1
                                                             
                           
                        DEPARTMENT OF DEFENSE
         DEFENSE OFFICE OF HEARINGS AND APPEALS
          
            
In the matter of: )
)
------------------ )       ISCR Case No. 09-05176
SSN: ----------- )
)
Applicant for Security Clearance )
Appearances
For Government: Ray T. Blank, Jr., Esq., Department Counsel
For Applicant: Pro se
                                                                            
______________
Decision
______________
MARSHALL, Jr., Arthur E., Administrative Judge:
On March 24, 2010, the Defense Office of Hearings and Appeals (DOHA) issued
to Applicant a Statement of Reasons (SOR) enumerating security concerns under
Guideline F (Financial Considerations). 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
adjudicative guidelines (AG).
In an April 12, 2010, answer to the SOR, Applicant admitted, with explanations,
four of the nine allegations set forth under Guideline F. She also requested a hearing
before an administrative judge. DOHA assigned the case to me on May 6, 2010. The
parties proposed a hearing date of June 10, 2010. A notice setting that date for the
hearing was issued on May 17, 2010. It was reissued with a different hour for the
hearing on June 1, 2010. I convened the hearing as scheduled. She gave testimony
and offered documents which were accepted into the record without objection as
exhibits (Exs.) A-B. The Government introduced seven documents that were accepted
into the record without objection as Exs. 1-7. Applicant was given until July 1, 2010, to
submit additional documents. DOHA received the transcript of the proceeding (Tr.) on
 Tr. 28.      1
 Tr. 30.      2
 Tr. 32.      3
2
June 17, 2010. On June 28, 2010, Applicant submitted six additional documents to
Department Counsel, who forwarded them to me on July 1, 2010, with no objection.
They were admitted into the record as Exs. C-H and the record was closed. Based on a
thorough review of the testimony, submissions, and exhibits, I find Applicant failed to
meet her burden regarding the security concerns raised. Security clearance denied.
Findings of Fact
Applicant is a 62-year-old senior contract specialist who has worked for her
current employer, a defense contractor, since June 2009. Applicant first had a security
clearance granted in approximately 1993 when working for a previous employer. She
applied for another security clearance in 2007 while working for her former employer.
When she started her present job, she was unaware that her 2007 security clearance
application had not been approved. Applicant has a bachelor of science degree in
business administration with a procurement and contracts management certification
from a leading university. She is currently single and has three adult children.
Applicant was divorced in the late 1980s. In 1995, she received financial
counseling and filed for bankruptcy. She pursued bankruptcy because she could no
longer afford the mortgage payments on a home she bought after her divorce. While
two of her children were grown and had left her home by that time, one child still lived
with her. Absolved of debt, she continued to live on a tight budget.1
Also in 1995, Applicant started a new job as a contracts specialist. She
continued with that job until March 1996, when she was dismissed from her position.
She appealed the dismissal and it was eventually determined that her dismissal was a
wrongful termination, but she was not rehired.  A period of unemployment followed. In2
October 1997, she found similar work as a contractor. 
Applicant was terminated from that position in about January 2003. Feeling that
her dismissal was another wrongful termination, she tried to contest her dismissal while
continuing her complaint against her former employer’s wrongful termination. She found
it difficult to fight what she considered two wrongful terminations simultaneously. She
lived on her 401k savings until they were depleted. With funds low, she worked with her
apartment management for a while regarding her rent payments, but she was
eventually evicted.  One son had Applicant move in with him in another state. She3
contacted the lender on a vehicle loan about her situation. In about September 2003,
however, her 1996 BMW was repossessed. After a while, she moved to a local shelter
while her church put her possessions into storage. She looked for work, but the region
 Tr. 34.      4
 Tr. 33.      5
 Tr. 38.      6
 Tr. 39.      7
 Tr. 40.      8
 Tr. 40-41.      9
 Ex. 1 (Application, dated Aug. 27, 2007). Having applied for a security clearance previously, Applicant was      10
aware that “finances could be a problem for people” applying for a security clearance. Tr. 78-79.
3
was economically stagnant.  From the shelter, she was unable to maintain contact with4
her mounting creditors.  5
In March 2004, Applicant returned to her prior state of residence to look for work
and try to get unemployment benefits. She stayed with acquaintances, then in a shelter
before returning to live with her son. By September 2004, she was offered a position
back in her original area of residence. She returned to that area. There, she stayed with
her other son, who lived nearby. She immediately started looking for an apartment by
public transportation. She found an apartment in an ideal neighborhood. The rent was
more than she could afford, but the landlord was willing to work with her.  Once she6
started work around September 7, 2004, she tried to catch up on her rent, which was
about $1,500 to $1,600 per month.  Now generating an income, Applicant tried to get7
control of her finances. Just as she started to do so, a garnishment was imposed
against her wages for delinquent student loans, reducing her net monthly income.  In8
March 2006, her employer reorganized. Applicant was unwilling to relocate with her
division and, consequently, she lost her job.  She took her two weeks of severance pay9
and started looking for another position.
In April 2006, Applicant found contract work that lasted until August 2006, just
before she accepted a new job as a senior subcontract administrator. That job expired
in June 2007, at which time she accepted a new position she thought would be ideal.
She started that job in July 2007. She completed her security clearance application on
August 27, 2007. On the application, she noted that she had her wages garnished or
had property repossessed in the preceding seven years. In the section for additional
information, she noted her 2003 eviction and referenced her student loan
garnishment.  She admitted currently having debts over 90 days delinquent and to10
having been over 180 days delinquent on debts within the preceding seven years. In
the space provided, she noted the repossessed car. 
Applicant’s supervisor gave her a promotion, but then left the organization.
Applicant’s new supervisor nullified the promotion and placed someone else in the job.
Applicant protested the substitution. After five months of fighting the issue, she was
terminated in January 2008. Feeling the termination was wrongfully motivated, she filed
 Tr. 43.      11
 Tr. 44.      12
 Tr. 49.      13
 Tr. 50, 87-88. See SOR allegations ¶¶ 1.a and 1.c, respectively. Reference is also made that indicates      14
concern was expressed regarding a collection entity-related debt. It is unclear whether that entity was a
predecessor to the collection agent for the delinquent apartment debt. Regardless, Applicant stated she could
not identify the account. Ex. A (E–mails, dated Jun. 29, 2009).
 Tr. 50-52, 57-58; Ex. A, supra, note 14, linking the apartment, collection agent, and owners.      15
 Tr. 52.      16
 Tr. 53.      17
 Id.      18
 Tr. 59.      19
 Tr. 54.      20
 Tr. 55.      21
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a complaint with the state’s human rights department.  She later filed an EEOC11
complaint, which is still pending.  She quickly found temporary work that lasted from12
January 2008 until March 2008, which was immediately followed by a job that lasted
from March 2008 until September 2008. Within a month she started work for another
employer from October 2008 through June 2009. She started her present position in
July 2009.
In 2009, Applicant was still “flailing” in debt.  That summer, she considered13
buying a house. She checked her credit report and met with a lender. She was told that
she could qualify for an FHA loan of about $729,000, except for two negative entries on
her credit report, an adverse county judgment for $1,939 and the debt owed to the
apartment complex from which she had been evicted for $3,681.  It was shown that the14
judgment was for the agent collecting debts for the apartment complex.  Noting the15
discrepancy between the two debts, Applicant asked the apartment’s corporate owners
how she could resolve what should be only one actual obligation.  She was told she16
could pay them directly. Unsure whether payment to them would also satisfy the
adverse judgment, Applicant did not know how to proceed.  She reported her findings17
to the bank, who told her it could not proceed with the FHA loan until both negative
credit report entries were resolved.  They remain unresolved.18 19
Applicant did not pursue financial counseling.  Instead, she consulted an20
attorney to help her address her debts. She was advised that the original owners of
obligations that have been charged-off would not have her account information. “So, if
you try to pay them, you’re not looking at the original amount you owed. You’re looking
at whatever you can work with for the collections agencies. . . .”  Having lost some21
 Id.      22
 Tr. 55-56.      23
 At Ex. D (Letter, dated Jun. 28, 2010), Applicant is worried that the record will include personal identi-      24
fying information. Such information is redacted from any public copies of this decision before publication,
including name and personal information in the caption. 
 Tr. 59-60.      25
 Tr. 61.      26
 Tr. 63.      27
 Tr. 65.      28
 Ex. D, supra, note 24, at 1.      29
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paperwork when she was evicted, she did not try to address such debts. While noting
that it is hard to commit to payments when one does not have a steady income,
Applicant stated: “I haven’t fixed this debt stuff. And I don’t quite know how to fix it.”22
She noted that she is trying to “build [her] life with a steady income. And [she] will have
to do what [she has] to do with the debt.”  23
At issue in the SOR are the following allegations, each reflecting a delinquent
debt:24
1.a – Adverse judgment for approximately $1,939. Unresolved. This judgment concerns
the collection effort by an attorney representing the corporate ownership of the
apartment from which Applicant was evicted, as discussed above.
1.b – Medical debt for approximately $260. Unresolved. Applicant cannot identify this
debt, which was acquired around 2003.  She is thinking of disputing the entry with the25
credit reporting bureaus.26
1.c – Collection account for approximately $3,681. Unresolved. This debt concerns that
debt arising from Applicant’s apartment eviction, as discussed above.
1.d – Medical debt for approximately $282. Unresolved. Applicant cannot identify this
debt.  There is no evidence this entry has been disputed.27
1.e – Collection account for approximately $2,501. Unresolved. At the hearing,
Applicant was unaware of the origin of this account. She was given contact information
for the creditor.  After the hearing, Applicant reported that the source from which the28
listed creditor, a collection agency, obtained the underlying debt is also a collection
agency.  She noted that she would be “unable to satisfy the original debt by making yet29
another commitment to a new lender. This would only serve to create new debt as
 Id.      30
 Ex. E (Partial statement, dated Jun 8, 2010) and copy of untransacted check, dated Jun. 13, 2010).      31
 Id.      32
 Ex. G (Student loan garnishment letter, dated Nov. 15, 2005, and received on Nov. 21, 2005).      33
 Id. stating that unless an exception is claimed, payment to the creditor is to be made from the “debtors      34
wages an amount not to exceed ten percent (10%) of the debtors disposable pay for each pay period. . . .”
 Ex. D, supra, note 24; Ex. 5 (Credit report, dated Sep. 7, 2007).      35
 Tr. 70-71.      36
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opposed to paying off old debt.”  She did not explain how paying the collection agent30
would not satisfy the original obligation.
1.f – Collection account for approximately $148. Insufficient evidence of satisfaction. In
her June 28, 2010, post-hearing submission materials, Applicant submitted a portion of
a June 8, 2010, statement indicating that the current balance of $148.43 could be
settled by payment of $25.  On the same statement page is a copy of the front of a31
check, dated June 13, 2010, payable to the creditor at issue for $25.  The check,32
however, does not show that it has been transacted. There is no additional evidence,
such as a bank, on-line, or ATM statement showing that the check was transacted and
cleared, nor is there documentary evidence that the check was mailed or received.
1.g – Charged-off account balance for approximately $3,042. Insufficient evidence of
satisfaction. This balance, shown as being for $2,926.03, is for a delinquent student
loan for which garnishment was to be applied on Applicant’s first pay check after receipt
of a November 15, 2005, notice.  It was stamped as received by Applicant’s payroll33
office on November 21, 2005. This occurred while Applicant was at the job she
maintained from September 2004 through March 2006. Applicant’s Ex. G consists of
only the first page of the garnishment letter, so all the terms are unknown. Handwritten
on the garnishment letter is “(RB Paid in Full)”; the “RB” is similar to the “RB” initials
Applicant made on her Answer to the SOR  The notation is not dated. There is no
evidence of payroll deductions between December 2005 and March 2006 or evidence
showing the amount of any deductions. There is no evidence that presumed deductions
over four months could have completely satisfied the $2,926.30 balance cited.  In her34
post-hearing correspondence, Applicant also points to her 2007 credit report for
evidence that the debt was paid, but does not specify which of the multiple entries
noted under the bank’s name or the lender’s name reflects the account at issue as
paid.  Many of the entries have similarly parsed account numbers reflected on her35
credit report. Applicant was given contact information regarding this account to obtain
verification of satisfaction, but no verification was submitted.  36
 Tr. 74.      37
 Id.      38
 Ex. D, supra, note 24.      39
 Tr. 79.      40
 Id.      41
 Tr. 80.      42
 Tr. 84.      43
 Id.      44
 Tr. 81.      45
 Tr. 89.      46
 Tr. 92.      47
 Tr. 93.      48
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1.h – Repossession-related debt for approximately $11,625. Unresolved.  This debt
was incurred as a result of the repossession of Applicant’s 1996 BMW vehicle in 1993.
There is no evidence Applicant has addressed this debt.
1.i – Charged-off account balance of approximately $494. Unresolved. Applicant
believes this debt, for an account opened in 2003, might have been incurred for
automobile tires.  She was given contact information for the listed creditor.  In her37 38
post-hearing submission, Applicant wrote that the entity was unable to locate her
account.  39
In 2009, Applicant told interviewers that she was living paycheck-to-paycheck.40
At that time, she had not contacted her creditors since 2003.  Between that time and41
the hearing, Applicant had only contacted her former apartment building and those
parties named in her adverse judgment related to that rental property.  Applicant relied42
on her attorney’s representation that to address delinquent debts for which the creditors
have not maintained contact and which will soon come off her credit report due to age
would raise the issue of “how would [she] pay them if [she] opened it all back up?”43
She also could not decide how to prioritize one creditor over another.  She has not44
made progress on her debts because she needs stability and a stable job to honor her
debts.45
Applicant’s current net monthly income is about $6,000.  She has not pursued46
debt consolidation because her son “is very good with things like that.”  Her son has47
not helped her financially, but Applicant has recently provided financial assistance to all
three of her adult children.  Aiding her children did not cause her any types of48
 Tr. 94.      49
 Id.d      50
 See also ISCR Case No. 94-1075 at 3-4 (App. Bd. Aug. 10, 1995).      51
 ISCR Case No. 93-1390 at 7-8 (App. Bd. Jan. 27, 1995).      52
8
problems related to her monthly obligations because she is now “getting to the point
where [she] can try to put a little money aside so that [she] can establish a [financial]
plan.”  She currently has savings worth approximately “a couple of months rent.”49 50
Policies
When evaluating an applicant’s suitability for a security clearance, an
administrative judge must consider the AG. In addition to brief introductory explanations
for each guideline, the AG list potentially disqualifying conditions and mitigating
conditions. 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 overarching
adjudicative goal is a fair, impartial, and commonsense decision. Under AG ¶ 2(c), this
process is a conscientious scrutiny of a number of variables known as the “whole-
person concept.” The administrative judge must consider all 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
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.
The Government must present evidence to establish controverted facts alleged
in the SOR. An 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 burden of proof is something less than a51
preponderance of evidence. The ultimate burden of persuasion is on the applicant.  52
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 the applicant may deliberately or inadvertently fail to safeguard
classified information. Such decisions entail a certain degree of legally permissible
extrapolation of potential, rather than actual, risk of compromise of classified
information.
 Id.      53
 Id.      54
 AG ¶ 18.      55
 Applicant provided sufficient evidence to show that the two related allegations concern the same debt,      56
but only provided testimony related to her inquiries regarding the debt.
 Any breaks between jobs these jobs, given Applicant’s evidence regarding her dates of unemployment,      57
would have been brief.
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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). “The clearly consistent standard
indicates that security clearance determinations should err, if they must, on the side of
denials.”  Any reasonable doubt about whether an applicant should be allowed access53
to sensitive information must be resolved in favor of protecting such sensitive
information.54
Based upon consideration of the evidence, Guideline F (Financial
Considerations) is pertinent to this case. Conditions pertaining to this AG that could
raise a security concern and may be disqualifying, as well as those which would
mitigate such concerns, are set forth and discussed below.
Analysis
Under Guideline F, “failure or an inability to live within one’s means, satisfy
debts, and meet financial obligations may indicate poor self-control, lack of judgment, or
an unwillingness to abide by rules and regulations, all of which can raise questions
about an individual’s reliability, trustworthiness and ability to protect classified
information.”  The guideline sets out several potentially disqualifying conditions. Here,55
Applicant incurred several delinquent debts, mostly between 2003 and 2005, amounting
to approximately $20,300 to $22,000, depending which allegation regarding her post-
eviction apartment-related debt best reflects her present obligation status.  She has56
not made contact with most of her creditors in several years. The vast majority, if not all,
of the debt at issue remains unpaid and unaddressed. Such facts are sufficient to raise
Financial Considerations Disqualifying Condition (FC DC) AG ¶ 19(a) (inability or
unwillingness to satisfy debts) and FC DC AG ¶ 9(c) (a history of not meeting financial
obligations). With such conditions raised, the burden shifts to Applicant to overcome the
case against her and mitigate security concerns. 
Applicant has struggled with financial difficulty for some time. Applicant states
that she has been unable to address these debts because she has not had stable
employment. However, the last significant break in Applicant’s employment history
occurred between January 2003 and September 2004. Since September 2004, she has
been continuously employed in various capacities. There is no evidence that she
suffered from any noteworthy periods of unemployment between those jobs.  Indeed,57
10
when one employer reorganized in 2006, she chose to remain in her present area of
residence and accept severance pay rather than relocate with her position in March
2006, leaving her to accept contracted work in April 2006. Moreover, the majority of the
delinquent debts at issue have largely been neglected for at least five years. She has
only initiated contact with a few of her creditors since 2003. At present, she has no finite
plan for addressing her delinquent debts. Consequently, Financial Considerations
Mitigating Condition (FC MC) AG ¶ 20(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)
does not apply. 
In 2003, Applicant was unexpectedly terminated from her job. This led to a
period of unemployment that lasted for over a year-and-a-half. During this time, she
moved several times and lost contact with her creditors, although she did try to work
with her apartment management and the lender on her automobile. While subsequent
temporary and contracting jobs may not have given her the sense of stability she seeks,
Applicant’s unemployment between January 2003 and September 2004 is sufficient to
raise FC MC AG ¶ 20(b) (the conditions that resulted in the behavior were largely
beyond the person’s control (e.g., loss of employment, a business downturn,
unexpected medical emergency, or a death, divorce or separation) and the individual
acted responsibly under the circumstances) with regard to the delinquent debts incurred
during that time period. 
Applicant has not received financial counseling and there is scant evidence she
has earnestly worked with her various creditors in the past few years, obviating
application of FC MC ¶ 20(c) (the person has received or is receiving counseling for the
problem and/or there are clear indications that the problem is being resolved or is under
control).
Wage garnishment is a reactive form of repayment that does not involve debtor’s
initiative. The same can be said of a repossession. While there is some evidence that
Applicant tried to resolve the seemingly conflicting debts owed to her former rental
property’s management, she declined to follow-up on her efforts. Her acceptance and
satisfaction of a settlement by payment of $25 to one creditor is not supported by the
evidence submitted. The rest of the debts at issue remain unaddressed. There is no
evidence she has formally disputed any of these debts with any of the three leading
credit reporting bureaus. Consequently, FC MC ¶ 20(d) (the individual initiated a good-
faith effort to repay overdue creditors or otherwise resolve debts) does not apply.
Applicant admits that little progress has been made on her debts and that she
has had minimal to no contact with most of her creditors for several years. She provided
no present ability to satisfy these debts, although she has savings equal to a few
months of rent in her control and she recently provided all three of her adult children
with financial assistance. She also demonstrated a lack of understanding with regard to
several areas of personal finance, including how collections for an underlying debt are
conducted and satisfied, as well as the use of credit report disputes to question or verify
an account. Even assuming sufficient evidence existed to show that those debts cited
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at SOR allegations ¶¶ 1.f and 1.g have been satisfied, the facts do not support a finding
that Applicant has mitigated financial considerations security concerns.
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 an applicant’s
conduct and all relevant circumstances. An administrative judge should consider the
nine adjudicative process factors listed at AG ¶ 2(a). Under AG ¶ 2(c), the ultimate
determination of whether to grant 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, as well as the “whole-person”
factors. Applicant is a credible woman. She is well-educated, a graduate of a leading
university.  Divorced, she raised three children. She has had the courage to challenge
perceived professional slights with conviction. Between 2003 and 2004, she was
unemployed and endured multiple hardships while seeking work. While her resume
reflects multiple jobs over the past decade, she has worked without serious interruption
since 2004.  
Applicant’s testimony detailed her difficulties while unemployed between 2003
and 2004. It appears that most of the debt at issue was created or became delinquent
during that time. Since about 2003, however, Applicant has had little to no contact with
her various creditors, stating that she has been financially unable to address her debts.
She testified that in 2003, she unsuccessfully tried to work with her landlord and her
BMW car loan holder. She also stated that in 2009, a year when she admitted she was
still struggling to live paycheck-to-paycheck, she tried to reconcile two disparate credit
report entries for the same debt arising from her 2003 eviction. Her motivation to exert
this latter effort, however, was the possibility that their resolution could make her eligible
for an FHA home loan of up to about $729,000. Meanwhile, she struggled to make ends
meet and a balance of about $20,000 in other delinquent debt remained virtually
unaddressed. Furthermore, Applicant testified that she is not currently able to pay her
delinquent debts. Elsewhere, however, she testified that she was recently able to
provide financial assistance to her children and that she currently maintains financial
reserves equal to a couple of months of rent payments.
Moreover, Applicant’s understanding of finances and credit is worrisome. No
documentary evidence of a current budget was introduced. She stated that she does
not want to pay one collection agency for an underlying debt because it would create a
new debt, but she failed to explain why she thought such payment would not simply
satisfy the underlying obligation. She also stated that to address delinquent debts for
which her creditors had not maintained contact and which will soon deleted due to age
would renew the obligation, but she failed to explain why she thought that continued
neglect would somehow honor her obligation. Elsewhere, she said she was unable to
prioritize her debts. Such expressions of financial understanding are worrisome,
12
particularly in light of her current reluctance to pursue financial counseling from a
professional financial counselor.
  
The burden in these proceedings is placed squarely on the Applicant to mitigate
the security concerns raised by the allegations. While Applicant’s difficulties in 2003
and 2004 were beyond her control, those circumstances only serve as mitigation for the
creation of the delinquent debt at issue. They do not mitigate the fact that these debts
remain largely ignored and unaddressed today. She presented scant evidence
demonstrating her efforts to address or resolve these debts. As for those medical debts
she does not recognize, she showed no evidence that she has disputed their entry with
any of the three leading credit reporting bureaus. Moreover, regarding those accounts
for which contact information was provided at the hearing, there is no evidence that
contact was made or that any effort was made to resolve their status with their contact
information provided. Applicant continues to live paycheck-to-paycheck, but continues
to live without a paying roommate in a less than modestly priced rental home. From that
same tight budget, she has also been able to provide financial assistance to her adult
children, but not toward some organized and coherent debt repayment plan. In the
absence of substantial progress on the over $20,000 in delinquent debts at issue, and
lacking an established and effective debt repayment plan, financial considerations
security concerns remain unmitigated. Clearance is denied.
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 F: AGAINST APPLICANT
Subparagraphs 1.a-i: Against 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 a security clearance.
Clearance is denied.
ARTHUR E. MARSHALL, JR.
Administrative Judge