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DEPARTMENT OF DEFENSE 
DEFENSE OFFICE OF HEARINGS AND APPEALS 
           
             
 
 
In the matter of: ) 
 ) 
 ------------------------1 )  ISCR Case No. 09-02958 
 SSN: ----------- ) 
 ) 
Applicant for Security Clearance ) 
 
 
Appearances 
 
For Government: James F. Duffy, Esq., Department Counsel 
For Applicant: David P. Price, Esq. 
 
 
______________ 
 
Decision 
______________ 
 
 
FOREMAN, LeRoy F., Administrative Judge: 
 
This case involves security concerns raised under Guidelines H (Drug 
Involvement, E (Personal Conduct), and I (Psychological Conditions). Eligibility for 
access to classified information is denied. 
 
Statement of the Case 
 
Applicant submitted a security clearance application on June 21, 2007. He 
resubmitted it on October 8, 2008, after changing employers. On March 10, 2010, the 
Defense Office of Hearings and Appeals (DOHA) sent him a Statement of Reasons 
(SOR) detailing the basis for its preliminary decision to deny his application, citing 
security concerns under Guidelines H, E, and I. DOHA acted 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 
                                                          
1 At the hearing, the Statement of Reasons was amended to reflect Applicant’s middle name.  
 
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adjudicative guidelines (AG) implemented by the Department of Defense on September 
1, 2006.  
 
 Applicant received the SOR on March 29, 2010; answered it in an undated 
document; and requested a hearing before an administrative judge. Department 
Counsel was ready to proceed on April 22, 2010, and the case was assigned to me on 
April 27, 2010. DOHA issued a notice of hearing on April 27, 2010, scheduling the 
hearing for May 12, 2010. I convened the hearing as scheduled. Government Exhibits 
(GX) 1 through 7 were admitted in evidence without objection. Applicant testified but 
presented no witnesses or documentary evidence. DOHA received the transcript (Tr.) 
on May 20, 2010. 
 
Findings of Fact 
 
 In his answer to the SOR, Applicant admitted the allegations in SOR ¶¶ 1.a-1.e 
and 2.a-2.c. He denied the allegation in SOR ¶ 3.a. His admissions in his answer and at 
the hearing are incorporated in my findings of fact.  
 
 Applicant is a 49-year-old employee of a defense contractor. He has worked for 
his current employer since February 2008. He received a security clearance in March 
2008.  
 
 Applicant was a federal civilian employee from May 1985 to May 1989, working 
as an aircraft electrician. He held jobs in the private sector until July 2006. He was 
unemployed from July 2006 to April 2007. He worked for a federal contractor from May 
to November 2007. He was unemployed from November 2007 until February 2008, 
when he began his current job.  
 
 Applicant married in May 2001 and divorced in January 2008. He has no 
children. (Tr. 23.) He currently resides with his 84-year-old father, who suffers from 
dementia. (Tr. 31.) 
 
 When Applicant submitted his security clearance applications in June 2007 and 
October 2008, he responded “yes” to question 24a on both applications, asking if, since 
the age of 16 or in the last seven years, he had illegally used any controlled substance. 
He stated that he used cocaine once in March 2006. (GX 1 at 29; GX 2 at 27.)  
 
In an interview with a security investigator in January 2009, Applicant stated that 
he had used cocaine twice in 2006, and he denied using cocaine or any other illegal 
substances during the last seven years. (GX 3 at 5.) In response to DOHA 
interrogatories in June 2009, he again stated that he used cocaine twice in 2006. (GX 4 
at 6.) In an affidavit executed in September 2009, he admitted that he used cocaine 
every other day for a couple of weeks in 2006, and he stated that he did not disclose the 
extent of his cocaine use on his security clearance applications or during his interview 
with the security investigator because he was embarrassed about it. (GX 5 at 2, 4.) 
 
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 At the hearing, Applicant testified he began using cocaine while working as a 
night club bouncer, and he used it about three times a year from 1985 to 2005. In 2005, 
his mother became seriously ill and he started having marital problems. In addition, his 
work environment became stressful because he was given difficult tasks without 
sufficient time to perform them properly, and he believed he was being “set up to fail.” 
(GX 3 at 3.). He purchased cocaine and used it every day for a couple of months. (Tr. 
26-27.) In September 2006, he left his job by mutual agreement because his supervisor 
considered his work unsatisfactory. (GX 1 at 27.)  
 
 On both of his security clearance applications, Applicant answered “no” to 
question 21, asking if he had consulted with a mental health professional or another 
health care provider about “mental health related conditions.” (GX 1 at 27; GX 2 at 25.) 
In 2005, Applicant had voluntarily obtained treatment for substance abuse in 2005, but 
he did not stop using cocaine. From March to June 2006, he received further treatment 
for cocaine abuse at a psychiatric center. When he was admitted for treatment, he 
denied having any suicidal tendencies or thoughts of self-injury, but he stated that he 
heard voices when he used cocaine and had once fired a gun at a wall. (GX 6 at 3). He 
was diagnosed by a medical doctor as being cocaine dependent and having an 
adjustment disorder with depressed mood. Further testing was ordered to rule out 
underlying psychosis such as major depression with psychotic features or bipolar, 
schizoaffective disorder. There is no evidence that further testing occurred. (GX 6; GX 
7.) In his September 2009 affidavit, he stated that he did not disclose his treatment at 
the psychiatric center because he had forgotten about it. (GX 5 at 7.) 
 
 At the hearing, Applicant admitted thinking about suicide and shooting at a wall. 
He denied hearing voices while using cocaine, but he admitted that he fabricated that 
explanation for his behavior because he was embarrassed about his suicidal thoughts. 
(Tr. 39-40.) 
 
Applicant used cocaine with friends after completing his treatment in 2006. He 
stopped using illegal drugs in January 2008 and has not used them since that date. (GX 
5 at 5; Tr. 25-30.) He now devotes all his time to his job and caring for his father. (Tr. 
42-43.) He attended a few Narcotics Anonymous meetings after completing his 
substance abuse treatment. He no longer attends meetings, but he now talks almost 
every day with a friend who acts as an informal sponsor. (Tr. 50.) 
 
Policies 
 
 “[N]o one has a ‘right’ to a security clearance.” Department of the Navy v. Egan, 
484 U.S. 518, 528 (1988). As Commander in Chief, the President has the authority to 
“control access to information bearing on national security and to determine whether an 
individual is sufficiently trustworthy to have access to such information.” Id. at 527. The 
President has authorized the Secretary of Defense or his designee to grant applicants 
eligibility for access to classified information “only upon a finding that it is clearly 
consistent with the national interest to do so.” Exec. Or. 10865, Safeguarding Classified 
Information within Industry § 2 (Feb. 20, 1960), as amended and modified.   
 
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Eligibility for a security clearance is predicated upon the applicant meeting the 
criteria contained in the AG. These guidelines are not inflexible rules of law. Instead, 
recognizing the complexities of human behavior, these guidelines are applied in 
conjunction with an evaluation of the whole person. An administrative judge’s 
overarching adjudicative goal is a fair, impartial, and commonsense decision. An 
administrative judge must consider all available, reliable information about the person, 
past and present, favorable and unfavorable. 
 
 The Government reposes a high degree of trust and confidence in persons with 
access to classified information. This relationship transcends normal duty hours and 
endures throughout off-duty hours. Decisions include, by necessity, consideration of the 
possible risk the applicant may deliberately or inadvertently fail to safeguard classified 
information. Such decisions entail a certain degree of legally permissible extrapolation 
about potential, rather than actual, risk of compromise of classified information. 
 
Clearance decisions must be made “in terms of the national interest and shall in 
no sense be a determination as to the loyalty of the applicant concerned.”  See Exec. 
Or. 10865 § 7. Thus, a decision to deny a security clearance is merely an indication the 
applicant has not met the strict guidelines the President and the Secretary of Defense 
have established for issuing a clearance. 
 
 Initially, the Government must establish, by substantial evidence, conditions in 
the personal or professional history of the applicant that may disqualify the applicant 
from being eligible for access to classified information. The Government has the burden 
of establishing controverted facts alleged in the SOR. See Egan, 484 U.S. at 531.  
“Substantial evidence” is “more than a scintilla but less than a preponderance.”  See v. 
Washington Metro. Area Transit Auth., 36 F.3d 375, 380 (4th Cir. 1994). The guidelines 
presume a nexus or rational connection between proven conduct under any of the 
criteria listed therein and an applicant’s security suitability. See ISCR Case No. 92-1106 
at 3, 1993 WL 545051 at *3 (App. Bd. Oct. 7, 1993).   
 
 Once the Government establishes a disqualifying condition by substantial 
evidence, the burden shifts to the applicant to rebut, explain, extenuate, or mitigate the 
facts. Directive ¶ E3.1.15. An applicant “has the ultimate burden of demonstrating that it 
is clearly consistent with the national interest to grant or continue his security 
clearance.” ISCR Case No. 01-20700 at 3 (App. Bd. Dec. 19, 2002). “[S]ecurity 
clearance determinations should err, if they must, on the side of denials.” Egan, 484 
U.S. at 531; see AG ¶ 2(b).  
 
Analysis 
 
Guideline H, Drug Involvement 
 
 The SOR alleges Applicant used marijuana in 1976 (¶ 1.a), used cocaine with 
varying frequency from 1985 to 2006 (¶ 1.b), was treated for cocaine abuse in 2005 (¶ 
1.c), purchased cocaine in 2006 (¶ 1.d), and was diagnosed with cocaine dependence 
 
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by a medical doctor in June 2006 (¶ 1.e). Applicant admitted all these allegations, and 
his admissions are corroborated by the evidence presented by Department Counsel and 
Applicant’s testimony at the hearing. 
 
The concern under this guideline is as follows: AUse 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.@ AG ¶ 
24. Guideline H encompasses Adrugs, 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).” AG ¶ 
24(a)(1).  
 
The evidence raises the following disqualifying conditions under this guideline: 
 
AG ¶ 25(a): any drug abuse, defined in AG ¶ 24(b) as “the illegal use of a 
drug or use of a legal drug in a manner that deviates from approved 
medical direction;  
 
AG ¶ 25(c): illegal drug possession, including cultivation, processing, 
manufacture, purchase, sale, or distribution; or possession of drug 
paraphernalia; and 
AG ¶ 25(d): diagnosis by a duly qualified medical professional (e.g., 
physician, clinical psychologist, or psychiatrist) of drug abuse or drug 
dependence. 
 Since the Government produced substantial evidence to raise the disqualifying 
conditions in AG ¶¶ 25(a), (c), (d), and (g), the burden shifted to Applicant to produce 
evidence to rebut, explain, extenuate, or mitigate the facts. 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. Sep. 22, 
2005).   
 
 Security concerns under this guideline may be mitigated if “the behavior 
happened so long ago, was so infrequent, or happened under such circumstances that 
it is unlikely to recur or does not cast doubt on the individual's current reliability, 
trustworthiness, or good judgment.” AG ¶ 26(a). The first prong of AG ¶ 26(a) 
(Ahappened so long ago@) focuses on whether the drug involvement was recent. There 
are no Abright line@ rules for determining when conduct is Arecent.@ The determination 
must be based on a careful evaluation of the evidence. If the evidence shows Aa 
significant period of time has passed without any evidence of misconduct,@ then an 
administrative judge must determine whether that period of time demonstrates Achanged 
circumstances or conduct sufficient to warrant a finding of reform or rehabilitation.@ 
ISCR Case No. 02-24452 at 6 (App. Bd. Aug. 4, 2004).  
 
 
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 Applicant’s abstinence from drugs for two and a half years, standing alone, is a 
“significant period of time.” However, it is less significant in the context of 21 years of 
cocaine use, including frequent use and relapse after treatment in 2005 and 2006. 
Although Applicant has an informal sponsor, he has no formal support structure, and he 
has not been evaluated by a medical professional since his diagnosis of cocaine 
dependence in 2006. After considering the totality of the evidence, I am not satisfied 
that his abstinence from cocaine since January 2008 is sufficient to demonstrate reform 
or rehabilitation. Thus, I conclude that the first prong of AG ¶ 26(a) is not established.  
 
 Applicant’s drug use was frequent and did not occur under circumstances making 
it unlikely to recur. Although Applicant is no longer married, he still faces job-related 
stress, loneliness, and concerns about his ailing father. I conclude that AG ¶ 26(a) is not 
established. 
 
Security concerns also may be mitigated by “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.” AG ¶ 26(b). Applicant no longer socializes 
with drug users, but instead is focused on his job and his ailing father. He has changed 
jobs and terminated his troubled marriage. I conclude AG ¶ 26(b)(1) and (2) are 
established. AG ¶ 26b(3) is not established for the reasons set out above in the 
discussion of AG 26(a). There is no evidence of the statement of intent required for AG 
¶ 26(d)(4). 
 
Security concerns also may be mitigated by Asatisfactory 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.@ AG ¶ 26(d). Applicant completed a drug treatment 
program, but he has abused drugs since completing the program, and he has not 
received a favorable prognosis. I conclude AG ¶ 26(d) is not established. 
 
Guideline E, Personal Conduct 
 
The SOR alleges Applicant falsified his security clearance application by failing to 
disclose the extent of his illegal drug use (¶ 2.a), intentionally failing to disclose his 
treatment by a mental health professional (¶ 2.b), and falsifying material facts about the 
extent of his illegal drug use during his interview with a security investigator (¶ 2.c). It 
also alleges he left a job by mutual agreement in September 2006, after his supervisor 
claimed that his work was not satisfactory (¶ 2.d). Finally, it cross-alleges his episode of 
shooting at a wall after using cocaine, alleged under Guideline I. Applicant admitted his 
falsifications in his response to the SOR and at the hearing, and he disclosed the 
circumstances of his job loss on his security clearance application. 
 
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 The concern under this guideline is set out in AG ¶ 15 as follows:  
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.   
 Applicant’s admissions and the evidence of record establish two disqualifying 
conditions related to his lack of candor during the security clearance process: AG ¶ 
16(a) (deliberate omission, concealment, or falsification of relevant facts from any 
personnel security questionnaire) and AG ¶ 16(b) (deliberately providing false or 
misleading information concerning relevant facts to an investigator).  
 Security concerns raised by false or misleading answers on a security clearance 
application or during a security interview may be mitigated by showing that “the 
individual made prompt, good-faith efforts to correct the omission, concealment, or 
falsification before being confronted with the facts.” AG ¶ 17(a). This mitigating 
condition is not established because Applicant made no effort to correct his omissions 
and misstatements until confronted with the evidence.  
 
The evidence of the circumstances surrounding Applicant’s job loss alleged in 
SOR ¶ 2.d is sparse. The limited evidence in the record strongly suggests that he left 
his job because his supervisor considered his technical performance substandard. 
While substandard performance could be related to drug use, it also could be 
attributable to inadequate training or the other stressors in his life, such as his mother’s 
failing health, his father’s dementia, and his marital breakup. Although the quantum of 
evidence required to raise a security concern is low, I am not satisfied that anything has 
been established about his job termination that has security significance. Thus, I will 
resolve SOR ¶ 2.d in Applicant’s favor.  
 
The episode alleged in SOR ¶¶ 2.e and 3.a, in which Applicant thought about 
committing suicide, fired a gun into a wall, and then fabricated a story about hearing 
voices raises the following disqualifying conditions under this guideline: 
AG ¶ 16(c): credible adverse information in several adjudicative issue 
areas that is not sufficient for an adverse determination under any other 
single guideline, but which, when considered as a whole, supports a 
whole-person assessment of questionable judgment, untrustworthiness, 
unreliability, lack of candor, unwillingness to comply with rules and 
regulations, or other characteristics indicating that the person may not 
properly safeguard protected information; 
 
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AG ¶ 16(d): credible adverse information that is not explicitly covered 
under any other guideline and may not be sufficient by itself for an 
adverse determination, but which, when combined with all available 
information supports a whole-person assessment of questionable 
judgment, untrustworthiness, unreliability, lack of candor, unwillingness to 
comply with rules and regulations, or other characteristics indicating that 
the person may not properly safeguard protected information. This 
includes but is not limited to consideration of . . . a pattern of dishonesty or 
rule violations; and  
AG ¶ 16(e): personal conduct, or concealment of information about one's 
conduct, that creates a vulnerability to exploitation, manipulation, or 
duress, such as . . . engaging in activities which, if known, may affect the 
person's personal, professional, or community standing.  
 Security concerns raised by personal conduct may be mitigated if “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”. AG ¶ 17(c). The incident 
happened four years ago. It occurred under unique circumstances, with a confluence of 
family illness, job stress, and marital strife. On the other hand, firing a gun is inside an 
inhabited building is not a “minor” offense, because it could have resulted in injury or 
death. While there is no evidence that Applicant had subsequent suicidal thoughts, 
there have been several incidents in which Applicant has intentionally provided false 
information to avoid embarrassment. Except for his own testimony, there is no evidence 
from medical professionals, friends, colleagues, or supervisors that he has overcome 
his cocaine dependence, depression, or suicidal thoughts. The credibility of his 
testimony is impaired by his record of falsification. The record leaves me with doubts 
about his current reliability, trustworthiness, and good judgment. Thus, I conclude that 
AG ¶ 17(c) is not established.  
Security concerns raised by personal conduct may be mitigated if “the individual 
has acknowledged the behavior and obtained counseling to change the behavior or 
taken other positive steps to alleviate the stressors, circumstances, or factors that 
caused untrustworthy, unreliable, or other inappropriate behavior, and such behavior is 
unlikely to recur.” AG ¶ 17(d). Applicant acknowledged his behavior at the hearing, but 
there is no evidence that the psychological testing prescribed upon Applicant’s 
admission to the psychiatric facility was completed. There is no evidence other than his 
testimony, which is of limited credibility, that he has alleviated the stressors that caused 
his behavior. Thus, there is an inadequate evidentiary basis for a reliable prediction 
about its recurrence. I conclude AG ¶ 17(d) is not established. 
Finally, security concerns under this guideline may be mitigated if “the individual 
has taken positive steps to reduce or eliminate vulnerability to exploitation, 
manipulation, or duress.” AG ¶ 17(e). Applicant’s vulnerability to exploitation, 
manipulation, or duress cannot be reliably evaluated without evidence, other than his 
 
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testimony, that he has overcome his cocaine dependence and the depression that 
apparently caused his behavior and his fabricated explanation for it. I conclude AG ¶ 
17(e) is not established. 
Guideline I, Psychological Conditions 
 
 The SOR alleges that Applicant stated, during a “biopsychosocial assessment,” 
that he fired a gun at a wall or ceiling because he heard voices (¶ 3.a). The security 
concern under this guideline is set out in AG ¶ 27 as follows: 
 
Certain emotional, mental, and personality conditions can impair 
judgment, reliability, or trustworthiness. A formal diagnosis of a disorder is 
not required for there to be a concern under this guideline. A duly qualified 
mental health professional (e.g., clinical psychologist or psychiatrist) 
employed by, or acceptable to and approved by the U.S. Government, 
should be consulted when evaluating potentially disqualifying and 
mitigating information under this guideline. 
 The relevant disqualifying condition under this guideline is AG ¶ 28(a): “behavior 
that casts doubt on an individual's judgment, reliability, or trustworthiness that is not 
covered under any other guideline, including but not limited to emotionally unstable, 
irresponsible, dysfunctional, violent, paranoid, or bizarre behavior.” The limited evidence 
establishes cocaine dependence and an adjustment disorder with depressed mood. The 
record does not reflect any further testing or evaluation. The accuracy of the diagnosis 
is compromised by Applicant’s testimony that he fabricated some of the facts regarding 
hearing voices because he was embarrassed by his suicidal thoughts. Notwithstanding 
the absence of medical evidence, Applicant’s testimony establishes that he thought 
about suicide and fired a gun into a wall. Such conduct was irresponsible, dysfunctional, 
violent, and bizarre, and is sufficient to raise AG ¶ 28(a).  
 The relevant mitigating conditions are AG ¶ 29(d) (“the past emotional instability 
was a temporary condition (e.g., one caused by death, illness, or marital breakup), the 
situation has been resolved, and the individual no longer shows indications of emotional 
instability”) and AG ¶ 29(e) (“there is no indication of a current problem”). Applicant has 
dealt with the death of his mother, found another job, and adjusted to the breakup of his 
marriage. However, other than his testimony, there has been no evidence, such as 
further professional evaluation or testimony of friends, coworkers, and supervisors, to 
show that he “no longer shows indications of emotional instability” or “a current 
problem.” I conclude that AG ¶¶ 29(d) and (e) are not established.  
 
Whole-Person Concept 
 
 Under the whole-person concept, an administrative judge must evaluate an 
applicant’s eligibility for a security clearance by considering the totality of the applicant’s 
conduct and all the relevant circumstances. An administrative judge should consider the 
nine adjudicative process factors listed at AG ¶ 2(a):  
 
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(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 have incorporated my 
comments under Guidelines H, E, and I in my whole-person analysis. Some of the 
factors in AG ¶ 2(a) were addressed under those guidelines, but some warrant 
additional comment. 
 
 Applicant was remorseful at the hearing. He appears to be trying hard to leave 
his troubled past behind him, but the record is devoid of evidence showing the current 
status of his cocaine dependence and psychological health. His multiple falsifications 
during the security clearance process raise grave doubts about his current reliability, 
trustworthiness, and good judgment. 
 
 After weighing the disqualifying and mitigating conditions under Guidelines H, E, 
and I, and evaluating all the evidence in the context of the whole person, I conclude 
Applicant has not mitigated the security concerns based on drug involvement, personal 
conduct, and psychological conditions. Accordingly, I conclude he has not carried his 
burden of showing that it is clearly consistent with the national interest to grant him 
eligibility for access to classified information. 
 
Formal Findings 
 
 I make the following formal findings on the allegations in the SOR: 
 
 Paragraph 1, Guideline H, Drug Involvement:  AGAINST APPLICANT 
 
  Subparagraphs 1.a-1.e:    Against Applicant 
 
 Paragraph 2, Guideline E, Personal Conduct:  AGAINST APPLICANT 
 
  Subparagraphs 2.a-2.c:    Against Applicant 
  Subparagraph 2.d:     For Applicant 
  Subparagraph 2.e:     Against Applicant 
 
 Paragraph 3, Guideline I, Psychological Conditions: AGAINST APPLICANT 
 
  Subparagraph 3.a:     Against Applicant 
 
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Conclusion 
 
 In light of all of the circumstances, 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. 
 
 
 
 
LeRoy F. Foreman 
Administrative Judge