DEPARTMENT OF DEFENSE 
         DEFENSE OFFICE OF HEARINGS AND APPEALS 
           
             
 
 
In the matter of: ) 
 ) 
  )  ISCR Case No. 09-07597 
  ) 
 ) 
Applicant for Security Clearance ) 
 
 
Appearances 
 
For Government: William T. O'Neal, Esquire, Department Counsel 
For Applicant: Ronald C. Sykstus, Esquire 
 
 
 
______________ 
 
Decision 
______________ 
 
 
CREAN, Thomas M., Administrative Judge: 
 
Based on a review of the pleadings, exhibits, and testimony, eligibility for access 
to classified information is denied. 
 
Statement of the Case 
 
On April 17, 2009, Applicant submitted an Electronic Questionnaire for 
Investigations Processing (e-QIP) to renew a security clearance for his position with a 
new defense contractor. While previously working for defense contractors, Applicant 
had access to classified information. In March 2009, Applicant's former employer 
submitted an adverse information report concerning Applicant's conduct that may have 
an adverse impact on his access to classified information to the appropriate security 
officials. After reviewing the results of an ensuing background investigation completed 
on June 15, 2009, adjudicators for the Defense Office of Hearings and Appeals (DOHA) 
issued to Applicant an interrogatory to clarify or augment potentially disqualifying 
information. After reviewing the results of the background investigations and Applicant's 
response to the interrogatories, DOHA could not make the preliminary affirmative 
 
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findings required to issue a security clearance. On September 21, 2010, DOHA issued a 
Statement of Reasons (SOR) to Applicant detailing security concerns for personal 
conduct under Guideline E. These actions were 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) effective in the Department of Defense on September 1, 
2006.  
 
 Applicant answered the SOR on October 9, 2010. He admitted the three 
allegations under Guideline E, and requested a hearing before an administrative judge. 
Department Counsel was prepared to proceed on February 2, 2011. The case was 
assigned to me on February 24, 2011. DOHA issued a Notice of Hearing on March 18, 
2011, for a hearing on April 7, 2011. I convened the hearing as scheduled. The 
Government offered three exhibits, marked and admitted into the record without 
objections as Government exhibits (Gov. Ex.) 1 through 3. Applicant and nine witnesses 
testified on his behalf. Applicant offered eight exhibits marked and admitted into the 
record without objection as Applicant exhibit (App. Ex.) A through H. DOHA received the 
transcript of the hearing (Tr.) on April 22, 2011. 
 
Findings of Fact 
 
 After a thorough review of the pleadings, transcript, and exhibits, I make the 
following essential findings of fact. Applicant admitted the three allegations under 
personal conduct. His admissions are included in my findings of fact.  
 
Applicant is a 34-year-old systems engineer working as an embedded test 
integrator for a defense contractor. He is a college graduate with a bachelor's degree in 
management information systems. He is married with two children. After graduating 
from college, Applicant worked as a systems engineer for a government contractor from 
August 1999 to October 2003. He then worked for defense contractor A as a systems 
engineer until April 2007. He worked for another defense contractor from April 2007 until 
March 2008, and then returned to defense contractor A as a senior systems engineer. 
He continued working for defense contractor A until starting work for his current 
employer, defense contractor B, in March 2009. He left defense contractor A because 
he no longer liked the tasks he was assigned and defense contractor B assigned him to 
tasks more to his liking. Applicant has held a security clearance since April 2001. (Tr. 
20-230; Gov. Ex. 1, e-QIP, dated April 17, 2009)  
 
Applicant was on temporary duty for defense contractor A in June 2007 at an Air 
Force base. His sister, an Air Force officer, was assigned to that base. He stayed with 
her for the five days he was on temporary duty at that location. He submitted a travel 
voucher requesting reimbursement for lodging at a rate lower than the authorized 
government lodging reimbursable rate. Attached to the travel voucher was a receipt for 
lodging expenses stating that he stayed at his sister's residence and gave the address 
of her house. The voucher further noted that he paid a $450 lodging expense in cash. 
 
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His sister did not run a lodging business at her residence and she did not provide him 
with the receipt. Applicant believes he created the receipt himself. His company 
reimbursed him for this travel including the claimed lodging expenses at his sister's 
residence. He did not reimburse his sister for any expenses she incurred. Applicant 
believed he was following the correct procedures for claiming lodging reimbursement for 
staying with a relative. When Applicant left the company in 2007 shortly after submitting 
reimbursement for travel expenses, his travel claims were not investigated by company 
A. (Tr. 30-32, 61-65, 72-23; Gov. Ex. 2, Corrective Action Report, dated February 26, 
2009, at 106-115) 
 
After returning to work for defense contractor A, Applicant traveled to the same 
Air Force base on temporary duty in June 2008 for a few weeks and stayed with his 
sister. Upon his return, he submitted a travel voucher similar to the one he previously 
submitted in 2007. He listed an expense for lodging at his sister's residence at a rate 
lower than the authorized Government reimbursement rate. A copy of the actual 
submitted travel voucher is not in the file. The travel clerk at defense contractor A 
challenged Applicant's lodging reimbursement request for his stay at a relative's 
residence. The clerk provided Applicant the Government Joint Travel Regulation 
provision concerning reimbursement for lodging expenses when staying with a relative. 
The Government regulation was used by the company as a guide to determine 
reimbursement for travel. Since Applicant did not incur a lodging expense, and did not 
provide the company with his sister's actual expenses for hosting him, the company 
denied the request for lodging reimbursement. Applicant was directed to submit an 
amended voucher not claiming a lodging expense. Applicant was paid for the expenses 
he actually incurred on the amended voucher.  
 
Applicant and the travel clerk corresponded by e-mail concerning his lodging 
claim. Applicant noted that the travel expenses should be calculated for a city near the 
Air Force base since he was unable to stay at the base and the city was the closest 
place with a per diem rate. He researched the Government travel regulations himself 
and questioned the travel clerk concerning reimbursement for lodging with relatives. 
Applicant believes that the rules for reimbursement for lodging expense with relatives 
are not clear. He also believes he should not have submitted the travel vouchers as he 
did. Applicant knew from this exchange of information with the travel clerk that he could 
only be reimbursed for the actual expenses incurred by the relative. He did not try to 
determine the actual expense incurred by his sister during his stay. (Tr. 32-35, 53-56, 
55-62, 65-66, 73-77; Gov. Ex. 2, Corrective Action Report, dated February 26, 2009, at 
100-103; App. Ex. B, Additional e-mails, dated June 25, 2008; App. Ex. G, Travel 
Regulations Frequently Asked Questions, dated March 28, 2011) 
 
Applicant traveled to the same location for the third time in January 2009, and 
stayed with his sister. This time he submitted with his travel voucher a receipt for 
lodging expenses at a fictitious bed and breakfast. Again he listed a room rate that was 
lower than the authorized government room rate. Applicant admitted that he created this 
document using his computer. He gave the bed and breakfast a fictitious name, 
address, and lodging rate. He stated he did not know if he was entitled to 
 
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reimbursement since he did not receive a clear answer from his company on his June 
2008 request for information. He wanted his sister to be reimbursed for her expenses in 
hosting him. Defense contractor A's travel clerk could not find a listing for the claimed 
bed and breakfast. She denied the lodging expenses and informed Applicant's 
supervisor. An audit revealed that Applicant had submitted the March 2007 travel 
voucher requesting reimbursement for lodging expenses at his sister's residence. (Tr. 
35-37, 66-68; Gov. Ex. 2, Corrective Action Report, dated February 26, 2009, at 95-99) 
His sister noted that Applicant did offer to pay her the lodging at the government rate 
but she declined. (App. Ex. H, e-mail, dated March 31, 2011) 
 
Applicant started interviewing with defense contractor B for a position with that 
company on January 26, 2009. He was informally offered a position on February 9, 
2009. He notified his supervisors at defense contractor A that he was negotiating a new 
position with another defense contractor. He was formally offered the position with 
defense contractor B on February 18, 2009, and accepted it on February 23, 2009. He 
submitted his resignation to defense contractor A on the same day. On February 25, 
2009, when his supervisors at defense contractor A learned of his resignation, they 
attempted to get him to stay with the company. (Tr. 37-48; App. Ex. C; e-mails, dated 
February 25, 2009; App. Ex. D, Hiring documents and e-mails, dated April 6, 2011)  
 
Defense contractor A started investigating Applicant's fraudulent travel claim as 
early as February 6, 2009. On February 26, 2009, Applicant was counseled by his 
supervisor and received an administrative warning for violating the company's travel and 
ethics policies. Applicant was advised that additional non-compliance with the policies 
would result in immediate termination of employment. When Applicant left defense 
contractor A in March 2009, his final pay was docked $450 for the 2007 incorrect 
lodging payment. This was the first time Applicant heard that defense contractor A 
classified the travel documents he submitted as fraudulent rather than ineligible. 
Defense contractor A submitted a report concerning the false travel documents to the 
appropriate security officials. On March 17, 2009, Applicant was notified of the report by 
defense contractor B's security manager. (Tr. 48-52, 66-71 ; App. Ex. E, Memorandum, 
dated March 6, 2009; App. Ex. F, e-mails, dated March 17, 2009) 
 
Applicant testified he received defense contractor A's personnel handbook when 
he started working for them. He signed the company's ethics policy as required by the 
contractor. He did not review the company's contract with the Government and does not 
know under the contract what travel expenses are reimbursable by the Government. He 
agrees that intentionally submitting a fake lodging receipt is fraud. However, he does 
not believe he submitted the travel document with the intent to deceive. The payment of 
the lodging expenses at his sister's house is unclear under the travel rules. He 
understood that defense contractor A would reimburse him for any cost he incurred 
while on travel for them. He understood he had to submit vouchers verifying his 
expenses except for meals and incidentals which were reimbursed at a set rate per day. 
For lodging expenses, he had to submit a voucher. The Government's Joint Travel 
Regulation would be used as a guide by defense contractor A to determine 
reimbursement. He submitted a voucher for the 2007 travel noting he stayed at his 
 
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sister's resident and that the cost was $75 per day. He did not actually incur that cost 
since his sister did not charge him for the expenses. His company initially paid his 2007 
lodging expense. For the 2008 travel, he submitted a lodging expense voucher which 
was not incurred since he again stayed at his sister's house. After being advised that he 
could not claim reimbursement for staying at his sister's house, he created a false 
receipt for lodging expense paid on his January 2009 travels. He did not have lodging 
expenses on this trip. (Tr. 77-84) 
 
Applicant's supervisor stated that he interviewed and hired Applicant in February 
2009 for his position as an imbedded test engineer for defense contractor B. He sees 
Applicant on a daily basis and rates Applicant as very professional. Since working for 
his company, Applicant has excelled and received bonuses and raises. He has no 
questions concerning Applicant's reliability, trustworthiness or honesty. However, he 
would have questions concerning someone who submitted a fictitious travel voucher. 
The supervisor also noted that there were some disagreements and friction between 
defense contractor A and other subcontractors concerning hiring of personnel away 
from that company. He is also aware that there was dissatisfaction by defense 
contractor A's employees and their company. (T. 87-103) 
 
The Government technical lead on Applicant's contract testified she has known 
Applicant for approximately two years. Applicant does an excellent job and is a self 
starter. He researches and documents on his own new components that could be added 
to the program. She acknowledged that there is disagreement between defense 
contractors A and B. (Tr. 103-109) 
 
A program lead testified that he has known Applicant since 2003 and worked on 
and off with him for approximately eight years. He knows Applicant is an excellent 
worker and he never questioned Applicant's handling of classified information. He has 
never heard derogatory comments concerning Applicant's reputation for honesty and 
trustworthiness. He does not have questions concerning Applicant being granted 
access to classified information. (Tr. 111-116) 
 
A lead integrator for a defense contractor testified that he has known Applicant 
since 2006 and would see him daily when they worked together on embedded test 
programs. He knows of the allegations against Applicant and thinks Applicant is getting 
a bad deal. (Tr. 116-120) 
 
A program manager for defense contractor A testified that he worked with 
Applicant at the company. During part of this time, Applicant worked directly for him for 
approximately a year. Applicant was an outstanding worker and he would like to have 
Applicant work for him again. He does not believe his company acted correctly in 
reporting Applicant for filing false travel documents since Applicant did not benefit from 
any travel fraud. As Applicant's manager, the witness signed the corrective action letter 
Applicant received on February 26, 2009. He was not aware of the action before signing 
but only signed to indicate that the action did take place. (Tr. 120-126) 
 
 
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Another lead integrator for defense contractor A testified that he was Applicant's 
co-worker for over two years at defense contractor A. When Applicant returned to the 
company, he became Applicant's manager. He does not agree that Applicant submitted 
fraudulent travel documents. He believes that the documents were submitted because 
of a misinterpretation of the travel rules. If he were in authority at defense contractor A, 
he would not have submitted the action report concerning Applicant to security officials. 
He believes defense contractor A treats employees well, but there are disagreements 
between defense contractors A and B. (Tr. 127-132) 
 
An assistant systems engineer for defense contractor B testified he has worked 
with Applicant for the last two years. He sees Applicant daily since the programs they 
work on are interconnected. Applicant is honest and cognizant of security requirements. 
He does not believe submitting the report concerning Applicant's submission of 
fraudulent travel documents was correct. However, he also believes the report does not 
place Applicant in a bad position. He has no concerns about Applicant's handling of 
classified information. (Tr. 132-136) 
 
A family friend testified that she has known Applicant and his family for 
approximately a year. She believes Applicant is such a good person that she trusts him 
to care for her sons. (Tr. 136-140) 
 
Applicant's wife also testified. She has been married to Applicant for over eight 
years. They have two children ages seven and four. She does not believe her husband 
is a liar. Her family is military and she has experience with travel vouchers. She believes 
the voucher submitted by Applicant made absolute sense. (Tr. 140-144) 
 
Applicant presented a package of information showing that he received 
exceptional performance awards and bonuses both at his present company and by 
other employers. He presented certificates of appreciation and recognition of his 
professional accomplishments. He also presented his performance appraisals at his 
present company showing his outstanding performance and value to his team. (App. Ex. 
B, Exhibits A through T, Certificates and Awards)  
 
Policies 
 
When evaluating an applicant’s suitability for a security clearance, the 
administrative judge must consider the adjudicative guidelines (AG). In addition to brief 
introductory explanations for each guideline, the adjudicative guidelines list potentially 
disqualifying conditions and mitigating conditions, which must be considered 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 
 
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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. Likewise, I have avoided drawing inferences 
grounded on mere speculation or conjecture. 
 
Under Directive ¶ E3.1.14, the Government must present evidence to establish 
controverted facts alleged in the SOR. Under Directive ¶ E3.1.15, the Applicant is 
responsible for presenting “witnesses and other evidence to rebut, explain, extenuate, 
or mitigate facts admitted by applicant or proven by Department Counsel. . . .” The 
Applicant has the ultimate burden of persuasion 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 the Applicant may deliberately or inadvertently fail to protect or protect 
classified information. Such decisions entail a certain degree of legally permissible 
extrapolation about potential, rather than actual, risk of compromise of classified 
information. 
 
Analysis 
 
Guideline E, Personal Conduct 
 
 A security concern is raised because conduct involving questionable judgment, 
untrustworthiness, unreliability, or unwillingness to comply with rules and regulations 
can raise questions about an individual’s reliability, trustworthiness, and ability to protect 
classified information. (AG ¶ 15) Personal conduct is always a security concern because 
it asks the central question does the person’s past conduct justify confidence the person 
can be entrusted to properly safeguard classified information.  
 
 Applicant submitted a false travel voucher for reimbursement of lodging 
expenses after being told that he was not eligible for reimbursement for such expenses 
at his sister's house. He also tried to claim money for expenses he did not pay. These 
facts raise Personal Conduct Disqualifying Condition (PC DC) AG ¶ 16(b) (deliberately 
providing false and misleading information concerning relevant facts to an employer, 
investigator, security official, competent medical authority, or other official government 
representative); and PC DC AG ¶ 16(d) (credible adverse information that is not 
 
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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 indicting that the person may not properly safeguard protected 
information. This includes but is not limited to consideration of: . . . (3) a pattern of 
dishonesty or rule violations).  
 
 The 2007 lodging voucher claimed reimbursement for expenses at his sister's 
house. Even though Applicant did not incur a lodging expense at his sister's house, he 
listed his sister's residence for lodging reimbursement at a fictitious cost below the 
Government's reimbursement rate. Applicant reasonably believed he submitted the 
voucher correctly, even though he did not pay his sister anything for his lodging. The 
voucher was paid. Since Applicant did not know the rules concerning reimbursement for 
lodging with a relative, he did not submit the documents with intent to deceive. 
 
 Likewise, Applicant did not know the rules for reimbursement when he submitted 
the 2008 lodging reimbursement request. He had been paid for the 2007 lodging 
expenses and followed the same procedures in 2008. Applicant again used a lodging 
expense below the Government reimbursement rate. The travel voucher submitted in 
June 2008 was not available, but it can be assumed that the same address for his sister 
was used and the only different information was the lodging expense. He again knew 
that he did not pay his sister for his lodging. At the time he submitted the voucher, he 
was not aware he was not entitled to reimbursement for lodging expenses at his sister's 
house. He learned he was not entitled to reimbursement when his request was denied 
in June 2008. When Applicant submitted the lodging document in June 2008, he did not 
intend to deliberately deceive his company on payment of the expenses.  
 
 However, when Applicant submitted the travel voucher in January 2009, he knew 
he was not entitled to reimbursement for lodging expenses at his sister's house because 
his previous request had been denied and he was advised of the company policy on 
reimbursement for lodging with a relative. Since he was aware that he was not entitled 
to reimbursement, he personally created and submitted a fraudulent receipt for a 
fictitious bed and breakfast. His actions were a deliberate attempt to deceive. He 
received a warning from his employer concerning his submission of fraudulent travel 
documents. Since Applicant did not submit the fraudulent lodging receipts for the March 
2007 and June 2008 travel with intend to deceive, I find for Applicant as to the part of 
SOR allegation 1.a pertaining to those two lodging receipts. The Government has 
established SOR 1.a concerning the submission of fraudulent lodging receipts 
pertaining to the January 2009 travel expenses. The Government also established the 
allegation at SOR 1.b. The Government did not establish the allegation at SOR 1.c. 
While an audit found that the lodging expense receipt submitted was not proper, 
Applicant did not submitted the receipt with intent to defraud.  
 
 In regard to the part of the allegation in SOR 1.a pertaining to the January 2009 
lodging expense, and SOR allegation 1.b, I have considered Personal Conduct 
 
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Mitigating Condition (PC MC) AG ¶17(d) (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); and PC MC AG 
¶ 17(c) (the offense is so minor, or so much time has passed, or the behavior is so 
infrequent, or it happened under such unique circumstances that is unlikely to recur and 
does not cast doubt on the individual's reliability, trustworthiness, or good judgment). 
These mitigating conditions do not apply. Applicant deliberately submitted a false travel 
document. Applicant was specifically told by his company's travel clerk that he was not 
entitled to reimbursement for lodging expenses at his sister's house. To counter this, he 
created a false document showing that he stayed at a lodging establishment. He never 
made an effort to correct his actions until confronted by this company. Even at the 
hearing, he did not totally acknowledge his wrongful act but attempted to shift the blame 
to his company. The deliberate act of submitting a false document is not a minor 
offense. It also happened recently, a little over two years ago. Applicant deliberately 
submitted a false document in direct violation of company policy. The circumstances 
were not unique in that Applicant acted deliberately with the knowledge his document 
was false. These factors reflect adversely on his judgment, reliability, candor, 
trustworthiness, and ability to follow rules and regulations, and indicate he may not 
properly protect classified information. The administrative warning issued by his 
supervisor was appropriate. The personal conduct security concerns under SOR 1.a 
pertaining to the January 2009 lodging expense and SOR 1.b are not mitigated. 
 
 I have also considered Applicant's contention that his former employer, defense 
contractor A, acted improperly by reporting his submission of the false document to 
security officials because of a disagreement between them and his present employer. 
Applicant had been told in 2008 that he could not be reimbursed for lodging at his 
sister's house unless he could establish her actual expenses for his lodging. Knowing 
that he could not be reimbursed, he created and submitted a false document for a 
fictitious lodging establishment to claim reimbursement. Defense contractor A 
immediately investigated Applicant's travel voucher after it was submitted and found it 
was fraudulent. The company has an obligation and duty to report his conduct to the 
appropriate security agency and not ignore his conduct since it could have a bearing on 
his security worthiness. (See NISPOM 1.302(a), Adverse Information Reports) To claim 
that the company acted improperly and maliciously by reporting his conduct is totally 
without merit.  
 
Whole-Person Analysis  
 
 Under the whole-person concept, the administrative judge must evaluate an 
applicant’s security eligibility by considering the totality of the applicant’s conduct and all 
the circumstances. An 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 
 
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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 a security clearance 
must be an overall commonsense judgment based upon careful consideration of the 
guidelines and the whole-person concept.  
 
I considered the potentially disqualifying and mitigating conditions in light of all 
the facts and circumstances surrounding this case. I considered that Applicant 
deliberately provided a false document to his employer to gain reimbursement for 
lodging expenses he did not incur after being advised that he could not be reimbursed 
for those expenses. I considered the testimony of his supervisors, friends, and fellow 
employees concerning his reputation for honesty, candor, reliability, judgment, and 
trustworthiness. I considered his reputation as an excellent employee and his record of 
accomplishments, and that he successfully held a security clearance for a number of 
years. However, offset against this good character information are his actions in 
knowingly and deliberately providing false documents with intent to gain monetary 
reimbursement for expenses he did not incur. This type of action indicates that he may 
not properly safeguard classified information. The record evidence leaves me with 
questions and doubts about Applicant’s eligibility and suitability for a security clearance. 
For all these reasons, I conclude Applicant has not mitigated the personal conduct 
security concerns under SOR 1.a and 1.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: 
 
 Paragraph 1, Guideline E:   AGAINST APPLICANT 
 
  Subparagraph 1a:   For Applicant as to the March 2007 and  
       June 2008 lodging expenses receipts. 
       Against Applicant as to the January 
       2009 lodging expenses receipt. 
 
  Subparagraph 1.b;   Against Applicant 
 
  Subparagraph 1.c:   For Applicant 
 
 
 
 
 
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Conclusion 
 
 In light of all of the circumstances presented by the record in this case, it is not 
clearly consistent with national interest to grant Applicant eligibility for a security 
clearance. Eligibility for access to classified information is denied. 
 
 
 
_________________ 
THOMAS M. CREAN 
Administrative Judge