the one that [sic] directed me to finance and suggest[ed] that I call them." 8. On 26 June 2014, the applicant's savings account showed a balance of $10,484.30. 9. On 30 June 2014, the IO issued the findings and recommendations for the Army Regulation 15-6 investigation. a. He found "[Applicant] did receive BAH while living at Coast Guard Housing. [Applicant] occupied Coast Guard Housing from 25 June 2013 to 21 January 2014. During the period 25 June 2013 to 21 January 2014, [Applicant] appears to have been paid approximately $11,488.20 in BAH." b. His sole recommendation regarding the applicant was that an action for recoupment be initiated against him to recoup the approximately $11,488.20 in BAH he received while living in Coast Guard housing during the period 25 June 2013 to 21 January 2014. 10. On 27 October 2014, a cashier's check was issued to the U.S Treasury in the amount of $11,537.20. 11. On 27 October 2014, the applicant's flag was removed from his records. The DA Form 268 shows the case was closed favorably. 12. On 9 December 2014, CID released the second corrected and final version of the CID ROI. It stated the "investigation established probable cause to believe [Applicant] committed the offense of Larceny of Government Property and Fraud when he submitted paperwork requesting BAH while residing in Coast Guard Housing, which he was not entitled to. The total loss to the U.S. Government was approximately $11,488.20." The applicant included a note on the ROI which states: "this is false, I terminated BAH." An additional note on the ROI states: "no reference to a legal review." 13. On 11 December 2014, the applicant was issued a GOMOR for wrongfully appropriating and receiving $11,488.20 in BAH entitlements from 25 June 2013 to 21 January 2014. The applicant did not provide documentation, nor is documentation available in the applicant's service records which would indicate subsequent actions taken after the applicant was issued the GOMOR. 14. On 24 December 2014, the applicant's battalion commander recommended locally filing the applicant's GOMOR. She stated: "[Applicant] may have made administrative errors in filing his documents but these were unintentional and there was no intent to defraud the government. [Applicant] had diligently worked the matter not only with finance but within the chain of command." 15. On 29 December 2014, the attorney for the applicant submitted a response to the GOMOR issued on 24 December 2014 wherein he highlighted the elements of wrongful appropriation and how the applicant's action did not meet those elements. He requested withdrawal or local filing of the applicant's GOMOR. 16. On 20 January 2015, the applicant received orders for PCS with a reporting date of 30 March 2015. 17. On 8 February 2015, the GOMOR issued to the applicant on 11 December 2014 was revoked. The reasons for revocation are not available for the Board to review. 18. On 8 February 2015, the applicant was issued a GOMOR for fraudulently receiving $4,922.00 in BAH entitlements from 25 June 2013 to 19 September 2013. The applicant did not provide documentation nor is documentation available in the applicant's service records, which would indicate subsequent actions taken after the applicant was issued the GOMOR. 19. On 16 February 2015, the attorney for the applicant submitted a response to the GOMOR issued on 8 February 2015 wherein he highlighted the fact that the predecessor in command issued a GOMOR and subsequently withdrew it. The attorney for the applicant emphasized distinctions between the first and second GOMORs with considerations for those distinctions to be weighed by the imposing commander in regard to the filing determination and requested local filing of the applicant's GOMOR. 20. From 20 through 26 February 2015, the applicant was on PCS leave. 21. On 2 March 2015, the applicant's commander completed a DA Form 4833 on which the applicant contests several points. a. The original suspense date for completion was 22 January 2015. The applicant included a note which stated: "the suspense date was 22 January 2015, but the second GOMOR was on 8 February 2015." b. Item 4 (Action Taken) shows the commander or reporting officer marked "Non- Judicial (Article 15)." The applicant included a note which stated: "this is 100% false. I was never given an NJP." c. Item 6 (Administrative Actions) is blank. The applicant included a note which stated, "Did not check the box that there was a GOMOR filed." d. Item 10a (Commander's Remarks) shows the applicant received a locally filed GOMOR on 24 February 2015. The applicant included a note which stated: "filed after I left the command." e. Item 11 (Commanding Officer or Reporting Officer) shows a deoxyribonucleic acid (DNA) sample was not collected. The applicant included a note which stated: "I submitted a DNA collection." 22. On 25 June 2019, the CRC provided the applicant with a redacted copy of the CID ROI. 23. On 13 December 2019, the CID issued a legal review to the CRC regarding the applicant's request to amend the CID ROI. The legal review determined credible information existed to believe the applicant committed the offense he was titled for and the wrong person's name was not entered into the block as a result of mistaken identity. No new, relevant, or material facts were submitted in the appeal to warrant revision of the titling determination. a. The memorandum stated: "based on the review of the LER and appeal, I find there is no basis for granting his request for an amendment." The applicant included a note which stated: "everything was based on the LER. The LER contains a false statement." b. The memorandum stated: "in addition, I concur with the decision of the trial counsel and find there was probable cause to believe [Applicant] committed the offenses." The applicant included a note which stated: "this is false, there was never a trial counsel for my case." 24. On 13 December 2019, the CID issued a memorandum to the CRC regarding the applicant's request to amend the CID ROI. Based on the legal review, the applicant was properly indexed as a subject utilizing the credible information standard; therefore, the request for removal should be denied. a. The memorandum stated, "a review was conducted of the above listed Law Enforcement Report (LER)." The applicant included a note which stated, "everything was based on the LER. The LER contains a false statement." b. The memorandum stated, "the Coast Guard requires Service Members to fill out a NORCALHSG-042 when accepting housing, which notifies the service member it is their responsibility to provide a copy to their unit administrator (UA) to stop their BAH." The applicant included a note which stated: "this is false. The form does not say I had to submit it to the UA. I admit that I did not fully read the form, but this is false." c. The memorandum stated "on 8 December 2014, a legal opinion was obtained from the OSJA [Office of the Staff Judge Advocate] who opined probable cause existed to believe [Applicant] committed the offenses of Larceny and Fraud." The applicant included a note which stated "the basis for this titling action is the 8 December 2014 legal opinion. I dispute its existence." 25. On 19 December 2019, the CID replied to the CRC regarding the applicant's request to amend the CID ROI. Based on the facts detailed within the investigation, there was sufficient evidence to meet the probable cause standard to support the listing of the applicant as a subject for the offenses listed in the LER. a. The memorandum stated: "credible information did exist at the time of this initial repot to warrant [Applicant] be titled as a subject in the referenced LER." The applicant included a note which stated: "everything was based on the LER. The LER contains a false statement." b. The memorandum stated: "[Applicant] knowingly received, and continued to receive Basic Allowance for Housing (BAH) while failing to submit documentation to terminate this allowance." The applicant included a note which stated: "this is false. I continually submitted documents to terminate BAH." 26. On 23 December 2019, the CID responded to attorney for the applicant regarding his request to correct information within the CID files. His request was denied. 27. The applicant provided DODI 5505.07, 27 January 2012, which: a. reissues reference (b) to establish policy and assign responsibilities that provide a uniform standard for titling and indexing subjects of criminal investigations in the DOD and b. prescribes procedures to create a uniform process that allows people named in criminal investigative reports or indexed in the Defense Central Index of Investigations (DCII) a chance to obtain a review of such actions. 28. On 2 June 2020, the applicant retained a military attorney who would act as the lead attorney vice the applicant's civilian attorney. 29. On 4 November 2020, Sergeant Major (SGM) P____ C____, the senior paralegal noncommissioned officer who oversaw the completion of the Army Regulation 15-6 investigation at the time, rendered a statement. SGM C____ stated the applicant was issued a locally filed GOMOR, but was not subjected to any UCMJ action and did not receive nonjudicial punishment. SGM C____ further stated the applicant did not plead guilty, nor was found guilty, of any UCMJ violations. 30. On 23 November 2020, Captain (CPT) D____ M____, the applicant's company commander at the time of the incident, rendered a statement. CPT M____ stated the applicant was proactive when the applicant immediately approached him with his BAH issues. CPT M____ was able to assist with getting the outstanding BAH debt balance paid in full. He further stated the applicant received a locally filed GOMOR as a result of the Army Regulation 15-6 investigation and was allowed to transfer to his next duty station. The applicant did not receive nonjudicial punishment, did not have a trial, nor did he have to plead to charges of any kind. BOARD DISCUSSION: After reviewing the application and all supporting documents, the Board found that relief was warranted. The Board carefully considered the counsel’ statement, supporting documents, evidence in the records and regulatory guidance. The Board considered the counsel’ statement, the applicant’s record of service and documents provided by the applicant’s counsel. One potential outcome was to deny relief based on the Office of Staff Judge Advocate who opined probable cause existed to believe the applicant committed the offenses of larceny and fraud to which he was properly indexed as a subject. However, the Board majority determined the applicant’s counsel provided evidence that demonstrated the GOMOR was dismissed and in good faith tried to correct the outstanding BAH debt balance. The Board agreed the applicant was improperly titled and should be removed from the law enforcement report (LER), dated December 2019, and any residual and/or affiliated titling actions from his records and all criminal databases to include his name from the title and/or subject block of the LER and any residual and/or affiliated titling actions. Therefore, the Board granted full relief. BOARD VOTE: Mbr 1 Mbr 2 Mbr 3 XXX : XX GRANT FULL RELIEF : : : GRANT PARTIAL RELIEF : : : GRANT FORMAL HEARING : XXX : DENY APPLICATION BOARD DETERMINATION/RECOMMENDATION: The Board determined the evidence presented is sufficient to warrant a recommendation for relief. As a result, the Board recommends that all Department of the Army records of the individual concerned be corrected to show removal from the law enforcement report (LER), dated December 2019, and any residual and/or affiliated titling actions from his records and all criminal databases to include his name from the title and/or subject block of the LER and any residual and/or affiliated titling actions. I certify that herein is recorded the true and complete record of the proceedings of the Army Board for Correction of Military Records in this case. REFERENCES: 1. Title 10, U.S. Code, section 1552(b), provides that applications for correction of military records must be filed within 3 years after discovery of the alleged error or injustice. This provision of law also allows the ABCMR to excuse an applicant's failure to timely file within the 3-year statute of limitations if the ABCMR determines it would be in the interest of justice to do so. 2. Army Regulation 195-2 (Criminal Investigation Activities) prescribes responsibilities, mission, objectives, and policies pertaining to the Army Criminal Investigation Program. Chapter 4 contains guidance for investigative records, files, and reports. a. Paragraph 4-4 contains guidance for individual requests for access to or amendment of CID ROIs. It states that requests to amend CID ROIs will be considered only under the provisions of this regulation. b. Paragraph 4-4b states requests for amendment of a CID ROI will be granted only if the individual submits new, relevant, and material facts that are determined to warrant revision of the report. The burden of proof to substantiate the request rests with the individual. Requests to delete a person's name from the title block will be granted if it is determined that credible information did not exist to believe the individual committed the offense for which titled as a subject at the time the investigation was initiated or the wrong person's name has been entered as a result of mistaken identity. The decision to list a person's name in the title block of a CID ROI is an investigative determination that is independent of judicial, nonjudicial, or administrative action taken against the individual or the results of such action. Within these parameters, the decision to make any changes in the report rests within the sole discretion of the CG, CID. The decision will constitute final action on behalf of the Secretary of the Army with respect to requests for amendment under this regulation. 3. Department of Defense Instruction (DODI) 5505.07 (Titling and Indexing Subjects of Criminal Investigations in the DOD) contains the authority and criteria for titling decisions and states that titling only requires credible information that an offense may have been committed. It states that regardless of the characterization of the offense as founded, unfounded, or insufficient in evidence, the only way to administratively remove a titling action from the DCII is to show either mistaken identity or a complete lack of credible evidence to dispute the initial titling determination. a. Titling ensures investigators can retrieve information in an ROI of suspected criminal activity at some future time for law enforcement and security purposes. Whether or not to title is an operational decision made by investigative officials, rather than a legal determination made by attorneys. b. Titling or indexing (in the DCII) alone does not denote any degree of guilt or innocence. Information is deemed credible if, "considering the source and nature of the information and the totality of the circumstances, it is sufficiently believable to indicate criminal activity has occurred and would cause a reasonable investigator under similar circumstances to pursue further facts of the case to determine whether a criminal act occurred or may have occurred." The criteria for titling are a determination that credible information exists that a person may have committed a criminal offense or is otherwise made the object of a criminal investigation. 4. DODI 5505.07 contains further legal guidance. a. Section 6.1. Organizations engaged in the conduct of criminal investigations shall place the names and identifying information pertaining to subjects of criminal investigations in title blocks of investigative reports. All names of individual subjects of criminal investigations by DoD organizations shall be listed in DCII. (This Instruction does not preclude the titling and indexing of victims or "incidentals" associated with criminal investigations.) Titling and indexing in the DCII shall be done as early in the investigation as it is determined that credible information exists that the subject committed a criminal offense. b. Section 6.3. The DOD standard that shall be applied when titling and indexing subjects of criminal investigations is a determination that credible information exists indicating the subject committed a criminal offense. c. Section 6.6. Once the subject of a criminal investigation is indexed, the name shall remain in the DCII even if a later finding is made that the subject did not commit the offense under investigation, subject to the following exceptions: (1) Section 6.6.1. Identifying information about the subject of a criminal investigation shall be removed from the title block of a report of investigation and DCII in the case of mistaken identity; i.e., the wrong person's name was placed in the ROI as a subject or entered into the DCII. (2) Section 6.6.2. Identifying information about the subject of a criminal investigation shall be removed from the title block of an ROI and the DCII if it is later determined a mistake was made at the time the titling and/or indexing occurred in that credible information indicating that the subject committed a crime did not exist. d. Section 6.9. When reviewing the appropriateness of a titling/indexing decision, the reviewing official shall consider the investigative information available at the time the initial titling decision was made to determine whether the decision was made in accordance with the standard stated in paragraph 6.3. 5. DODI 5505.7 also provides the following definitions: a. E1.1.1 – Credible Information: Information disclosed or obtained by an investigator that, considering the source and nature of the information and the totality of the circumstances, is sufficiently believable to lead a trained investigator to presume that the fact or facts are true. b. E1.1.2 – Criminal Investigation: Investigation into alleged or apparent violations of law undertaken for purposes which include the collection of evidence in support of potential criminal prosecution. c. E1.1.3 – DCII: A centralized database, organized in a searchable format, of selected unique identifying information and security clearance data utilized by security and investigative agencies in the DOD, as well as selected other Federal agencies, to determine security clearance status and the existence/physical location of criminal and personnel security investigative files. The DCII database is physically maintained by the Defense Security Service; however, the data it contains is the responsibility of the contributing agencies. d. E1.1.4 – Incidental: Any person or entity associated with a matter under investigation whose identity may be of subsequent value for law enforcement or security purposes. e. E1.1.5 – Indexing: Refers to the procedure whereby an organization responsible for conducting criminal investigations submits identifying information concerning subjects, victims, or incidentals of investigations for addition to the DCII. f. E1.1.6 – Subject: A person, corporation, or other legal entity about which credible information exists that would cause a trained investigator to presume that the person, corporation, or other legal entity committed a criminal offense. g. E1.1.7 – Title Block: Portion of an investigative report used to identify the persons, entities, or activities on which the investigation focuses. h. E1.1.8 – Titling: Placing the name(s) of person(s), corporation(s), other legal entity, organization(s), or occurrence(s) in the title block of a criminal investigative report. //NOTHING FOLLOWS// ABCMR Record of Proceedings (cont) AR20200008848 12 ARMY BOARD FOR CORRECTION OF MILITARY RECORDS RECORD OF PROCEEDINGS 1