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                           DEPARTMENT OF DEFENSE 
         DEFENSE OFFICE OF HEARINGS AND APPEALS 
           
             
 
In the matter of: ) 
 ) 
  )  ISCR Case No. 11-02215 
  ) 
 ) 
Applicant for Security Clearance ) 
 
 
Appearances 
 
For Government: Alison O’Connell, Esquire, Department Counsel 
For Applicant: Pro Se 
 
 
______________ 
 
Decision 
______________ 
 
 
HOGAN, Erin C., Administrative Judge: 
 
Applicant submitted an application for a security clearance (e-QIP) on August 31, 
2010. On August 15, 2011, the Defense Office of Hearings and Appeals (DOHA) issued 
a Statement of Reasons (SOR) to Applicant detailing the security concerns under 
Guideline H, Drug Involvement, and Guideline E, Personal Conduct. The action was 
taken under Executive Order 10865, Safeguarding Classified Information within Industry 
(February 20, 1960), as amended; Department of Defense Directive 5220.6, Defense 
Industrial Personnel Security Clearance Review Program (January 2, 1992), as 
amended (Directive); and the adjudicative guidelines (AG) implemented within the 
Department of Defense on September 1, 2006.  
  
 On September 14, 2011, Applicant answered the SOR and requested his case 
be decided on the written record. Department Counsel prepared a File of Relevant 
Material (FORM) on October 16, 2011. The FORM was forwarded to Applicant on 
October 20, 2011.  Applicant received the FORM on November 1, 2011. He had 30 
days to submit a response to the FORM. He did not submit a response. On January 17, 
2012, the FORM was forwarded to the Hearing Office and was assigned to me on 
January 18, 2012. Based upon a review of the case file, pleadings, and exhibits, 
eligibility for access to classified information is denied. 
 
 
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Findings of Fact 
 
 In his answer to the SOR, Applicant admits the allegations in SOR ¶¶ 1.b, 1.c,  
1.e, 1.f, 2.c, and 2.e. He denies the allegations in SOR ¶¶ 1.a, 1.d, 2.a, 2.b, and 2.d. 
(Item 4)  
 
Applicant is a 34-year-old employee of a Department of Defense contractor who 
has been employed with the contractor since September 2003. He was previously 
granted a Top Secret DoD security clearance on October 26, 2004. He has a bachelor 
of science degree in electrical engineering. He is single and has an eight-year-old 
daughter. (Item 5; Item 6; Item 7)   
 
Guideline H – Drug Involvement 
 
Applicant admits marijuana use with varying frequency between 1994 and 2005. 
He last used marijuana in February 2009 while on the way to a hockey game with 
friends. He admits that he has purchased marijuana in the past and grew marijuana 
plants in the summer 2002. He also admits to using hashish on one occasion in 2003.  
From late November 2005 to October 2006, Applicant used cocaine on several 
occasions. In late November 2005 to early December 2005, he attended a friend’s 
wedding at a location outside of the United States. He used cocaine on six of the seven 
days during his visit. He used cocaine on another occasion in December 2005 while at 
friend’s party. His last use of cocaine was on October 21, 2006, while at another party. 
His last use of illegal drugs was his marijuana use in February 2009. (Item 4; Item 8 at 2 
– 4)   
 
On January 21, 2006, Applicant attended a party. He had four to five beers and a 
couple shots of hard liquor. When he left the party, he drove a few blocks down the 
street. He discovered he was in no condition to drive so he parked his car and went to 
sleep. Around 11 pm, a police officer approached his car and woke him up. Applicant 
was arrested and charged with Disorderly Conduct: Drugs With Alcohol. He spent the 
night in jail. Applicant states that he was taken to jail for his own safety and no further 
charges were pursued. The record does not indicate the outcome of Applicant’s arrest. 
(Item 8 at 3; Item 9 at 10-11) 
 
Guideline E – Personal Conduct 
 
On October 17, 2003, Applicant completed a personnel security questionnaire, 
Standard Form (SF) 86. Applicant answered “yes” in response to question 27 which 
reads:  
 
Your  Use of Illegal Drugs and Drug Activity – Illegal Use of Drugs 
Since the age of 16 or in the last 7 years, whichever is shorter, have you 
illegally used any controlled substance, for example, marijuana, cocaine, 
crack cocaine, hashish, narcotics (opium, morphine, codeine, heroin, etc.), 
amphetamines, depressants (barbituates, methaqualone, tranquilizers, 
etc.), hallucinogenics (LSD, PCP, etc.), or prescription drugs?  
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He listed that he used marijuana on a social basis between January 1, 1999, and June 
1, 2000. He did not list his marijuana use between 1996 and 1999 and between June 
2000 and October 2003. (Item 7 at 9)  
 
On March 24, 2004, Applicant provided a signed statement to his employer 
indicating that he would not use illegal drugs. He acknowledged in the statement that 
any future use of any narcotic substance, including marijuana, could result in removal of 
special security access.  After his background investigation, Applicant was granted a 
Top Secret DoD security clearance on October 26, 2004. As mentioned above, 
Applicant used marijuana and cocaine after March 2004 on numerous occasions until 
October 2006. He last used marijuana in February 2009. (Item 8 at 3-4; Item 9) 
  
In December 2008, Applicant received a reprimand from his employer for 
charging overtime without receiving advance written approval to work overtime. In an 
affidavit dated November 23, 2010, Applicant indicated that prior to the written 
reprimand, he had always received verbal approval for overtime from his supervisor. He 
was not aware of the policy to obtain advance written approval for overtime. Once he 
became aware of the policy (i.e. after he received the reprimand), he has followed the 
overtime policy. This is the first and only time he was ever reprimanded by his 
employer. Applicant states that his job performance record is good and he always 
complied with rules and regulations. He claims the reprimand is an isolated event and 
does not establish a pattern of failure to follow rules. I find for Applicant with respect to 
SOR ¶ 1.d because he was unaware of the overtime policy and has followed it after 
becoming aware of the policy. (Item 8 at 1)  
 
On April 24, 2009, Applicant completed another SF 86. He answered, “yes” in 
response to question 23a which asks: 
 
In the last 7 years, have you illegally used any controlled substance, for 
example, cocaine, crack cocaine, THC (marijuana, hashish, etc.), 
narcotics (opium, morphine, codeine, heroin, etc.), stimulants 
(amphetamines, speed, crystal methamphetamine, Ecstacy, ketamine, 
etc.), depressants (barbituates, methaqualone, tranquilizers, etc.), 
hallucinogenics (LSD, PCP, etc.), steroids, inhalants (toluene, amyl 
nitrate, etc.) or prescription drugs (including painkillers)? Use of a 
controlled substance includes injecting, snorting, inhaling, swallowing, 
experimenting with or otherwise consuming any controlled substance. 
 
In the remarks section of the SF 86, dated April 24, 2009, Applicant indicated that he 
used marijuana on a social basis between January 1997 and June 2003 and used 
cocaine in February 2005 on a one-time experimental basis. He did not list his  
marijuana use between June 2003 and 2005 and his last use of marijuana in February 
2009. He also did not list his use of cocaine between late November 2005 to October 
2006. (Item 6 at 16) 
  
 On January 19, 2010 and January 20, 2010, Applicant underwent polygraph 
examinations as part of a background investigation with another government agency. 
During a post-polygraph interview, Applicant admitted to using marijuana on a regular 
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basis from July 1994 through February 2009. He admitted that he used cocaine eight 
times between December 2005 and October 2006. When asked why he did not 
accurately list his illegal drug use on his security clearance questionnaires, Applicant 
said he did not disclose his marijuana use in 2003 out of fear that he would not receive 
a clearance and would be ineligible for his job. In 2009, he was afraid if he reported all 
of his drug use, he would lose his job. When asked why he listed only a one-time use of 
cocaine on his 2009 security clearance questionnaire, he rationalized that all of the uses 
at the wedding (at least daily over a period of six days) were really only one use 
because it was no longer a part of his life. (Item 9 at 2)  
 
On June 21, 2010, another government agency revoked Applicant’s program 
access because of his falsification on his security clearance questionnaires pertaining to 
illegal drug use; his use of illegal drugs while holding a security clearance; and his use 
of illegal drugs after providing a statement to his employer acknowledging that future 
use of any narcotic substance, including marijuana, could result in the removal of 
Special Security Access. (Item 9) SOR ¶ 2.d alleges the fact that Applicant was 
disapproved for access to classified information by another government agency 
because of his drug involvement and personal conduct. While the allegation consists of 
a relevant fact related to Applicant’s falsifications and illegal drug use while holding a 
security clearance, it does not raise a separate security concern. For this reason, I find 
for Applicant with respect to SOR ¶ 2.d.  
 
 On August 23, 2010, Applicant submitted his most recent security clearance 
application. He disclosed all of his illegal drug use on this application. (Item 5) On 
November 23, 2010, Applicant was interviewed by an investigator conducting his 
security clearance background investigation. He provided a signed sworn affidavit. He 
admitted to his arrest in January 2006 (although he recalled the arrest was in February 
2006) for Disorderly Conduct/Drug with Alcohol. He estimated that between January 
2004 and 2005, he used marijuana about less than once a week at parties with friends, 
at other social events, and occasionally when he was alone. He did not use marijuana 
between 2005 to February 2009. He used marijuana one last time on February 17, 
2009. He also admitted to cocaine use between November 2005 and January 2006 
while at a wedding. He used cocaine on six of the seven days when he was at the 
location where the wedding was held. He used cocaine in December 2005 while at party 
with friends. His last use of cocaine was on October 21, 2006, at another party with his 
friends. (Item 8) 
 
 In the November 23, 2010 affidavit, Applicant stated that he has not used illegal 
drugs for several years. He is not addicted to marijuana or cocaine.  He has never 
received treatment for drug use and no one has ever suggested to him that he needs 
treatment. His drug or alcohol use has not had a negative impact on his job 
performance, his financial stability, his judgment, and reliability. He has never failed a 
drug test. He admits that he used illegal drugs during the period that he had a security 
clearance and he acknowledges that he was warned of the consequences in writing. 
(Item 8 at 4) 
 
 Regarding SOR ¶ 1f, I find for Applicant. This allegation relates to Applicant’s 
arrest for Disorderly Conduct: Drug With Alcohol in January 2006. While this is an 
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alcohol-related arrest, there is nothing in the record suggesting Applicant also ingested 
illegal drugs on the night of the arrest. It is not a proper allegation under the Drug 
Involvement Guideline. If it was properly alleged under Guideline G, Alcohol 
Consumption, it would have been mitigated because of the passage of time.  
 
 SOR ¶ 2b alleges two subparts of Section 23. Subpart 23a. asks about illegal 
drug use within the last seven years. Subpart 23b. asks: 
  
Have you EVER illegally used a controlled substance while possessing a 
security clearance; while employed as a law enforcement officer, 
prosecutor, or courtroom official; or while in a position directly and 
immediately affecting public safety? 
 
Applicant answered, “yes” to this question. Because he answered affirmatively, I find for 
Applicant with respect to his answer to SOR ¶ 2.b pertaining to Section 23.b on his 
security clearance questionnaire. He did not deliberately falsify his response to this 
question. His deliberate falsification of the extent of his illegal drug use relates to the 
allegation pertaining to Section 23.a on his security clearance questionnaire. 
Regardless, SOR ¶ 2.b should have been two separate allegations in the SOR. 
Combining alleged falsifications involving separate questions on the personnel security 
questionnaire into one SOR allegation results in a convoluted and confusing SOR 
allegation. It is not a good practice.    
  
 Applicant states that he has made good faith attempts to set the record straight 
and correct the information which appeared to be misleading or omitted. He said that he 
does not intend to use illegal drugs in the future. He claims he no longer associates with 
people who use illegal drugs. They all live far away from him. He acknowledges his 
wrongdoings and wishes to make amends. (Item 8 at 4)  
    
Policies 
 
 When evaluating an applicant’s suitability for a security clearance, the 
administrative judge must consider the adjudicative guidelines (AG). In addition to brief 
introductory explanations for each guideline, the adjudicative guidelines list potentially 
disqualifying conditions and mitigating conditions, which are useful in evaluating an 
applicant’s eligibility for access to classified information. 
 
These guidelines are not inflexible rules of law. Instead, recognizing the 
complexities of human behavior, these guidelines are applied in conjunction with the 
factors listed in the adjudicative process. The administrative judge’s over arching 
adjudicative goal is a fair, impartial and commonsense decision. According to AG ¶ 2(c), 
the entire process is a conscientious scrutiny of a number of variables known as the 
“whole person concept.” The administrative judge must consider all available, reliable 
information about the person, past and present, favorable and unfavorable, in making a 
decision. 
 
The protection of the national security is the paramount consideration. AG ¶ 2(b) 
requires that “[a]ny doubt concerning personnel being considered for access to 
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classified information will be resolved in favor of national security.” In reaching this 
decision, I have drawn only those conclusions that are reasonable, logical, and based 
on the evidence contained in the record.  
 
Under Directive ¶ E3.1.14, the Government must present evidence to establish 
controverted facts alleged in the SOR. Under Directive ¶ E3.1.15, the applicant is 
responsible for presenting “witnesses and other evidence to rebut, explain, extenuate, 
or mitigate facts admitted by applicant or proven by Department Counsel. . . .” The 
applicant has the ultimate burden of persuasion as to obtaining a favorable security 
decision.  
 
A person who seeks access to classified information enters into a fiduciary 
relationship with the government predicated upon trust and confidence. This relationship 
transcends normal duty hours and endures throughout off-duty hours. The government 
reposes a high degree of trust and confidence in individuals to whom it grants access to 
classified information. Decisions include, by necessity, consideration of the possible risk 
that the applicant may deliberately or inadvertently fail to protect or safeguard classified 
information. Such decisions entail a certain degree of legally permissible extrapolation 
as to potential, rather than actual, risk of compromise of classified information. 
  
Section 7 of Executive Order 10865 provides that decisions shall be “in terms of 
the national interest and shall in no sense be a determination as to the loyalty of the 
applicant concerned.” See also EO 12968, Section 3.1(b) (listing multiple prerequisites 
for access to classified or sensitive information).   
 
Analysis 
 
Guideline H, Drug Involvement 
 
The security concern relating to the guideline for Drug Involvement is set out in 
AG &24:       
 
Use of an illegal drug or misuse of a prescription drug can raise questions 
about an individual’s reliability and trustworthiness, both because it may 
impair judgment and because it raises questions about a person’s ability 
or willingness to comply with laws, rules and regulations.  
 
Drugs are defined as mood and behavior altering substances, and include: 
(1) Drugs, materials, and other chemical compounds identified and listed 
in the Controlled Substances Act of 1970, as amended, (E.g., marijuana or 
cannabis, depressants, narcotics, stimulants, and hallucinogens), and (2) 
inhalants and other similar substances; 
 
Drug abuse is the illegal use of a drug or use of a legal drug in a manner 
that deviates from approved medical direction. 
 
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The guideline notes several disqualifying conditions that could raise security 
concerns. I find the following drug involvement disqualifying conditions apply to 
Applicant’s case.  
 
AG &25(a) (any drug abuse); 
 
AG &25(c) (illegal drug possession, including cultivation, processing, 
manufacture, purchase, sale, or distribution; or possession of drug 
paraphernalia); 
 
AG &25(g) (any illegal drug use after being granted a security clearance); 
and 
 
AG &25(h) (expressed intent to continue illegal drug use, or failure to 
clearly and convincingly commit to discontinue drug use).  
 
Applicant used marijuana on numerous occasions between 1996 and February 
2009. He used cocaine on six occasions while attending a friend’s wedding in 
November 2005 to December 2005. He used cocaine on another occasion in December 
2005 and again at a party in October 2006. AG &25(a) applies. AG &25(c) also applies 
because Applicant possessed the drugs on occasion. He also purchased marijuana for 
his personal use. When he was younger, he cultivated marijuana plants for his own use. 
  
AG &25(g) applies because Applicant used illegal drugs after being granted a 
security clearance on October 26, 2004. 
 
AG &25(h) applies because Applicant signed a statement in March 2004 
expressly stating the he will not use illegal drugs which he provided to his employer. He 
continued to use illegal drugs despite the statement. Through his actions, he failed to 
clearly and convincingly commit to discontinue drug use.  
    
The Government’s substantial evidence and Applicant’s own admissions raise 
security concerns under Guideline H, Drug Involvement. The burden shifted to Applicant 
to produce evidence to rebut, explain, extenuate, or mitigate the security concerns. 
(Directive ¶E3.1.15) An applicant has the burden of proving a mitigating condition, and 
the burden of disproving it never shifts to the Government. (See ISCR Case No. 02-
31154 at 5 (App. Bd. September 22, 2005))  
  
Guideline H also includes examples of conditions that could mitigate security 
concerns arising from drug involvement. The following mitigating conditions potentially 
apply to the Applicant’s case:  
 
AG ¶ 26(a) (the behavior happened so long ago, was so infrequent, or 
occurred under such circumstances that it is unlikely to recur and does not 
cast doubt on the individual=s current reliability, trustworthiness, or good 
judgment); 
  
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AG & 26(b) (a demonstrated intent not to abuse any drugs in the future, 
such as: (1) disassociation from drug-using associates and contacts; (2) 
changing or avoiding the environment where drugs were used; (3) an 
appropriate period of abstinence; and (4) a signed statement of intent with 
automatic revocation of clearance for any violation); and  
 
AG &26(d) (satisfactory completion of a prescribed drug treatment 
program, including but not limited to rehabilitation and aftercare 
requirements, without recurrence of abuse, and a favorable prognosis by a 
duly qualified medical professional.) 
   
 None of the mitigating conditions apply. AG ¶ 26(a) does not apply because 
Applicant has a long history of illegal drug use. While he claims not to have used illegal 
drugs since February 2009, and states that he will not abuse illegal drugs in the future, 
his assertions are given less credit because he previously signed a written statement in 
March 2004, expressing his intent to not use illegal drugs, yet he continued to use illegal 
drugs after making the statement and after being granted a security clearance. Based 
on his past history, Applicant’s reliability, trustworthiness, and judgment remain 
questionable.  
 
 AG ¶ 26(b) does not apply for the reasons mentioned in the above paragraph. In 
addition, while Applicant claims he no longer associates with any of his drug-using 
friends, in part, because they all live far away from him, a lot of his past illegal drug use 
occurred when he visited his friends. Applicant appears to succumb to peer pressure 
when he is around friends who use illegal drugs. Although Applicant claims to have 
abstained from illegal drugs for two years, this is not a sufficient period of abstinence 
based on his long history of illegal drug use. He did not present a signed statement of 
intent acknowledging that his clearance will be automatically revoked for any violation. 
Even if he had done so, it would be given little weight because he provided a similar 
statement in 2004, but continued to use illegal drugs.  
 
 No evidence was presented that would raise AG ¶ 26(d). Applicant has not met 
his burden to mitigate the security concerns raised under Guideline H, Drug 
Involvement.  
 
Personal Conduct 
 
 The security concern relating to the guideline for Personal Conduct is set out in 
AG &15: 
 
Conduct involving questionable judgment, lack of candor, dishonesty, or 
unwillingness to comply with rules and regulations can raise questions 
about an individual’s reliability, trustworthiness and ability to protect 
classified information. Of special interest is any failure to provide truthful 
and candid answers during the security clearance process or any other 
failure to cooperate with the security clearance process.  
 
 
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 The following disqualifying conditions apply to Applicant’s case: 
 
AG ¶ 16(a) (deliberate omission, concealment, or falsification of relevant 
facts from any personnel security questionnaire, personal history 
statement, or similar form used to conduct investigations, determine 
employment qualifications, award benefits or status, determine security 
clearance eligibility or trustworthiness, or award fiduciary responsibilities); 
  
AG ¶ 16(e) (personal conduct, or concealment of information about one’s 
conduct, that creates a vulnerability to exploitation, manipulation, or 
duress, such as (1) engaging in activities which, if known, may affect the 
person’s personal, professional, or community standing, or (2) while in 
another country, engaging in any activity that is illegal in that country or 
that is legal in that country but illegal in the United States and may serve 
as a basis for exploitation or pressure by the foreign security or 
intelligence service or other group); and 
 
AG ¶ 16(f) (violation of a written or recorded commitment made by the 
individual to the employer as a condition or employment).  
 
 Applicant deliberately falsified his response to question 27 on his security 
clearance questionnaire, dated October 17, 2003, and his response to question 23a on 
his security clearance questionnaire, dated April 24, 2009, by minimizing his illegal drug 
use. The full extent of his illegal drug use was disclosed during post-polygraph 
interviews by another government agency on January 19-20, 2010. AG ¶ 16(a) applies 
to Applicant’s case.  
 
 AG ¶ 16(e) applies because his illegal drug use and his intentional omissions on 
his security clearance questionnaires make him vulnerable to exploitation, manipulation 
and duress.  
 
 AG ¶ 16(f) applies because Applicant continued to use illegal drugs after 
providing a statement in 2003 that he would refrain from doing so as a condition of 
special security access.  
 
 The following Personal Conduct Mitigating Conditions potentially apply to this 
case: 
  
AG ¶ 17(a) (the individual made prompt, good-faith efforts to correct the 
omission, concealment, or falsification before being confronted with the 
facts); 
 
AG ¶ 17(c) (the offense is so minor, or so much time has passed, or the 
behavior is so infrequent, or it happened under such unique 
circumstances that it is unlikely to recur and does not cast doubt on the 
individual’s reliability, trustworthiness, or good judgment); and  
 
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AG ¶ 17(e) (the individual has taken positive steps to reduce or eliminate 
vulnerability to exploitation, manipulation, or duress). 
 
 AG ¶ 17(a) does not apply because Applicant deliberately minimized his illegal 
drug use on two different security clearance applications. He did not attempt to correct 
his deliberate falsifications in a prompt manner.  
 
 AG ¶ 17(c) does not apply because Applicant’s deliberate falsifications and his 
continued illegal drug use after being granted a security clearance are serious offenses. 
His decision to continue to use illegal drugs was of his own volition. It did not happen 
under circumstances that are unlikely to occur. Applicant’s past actions continue to raise 
questions about his reliability, trustworthiness, and good judgment.   
 
 AG ¶ 17(e) does not apply because Applicant’s past conduct still makes him 
vulnerable to exploitation, manipulation or duress.  
 
 Personal conduct concerns are not mitigated.  
  
Whole-Person Concept 
 
 Under the whole-person concept, the administrative judge must evaluate an 
applicant’s eligibility for a security clearance by considering the totality of the applicant’s 
conduct and all relevant circumstances. The administrative judge should consider the 
nine adjudicative process factors listed at AG ¶ 2(a):  
 
(1) the nature, extent, and seriousness of the conduct; (2) the 
circumstances surrounding the conduct, to include knowledgeable 
participation; (3) the frequency and recency of the conduct; (4) the 
individual’s age and maturity at the time of the conduct; (5) the extent to 
which participation is voluntary; (6) the presence or absence of 
rehabilitation and other permanent behavioral changes; (7) the motivation 
for the conduct; (8) the potential for pressure, coercion, exploitation, or 
duress; and (9) the likelihood of continuation or recurrence.  
 
Under AG ¶ 2(c), the ultimate determination of whether to grant eligibility for a security 
clearance must be an overall commonsense judgment based upon careful consideration 
of the guidelines and the whole-person concept.        
 
I considered the potentially disqualifying and mitigating conditions in light of all 
the facts and circumstances surrounding this case. I considered Applicant’s work as a 
contractor for the Department of Defense since 2003. I considered Applicant’s history of 
illegal drug use, his use of illegal drugs while holding a security clearance, and after 
providing a signed statement to his employer indicating he will abstain from illegal drug 
use. I considered his deliberate minimization of his illegal drug use on two different 
security clearance applications. Applicant’s actions raise serious concerns about his 
judgment, trustworthiness, and reliability. Applicant has not met his burden to overcome 
those concerns.   
 
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Formal Findings 
  
Formal findings for or against Applicant on the allegations set forth in the SOR, 
as required by section E3.1.25 of Enclosure 3 of the Directive, are: 
 
 Paragraph 1, Guideline H:    AGAINST APPLICANT 
 
  Subparagraph 1.a:    Against Applicant 
  Subparagraph 1.b:    Against Applicant 
  Subparagraph 1.c:    Against Applicant 
  Subparagraph 1.d:    Against Applicant 
  Subparagraph 1.e:    Against Applicant  
  Subparagraph 1.f:    For Applicant  
 
  Paragraph 2, Guideline E:   AGAINST APPLICANT 
 
  Subparagraph 2.a:    Against Applicant 
  Subparagraph 2.b: 
    #23a:    Against Applicant 
    #23b:    For Applicant  
  Subparagraph 2.c:    Against Applicant 
  Subparagraph 2.d:    For Applicant 
  Subparagraph 2.e:    For Applicant 
   
Conclusion 
 
In light of all of the circumstances presented by the record in this case, it is not 
clearly consistent with the national interest to grant Applicant eligibility for a security 
clearance.  Eligibility for access to classified information is denied. 
 
                                                
_________________ 
ERIN C. HOGAN 
Administrative Judge