I am busy with a couple of motions myself, so don't have a lot of time. Here are some quick comments that caught my eye that are pretty important issues:
"The complaint states a claim for declaratory and injunctive relief under 10 U.S.C. § 1203"
This is troublesome.... remember, the Court of Federal Claims has jurisdiction over MONEY CLAIMS....there is no direct equitable relief available in CoFC (the court can fashion equitable relief after finding money due, but absent entitlement to money damages, the court will not have subject matter jurisdiction....I quoted the statute which applies, below). This statement is very risky.
"and the plaintiffs have standing to bring their claims, because CALIFORNIA ARMY NATIONAL GUARD illegally plaintiff's rights to a medical evaluation board and a timely line of duty."
This is very problematic. Potentially disastrous. (But, there may be a saving grace).
Take a look at the jurisdictional statute for the Court of Federal Claims:
https://www.law.cornell.edu/uscode/text/28/1491
28 USC 1491:
"(a)
(1) The United States Court of Federal Claims shall have jurisdiction to render judgment
upon any claim against the United States founded either upon the Constitution, or any Act of Congress or any regulation of an executive department, or upon any express or implied contract with the United States, or for liquidated or unliquidated damages in cases not sounding in tort. For the purpose of this paragraph, an express or implied contract with the Army and Air Force Exchange Service, Navy Exchanges, Marine Corps Exchanges, Coast Guard Exchanges, or Exchange Councils of the National Aeronautics and Space Administration shall be considered an express or implied contract with the United States.
(2) To provide an entire remedy and to complete the relief afforded by the judgment, the court may, as an incident of and collateral to any such judgment, issue orders directing restoration to office or position, placement in appropriate duty or retirement status, and correction of applicable records, and such orders may be issued to any appropriate official of the United States. In any case within its jurisdiction, the court shall have the power to remand appropriate matters to any administrative or executive body or official with such direction as it may deem proper and just." (Emphasis added).
The bold part is the important point....The claim has to be against the United States. I have seen several cases where people allege failures against National Guard officials and they have been dismissed. (This may sound like circular reasoning, but, a claim against a State National Guard will fail....but, remember, the National Guard has "dual" status as a State and Federal entity...so, National Guard "actions" that violate Army or DoD or Air Force regs, or Federal statutes can support jurisdiction. The key is in the wording). The good thing is that your complaint is styled as Dresen v. United States. But, depending on how the Court views your statement, it may be bad for your case. As a pro se party, the Court may read your filings favorably enough that this is not a disaster.
Another point, this language is something to be somewhat concerned about: "illegally plaintiff's rights to a medical evaluation board and a timely line of duty" The problem is that this language, where it is found discussing your argument that the court does have jurisdiction (it is not a standing issue, but, I would think that a reader would assume you really meant jurisdiction) is that it suggests, again, equitable relief and does not focus as much as it could on claims for money damages. Better would be something like, "the Army has failed to pay plaintiff money due to him for military disability retirement."
It was probably a good idea that you asked for a remand.
I don't mean to come off as sounding overly negative. I spend a lot of time trying to shred opposing counsel's arguments, so it is second nature to try to identify weaknesses.
What to do, now? You could let it ride. Or you could file an amended response. If you can find a pro bono program at a law firm, or have a reasonable shot at finding representation, you could ask the court for a brief stay so that you can retain counsel.
Need to get back to work. Hope my thoughts helped.