CASE 2026-08 | FORT EUSTIS, VIRGINIA | ARMY W-2
The Army Took Two Shots. Bilecki Got the First GOMOR Destroyed and Stopped Permanent Filing of the Second
August 2026
Fort Eustis, Virginia
Army Chief Warrant Officer 2 – W-2
Allegations: Physical and Sexual Abuse in First General Officer Memorandum of Reprimand; Physical Abuse in Second General Officer Memorandum of Reprimand
Facts
The Army took two shots at permanently filing a GOMOR against this Chief Warrant Officer. We stopped permanent filing both times. The first reprimand was withdrawn and destroyed. The Commanding General ordered the second filed locally rather than permanently in his Army Military Human Resource Record.
Our client had risen from the enlisted ranks to become a Chief Warrant Officer. A permanent GOMOR could affect future promotion, assignment, retention, and retirement decisions. The Army was not deciding where to store a piece of paper. It was deciding whether allegations from a broken marriage would become the permanent lens through which the rest of his career would be judged.
The first GOMOR accused him of physical and sexual abuse said to have occurred years earlier. It included allegations of choking, striking, and even forcing dog food into his former spouse's mouth. The Army announced its intent to file the reprimand permanently.
We did not answer those accusations with a character letter and a request for mercy. We took them apart incident by incident.
One alleged dog food assault was placed before the family even owned the dog. The rebuttal argued that other accusations conflicted with the family's address history. Medical records, photographs, travel records, and the message history did not line up with critical parts of the story the Army had been given. The Government relied on selective screenshots instead of a validated extraction of the complete conversation. Our first rebuttal stated the defense position plainly: “This matter is about child custody.”
We put 16 enclosures behind that argument. The company and battalion commanders and the command chief warrant officer unanimously recommended withdrawal and destruction. The Staff Judge Advocate still recommended permanent filing. The Commanding General rejected that recommendation, withdrew the GOMOR, and ordered it destroyed.
Six days later, the Army tried again.
The second GOMOR dropped every sexual abuse allegation and every specific incident from the first. It alleged physical abuse and again called for permanent filing. There was no new evidence. No new witness. No new document. Its entire case was four quotations taken from the same screenshots the Commanding General had already reviewed before destroying the first GOMOR.
Read alone, the words were ugly. The excerpts included phrases about abuse that “won't happen again,” making his former spouse's life “a living hell,” and taking responsibility for abusing her. We did not dodge those words or insult the Commanding General by pretending they looked good. We confronted the strongest evidence directly.
Our client had preserved more than 9,000 pages of messages covering four years of a collapsing long distance marriage. The Government had four excerpts from photographs of a phone screen. The screenshots jumped across dates and left out the surrounding conversation. They were not a complete extraction and contained no metadata to establish the full exchange.
Tim Bilecki took each excerpt apart. We did not concede that our client wrote the messages. We did not have to. Even taking every screenshot at face value, not one identified a blow, shove, restraint, injury, date, place, or other act of physical violence. The word “abuse” inside years of apologies, arguments, separation, and a custody fight was not a blank check for the Army to declare years of physical assault proven.
We also did not argue that our client had been a perfect husband. We owned the bad marital language the record supported. But marital failure, anger, and an ugly apology do not prove the physical violence alleged in a permanent GOMOR. That distinction was the heart of the second rebuttal.
We reminded the Commanding General that he had already reviewed the same screenshots and destroyed the first reprimand. We asked him to withdraw and destroy the second one as well. We also gave him a fallback: if he believed the language itself warranted correction, keep the reprimand local instead of putting it permanently into our client's AMHRR.
The company commander, battalion commander, and command chief warrant officer again recommended withdrawal and destruction. The brigade commander recommended local filing.
The Commanding General did not give us our first choice. He did not destroy the second GOMOR. But he rejected permanent AMHRR filing and chose the fallback we had argued for. He ordered the GOMOR into the local unit file for 18 months or until our client is reassigned to another general court martial jurisdiction, whichever occurs first.
We asked for more and did not get it. What we stopped still mattered. A permanent reprimand could have followed this warrant officer through the rest of his career. A local reprimand has a defined endpoint.
Two GOMORs. One destroyed. One ordered local. Neither was ordered permanently filed in the AMHRR.
Result: First GOMOR withdrawn and destroyed. Second GOMOR ordered filed locally for a limited period, not permanently in the AMHRR.
FAQ
Q: What got the first GOMOR withdrawn and destroyed?
We treated the allegations as a case that had to be proved, not as an administrative decision that had already been made. The rebuttal answered the accusations incident by incident and used 16 enclosures to test them against dates, addresses, medical records, photographs, travel, messages, and our client's service history. One accusation was dated before the family owned the dog involved in the story. Others did not fit the locations or records. The chain of command unanimously recommended withdrawal and destruction. The Staff Judge Advocate recommended permanent filing, but the Commanding General withdrew and destroyed the GOMOR.
Q: Why did the four text quotations not prove years of physical abuse?
Read alone, the quotations sounded like admissions. That was the Army's strongest evidence, and we faced it directly. Our client had preserved more than 9,000 pages of messages from the marriage. The Army used four excerpts from selective screenshots that jumped across dates and did not provide the complete conversation. More importantly, the quotations did not identify the specific physical acts, dates, places, or injuries alleged in the reprimand. We did not argue that the language was good. We showed why four ugly excerpts could not carry everything the Army wanted them to prove.
Q: Why did local filing matter if the second GOMOR was not destroyed?
Because the Army again intended permanent AMHRR filing. A permanent reprimand could affect the Chief Warrant Officer's future promotion, assignment, retention, and retirement decisions. We asked first for destruction, but we also argued that any reprimand should stay local if the Commanding General believed the language warranted correction. That is what he ordered. The signed decision directs local filing for 18 months or until reassignment to another general court martial jurisdiction, whichever occurs first. It does not order permanent filing in the AMHRR.
Prior results do not predict future outcomes.