1
 
                                                             
                           DEPARTMENT OF DEFENSE
         DEFENSE OFFICE OF HEARINGS AND APPEALS
          
            
In the matter of: )
)
)       ISCR Case No. 10-01284
)
)
Applicant for Security Clearance )
Appearances
For Government: Nichole Noel, Esquire, Department Counsel
For Applicant: Pro se  
______________
Decision
______________
HENRY, Mary E., Administrative Judge:
Based upon a review of the pleadings, exhibits, and testimony, I deny Applicant’s
eligibility for a security clearance.
Statement of the Case
Applicant signed an Electronic Questionnaire for Investigations Processing (e-
QIP) version of a security clearance application (SF-86) on January 25, 2006. The
Defense Office of Hearings and Appeals (DOHA) issued Applicant a Statement of
Reasons (SOR) on July 26, 2010 detailing security concerns under Guideline B, Foreign
Influence, that provided the basis for its preliminary decision to deny him a security
clearance. 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 on September 1, 2006. 
2
 
Applicant acknowledged receipt of the SOR on August 2, 2010. He answered the
SOR in writing on August 10, 2010, requesting a hearing before an administrative judge.
DOHA received the request on August 12, 2010, and Department Counsel was
prepared to proceed on August 19, 2010. I received the case assignment on October 4,
2010. DOHA issued a notice of hearing on October 26, 2010, and I convened the
hearing as scheduled on November 18, 2010. The Government offered two exhibits
(GE) 1 and 2, which were received and admitted into evidence without objection.
Applicant testified. He submitted nine exhibits (AE) A through I, which were received
and admitted into evidence without objection. The record closed on November 18, 2010.
DOHA received the transcript of the hearing (Tr.) on December 3, 2010.
Procedural and Evidentiary Rulings
Notice
Applicant received the hearing notice on November 5, 2010, less than 15 days
before the hearing. (Tr. 8.) I advised Applicant of his right under ¶ E3.1.8 of the
Directive to receive the notice 15 days before the hearing. Applicant affirmatively waived
his right to the 15-day notice. (Id.) 
Request for Administrative Notice
Department Counsel submitted a formal request that I take administrative notice
of certain facts relating to Peoples Republic of China (PRC). The request and the
attached documents were not admitted into evidence, but were included in the record as
Hearing Exhibit 1, I-XV. The facts administratively noticed will be limited to matters of
general knowledge and matters not subject to reasonable dispute, and are set out in the
Findings of Fact below. 
Findings of Fact
In his Answer to the SOR, Applicant admitted the factual allegations in ¶ 1.a and
some of the facts in ¶ 1.b of the SOR. His admissions are incorporated herein as
findings of fact. He denied the factual allegation in ¶ 1.b, concerning the residence of his
stepson. He also provided additional information to support his request for eligibility for
a security clearance. After a complete and thorough review of the evidence of record, I
make the following additional findings of fact.  
Applicant, who is 50 years old, works as a mechanic for a Department of
Defense contractor. He began his employment with his current employer in 2009. He
previously worked for another Department of Defense contractor in a similar position for
approximately five years. Applicant’s immediate supervisor, a military officer, describes
Applicant as a valued member of their battalion. Applicant spoke candidly with him
about his plans to marry a Chinese national, and Applicant knew his marriage may have
a negative impact on his security clearance. Applicant has little exposure to sensitive
GE 1; GE 2; AE A; Tr. 33-34.1
GE 1; Tr. 19.2
GE 2; Tr. 19-20.3
GE 2; Tr. 23-24, 26-28, 32.4
3
materials in his job and has zero access to any computer networks in the battalion.
Applicant applied for a clearance as it is required for everyone in the unit. His supervisor
does not believe that Applicant is a threat to national security. Applicant stated that he
must use his supervisor’s common access card to enter his work time and does so only
with his supervisor’s permission.1
Applicant married his first wife when he was 17 years old. After 25 years of
marriage, they separated. They divorced in 2005. He has two daughters, ages 32 and
29. Applicant’s daughters, mother, stepfather, and two brothers are United States
citizens by birth and live in the United States. His former wife is a United States citizen
by birth. Her current residence is unknown. Applicant and his family members are not of
Pacific-Asian heritage.2
After his divorce, Applicant met his second wife on an internet website. For
almost two years, they communicated with each other by e-mail and through a web cam
as she lived in the PRC. In 2006, Applicant decided he needed to meet her in person to
decide if their relationship could develop into a long-term relationship. He also knew that
a face-to-face meeting was required by the United States Citizenship and Immigration
Services, formerly known as the United States Immigration and Naturalization Services,
or INS, before he could request a fiance!e visa. He obtained his passport in June 2006
and traveled to her home town in the PRC in September 2006. He stayed three weeks
in her home town. He met her parents, son, brother and friends, and visited her work
place, while in the PRC. He did not encounter any problems during this visit with the
government of the PRC.3
Upon his return from the PRC in the fall of 2006, Applicant applied for a fiance!e
visa. The visa was issued approximately nine months later in 2007. His soon-to-be wife
came to the United States in October 2007 with her 14-year-old son. Applicant and she
married a few days after her arrival in October 2007. About six months later, she and
her son returned to the PRC for a visit, as her mother was ill and her former employer
owed her some money. She stayed for two months at his suggestion. She returned, but
her son remained in the PRC as he missed his friends. Applicant’s stepson returned to
the United States in January 2010 at the insistence of his grandparents. He is a
sophomore in high school, where he is learning English. He plans to attend college in
the United States. His wife and stepson still hold passports from the PRC, as they are
not citizens of the United States. There are no plans for them to travel to the PRC.4
Applicant’s wife earned a bachelor’s degree in engineering from a university in
the PRC. She worked for 20 years as a structural engineer for the city planning
GE 2; AE C; Tr. 20-22, 26-29.5
GE 2; Tr. 24-25.6
GE 2; Tr. 31–32.7
GE 2; Tr. 25, 33.8
GE 2; Tr. 30, 33-349
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commission in her hometown. Her work involved reading construction blueprints,
reviewing construction work for high rise buildings, and conducting site inspections.
After moving to the United States, his wife obtained work as a housekeeper in a hotel.
She learned that her engineering degree would not be accepted in the United States,
and she decided not to return to college for an engineering degree. Rather, she decided
to obtain training in accounting. She is currently enrolled at a technical college. She
expects to receive a certificate in accounting when she completes her program in March
2011. She left her housekeeping job to attend school full-time in the fall of 2010. She
will look for entry level work in accounting when she completes her classes. She has
also taken additional courses in English since arriving in the United States. Applicant
describes her English as “pretty good” as she uses her translator infrequently.5
The parents of Applicant’s wife are retired university professors, who taught
agriculture and farming related subjects. They live in an apartment near the university
where they worked. Their residence is state sponsored and may have been provided to
them in recognition for their many years of work at the university. Applicant does not
know the actual financial arrangement for his parents-in-law’s apartment. Her parents
are not involved in political activities in the PRC.6
Applicant’s mother-in-law does not speak or understand English, and he does not
speak or understand Chinese. Thus, he does not talk with his mother-in-law. His wife
speaks with her mother on a weekly basis. His father-in-law speaks English, and
Applicant has spoken with him on the telephone. When Applicant speaks with his father-
in-law, it is usually a greeting and an inquiry about how he is. To his knowledge, his wife
does not talk with her brother, and does not talk regularly with her father.  7
Since arriving in the United States, his wife has made friends with Chinese
individuals at her school who are married to United States citizens. Applicant and his
wife socialize with her new friends. Her parents have not traveled to the United States
and have no intent to move from the PRC. His wife has one cousin, who lives in the
United States and is married to a United States citizen.8
Applicant’s wife does not own property in the PRC. She is not entitled to any
benefits from the Chinese government and does not have any bank accounts or assets
in the PRC. Her son does not have any assets in the PRC. Applicant and his wife are
buying a house and a car in the United States.9
AE B. 10
Tr. 33-35.11
Hearing Exhibit 1, I-XV.12
5
Applicant’s wife intends to become a United States citizen when she is eligible.
She can read, write, and speak English, a requirement for citizenship. She must also
reside in the United States continuously for three years. She will meet this requirement
in the summer of 2011. She is learning United States history and civics, also a
requirement for citizenship.10
Applicant denied any strong family bonds with his parents-in-law. When asked at
the hearing about what he would do if his wife told him that her parents were being
pressured by the government of the PRC to ask him for classified information, Applicant
responded that there was nothing he could do to help them because he did not intend to
do anything to help the “Chinese” government and cause harm to the United States. He
does not believe his wife’s family would be targeted because he works as a mechanic
and does not have access to classified information. To his knowledge, his wife’s family
has not been pressured by the government of the PRC. Neither he nor his wife has
been approached by anyone connected with the government of the PRC. Applicant’s
wife has not shown any interest in his job. She has not asked any questions about his
work. Applicant drove her to his work site once, but did not take her inside. He wanted
her to know where he worked if she needed to reach him. She has not returned to his
work location and has not been inside his work area, which is not a restricted area.11
 
I take administrative notice of the following facts on the Peoples Republic of
China (PRC). The PRC is an authoritarian, communist party-led state. Human rights
violations continue to be problematic. Concerns regarding the PRC’s weapons
development, theft of classified technology information between 1979 and 1999, and
industrial espionage activities remain. The PRC continues to have active intelligence
operations in the United States, which seek to obtain military and industrial secrets
through Americans of Chinese ancestry. In its efforts to obtain this information, the PRC
often targets individuals with access to classified information. On the other hand, the
PRC supports the United States’s anti-terrorism position and activities. The United
States and the PRC have developed joint trade agreements, resulting in the sale of
goods to each other, and work together on environmental issues. The PCR enjoys a
most favored nation status in trading with the United States. The PRC has opened its
doors to outside investment. Terrorism is rare in the PRC and is mostly related to
criminal activity. The PRC continues to be a safe country for travel.12
Policies
When evaluating an applicant’s suitability for a security clearance, the
administrative judge must consider the adjudicative guidelines. In addition to brief
introductory explanations for each guideline, the adjudicative guidelines list potentially
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disqualifying conditions and mitigating conditions, which are used 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 overarching
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
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, 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. . . .” An
applicant has the ultimate burden of persuasion for 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 an 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 B, Foreign Influence
The security concern relating to the guideline for Foreign Influence is set out in
AG & 6:
7
Foreign contacts and interests may be a security concern if the individual
has divided loyalties or foreign financial interests, may be manipulated or
induced to help a foreign person, group, organization, or government in a
way that is not in United States interests, or is vulnerable to pressure or
coercion by any foreign interest. Adjudication under this Guideline can and
should consider the identity of the foreign country in which the foreign
contact or financial interest is located, including, but not limited to, such
considerations as whether the foreign country is known to target United
States citizens to obtain protected information and/or is associated with a
risk of terrorism. 
Under the potential disqualifying conditions described in AG ¶ 7, the following
conditions could raise a security concern and may be disqualifying in this case:
(a) contact with a foreign family member, business or professional
associate, friend, or other person who is a citizen of or resident in a
foreign country if that contact creates a heightened risk of foreign
exploitation, inducement, manipulation, pressure, or coercion; 
(b) connections to a foreign person, group, government, or country that
create a potential conflict of interest between the individual's obligation to
protect sensitive information or technology and the individual's desire to
help a foreign person, group, or country by providing that information; and
(d) sharing living quarters with a person or persons, regardless of
citizenship status, if that relationship creates a heightened risk of foreign
inducement, manipulation, pressure, or coercion.
Applicant is a U.S. citizen by birth. His mother is also a U.S. citizen by birth as
are his two daughters and two brothers. They live in the United States. His stepfather
and former wife were U.S. citizens by birth. Applicant and his family members are not
descendant’s of a Pacific-Asian heritage. Thus, no security concern is raised by these
family members. Applicant’s wife and stepson are citizens of the PRC, and residents of
the United States. Because they reside in the United States, they do not directly raise a
security concern. His wife’s mother, father, and brother are citizens and residents of the
PRC. Applicant has minimal contact with his wife’s parents, particularly her mother, who
does not speak English. He speaks infrequently to his father-in-law, who can speak
English. He and his wife do not speak to her brother. Applicant’s wife, however, speaks
to her mother on a weekly basis. She speaks infrequently with her father. His stepson
communicates with his friends in the PRC through the Internet. His wife maintains a
normal, familial relationship with her mother, and a somewhat more limited familial
relationship with her father. Applicant met her parents during his visit to the PRC in
2006, but has not visited with them in person since he left the PRC. His wife arrived in
the United States in October 2007. She returned to to the PRC in 2008, but has
otherwise remained in the United States. He does not provide financial support for her
family in the PRC. His wife’s family relationships are not per se a reason to deny
The Government submitted several examples of the PRC targeting naturalized American citizens born in the13
PRC, but no example of the PRC targeting American citizens not of Chinese ancestry. Hearing Exhibit 1, I-XV.
8
Applicant a security clearance, but her contacts with family members must be
considered in deciding whether to grant Applicant a clearance. The Government must
establish that these family relationships create a heightened risk of foreign exploitation,
inducement, manipulation, pressure, or coercion or would create a potential conflict of
interest between his obligations to protect sensitive information and his desire to help
his family members. The Appeal Board has held that there is a rebuttable presumption
that a person has ties of affection for, or obligation to, the immediate family members of
the person’s spouse. See ADP Case No. 08-10099 (App. Bd. Jan. 28, 2011), ISCR
Case No. 03-26176 (App. Bd. Oct. 14, 2005); ISCR Case No. 01-03120 (App. Bd. Feb.
20, 2002).  
In determining if a heightened risk exists, I must look at Applicant’s relationship
and contacts with his wife’s family members as well as the nature of the foreign
government involved, the intelligence gathering history of the PRC, the presence of
terrorist activity within the PRC, and the PRC’s human rights record. See ADP Case No.
08-10099 (App. Bd. Jan. 28, 2011), ISCR Case No. 07-05809 (App. Bd. May 27, 2008).
The risk that an applicant could be targeted for manipulation or induced into
compromising classified information is real, not theoretical. Applicant’s wife’s
relationship and contacts with her mother and father and his stepson’s contacts with
friends in the PRC raise a heightened risk of security concerns because of the activities
of the government of the PRC to its goal of obtaining military, technological, and
classified information from the United States. The evidence shows that the PRC
government engages in espionage activities in the United States and that it targets U.S.
citizens, particularly those of Chinese ancestry in the United States by exploiting,
manipulating, pressuring, or coercing them to obtain protected information. 
Under the guidelines, the potentially conflicting loyalties may be weighed to
determine if an applicant can be expected to resolve any conflict in favor of the United
States interests. In determining if Applicant’s contacts in the PRC cause security
concerns, I considered that the PRC supports the United States in the fight against
terrorism, that the United States has granted the PRC most favored nation status, and
that the United States and the PRC have joint trade agreements. I also considered the
active intelligence gathering activities of the PRC in the United States, as the PRC
continues its significant efforts to obtain military and industrial secrets through
Americans of Chinese ancestry.  The government of the PRC specifically targets13
Chinese-Americans citizens for assistance in collecting classified information from the
United States. While none of these considerations by themselves dispose of the issue,
they are all factors to be considered in determining Applicant’s vulnerability to pressure
or coercion because of his wife’s family members in the PRC. The activities of the
government of the PRC, his stepson’s contacts with friends in the PRC, and his wife’s
contacts with her family, as well as his, in the PRC raise a heightened risk under AG ¶¶
7(a), 7(b), and 7(d).
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In deciding if Applicant has established mitigation under AG ¶ 8 (a), I must
consider: 
the nature of the relationships with foreign persons, the country in which
these persons are located, or the positions or activities of those persons in
that country are such that it is unlikely the individual will be placed in a
position of having to choose between the interests of a foreign individual,
group, organization, or government and the interests of the United States
Under AG ¶ 8(b), I must consider whether Applicant has established:
 
there is no conflict of interest, either because the individual's sense of
loyalty or obligation to the foreign person, group, government, or country is
so minimal, or the individual has such deep and longstanding relationships
and loyalties in the United States, that the individual can be expected to
resolve any conflict of interest in favor of the United States interests.
Finally, under AG ¶ 8(c), I must consider whether Applicant has established:
(c) contact or communication with foreign citizens is so casual and
infrequent that there is little likelihood that it could create a risk for foreign
influence or exploitation .
Applicant’s relationship with his wife’s family members is not an automatic basis
to deny him a security clearance; however, his burden of proof on mitigation requires
more than statements about the limited scope of his conversations with his mother-in-
law and his father-in-law. See ISCR Case No. 07-02485 (App. Bd. May 9, 2008). His
wife worked for a city government in the PRC for 20 years as a structural engineer, and
her parents worked for the university. Her family members have never held a political
position, nor have they been targeted by the government of the PRC. Her family
members have never been imprisoned nor is there any evidence that her family
members in the PRC have suffered any abuses from the PRC government. However,
the Appeal Board has held that her family’s obscurity does not provide a meaningful
measure when the family are subject to the authority of a regime that has a dismal
human rights record. See ADP Case No. 08-10099 (App. Bd. Jan. 28, 2011).
Applicant’s wife and stepson continue to hold passports from the PRC, as they are not
U.S. citizens. They have no plans for travel to the PRC, and her family living in the PRC
has not traveled to the United States. Applicant’s wife speaks with her mother on a
weekly basis and her son continues to interact regularly with his friends in the PRC
through the internet. Applicant has limited contact with his wife’s parents and none with
her brother. His wife does not have a strong emotional tie to her brother. His telephone
conversations with his mother-in-law are limited to “hi” because of a language barrier,
and his telephone calls with his father-in-law are general and casual. His closest family
members are his wife and her son, who are residents of the United States. She and her
son do not own property in the PRC and do not keep any financial assets in the PRC. 
Lack of current access to classified information in the work environment is not a factor in granting a security14
clearance.
10
Before he married his wife, Applicant complied with the rules of the U.S.
government and traveled to the PRC to meet her and her family. He has not returned to
the PRC. Applicant specifically and credibly stated at the hearing that if the PRC
government threatened her parents, he would not do anything as he would not help the
Chinese government. His supervisor clearly stated that he did not have access to
classified information.  Because he is a mechanic, Applicant does not believe that the14
government of the PRC would have any interest in him. 
Balancing these factors as well as the PRC’s support of the anti-terrorism
position and activities of the United States, I find that Applicant’s contact with his
mother-in-law and brother-in-law are casual and infrequent. Because he talks with his
father-in-law, he has developed a bond with him. Most importantly, the PRC actively
seeks military and economic information from the United States, which must be weighed
against his statement that he would not do anything to help his wife’s family in the PRC,
if pressured, because he would not help the Chinese government. Applicant has no
connections to the culture of the PRC, only to the culture of the United States. While  he
does not work with classified information, and he is not given access to classified
information, this is not a factor in determining his eligibility for a security clearance.
Applicant lives with his wife, who maintains regular contact with her parents in the PRC,
and his stepson, who regular communicates with his friends in the PRC. In weighing
these facts and all the facts of record, I find that Applicant has not provided sufficient
evidence to mitigate the security concerns raised. See ISCR Case No. 07-02485 (App.
Bd. May 9, 2008). Given that terrorism is rare in the PRC, there is little likelihood of
threats by terrorists organizations against Applicant’s wife’s family in the PRC. His
loyalties are to the United States, not to the PRC, and are not questioned. His loyalty to
the United States is insufficient to show mitigation of the security concerns raised by his
marriage. Applicant has not mitigated the Government’s security concerns as to his
contacts with his in-laws under AG ¶ 8.
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 an 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
11
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. The decision to grant or
deny a security clearance requires a careful weighing of all relevant factors, both
favorable and unfavorable. In so doing, an administrative judge must review all the
evidence of record, not a single item in isolation, to determine if a security concern is
established and then whether it is mitigated. A determination of an applicant’s eligibility
for a security clearance should not be made as punishment for specific past conduct,
but on a reasonable and careful evaluation of all the evidence of record to decide if a
nexus exists between established facts and a legitimate security concern. 
In reaching a conclusion, I considered the potentially disqualifying and mitigating
conditions in light of all the facts and circumstances surrounding this case. Applicant
married a woman from the PRC knowing that his marriage had the potential to affect his
eligibility for a security clearance. He complied with the requirements of the U.S.
government and traveled to China to met his wife and her family before he married her.
Because of the language barrier, he has not developed any emotional bonds with his
mother-in-law and his contacts are extremely limited. He has developed some bonds
with his father-in-law, and since his stepson returned to the United States a year ago,
he has developed stronger bonds with him. His wife decided not to continue her career
as an engineer. Instead, she is training to work in the accounting field. They socialize
with other couples who are both Chinese and American. Applicant’s wife shows no
interest in his work or his job, as she has not asked, nor does she ask, him about his
work. He is loyal to the United States, where he was born and raised.
The PRC, however, actively targets Americans who were born and raised in the
PRC and Americans of Chinese ancestry to participate in its economic and industrial
espionage program to gain access to classified information and industrial secrets. The
PRC has operated its espionage program for many years and continues to do so in an
effort to gain information from the United States which is beneficial to the PRC’s military
growth and to its goals of becoming a world power. Because of the activities of the
government of the PRC, Applicant has not provided sufficient evidence to mitigate the
security concerns raised by his marriage.
Overall, the record evidence leaves me with questions or doubts as to Applicant’s
eligibility and suitability for a security clearance. For all these reasons, I conclude
Applicant mitigated the security concerns arising under Guideline B.
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:
12
Paragraph 1, Guideline B: AGAINST APPLICANT
Subparagraph 1.a: Against Applicant
Subparagraph 1.b: 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 eligibility for a security
clearance. Eligibility for access to classified information is denied.
                                                              
MARY E. HENRY
Administrative Judge