1 
 
 
                                                              
DEPARTMENT OF DEFENSE 
DEFENSE OFFICE OF HEARINGS AND APPEALS 
           
             
 
 
In the matter of: ) 
 ) 
 [Redacted] )  ISCR Case No. 10-05535 
 ) 
Applicant for Security Clearance ) 
 
 
Appearances 
 
For Government: Tovah Minster, Esq., Department Counsel 
For Applicant: Pro se 
 
 
______________ 
 
Decision 
______________ 
 
 
FOREMAN, LeRoy F., Administrative Judge: 
 
This case involves security concerns raised under Guideline F (Financial 
Considerations). Eligibility for access to classified information is denied. 
 
Statement of the Case 
 
Applicant submitted a security clearance application on February 17, 2010. On 
April 4, 2012, the Defense Office of Hearings and Appeals (DOHA) notified him that it 
was unable to find that it was clearly consistent with the national interest to grant him 
access to classified information, and it recommended that his case be submitted to an 
administrative judge for a determination whether to grant or deny his application. DOHA 
set forth the basis for its action in a Statement of Reasons (SOR), citing security 
concerns under Guideline F. 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) implemented by the Department of Defense on September 1, 2006.  
 
 
2 
 
 
 Applicant received the SOR on April 13, 2012; answered it on May 2, 2012; and 
requested a hearing before an administrative judge. DOHA received the request on May 
3, 2012. Department Counsel was ready to proceed on May 21, 2012, and the case was 
assigned to me on May 29, 2012. DOHA issued a notice of hearing on June 1, 2012, 
scheduling it for June 21, 2012. I convened the hearing as scheduled. Government 
Exhibits (GX) 1 through 6 were admitted in evidence without objection. Applicant 
testified, presented the testimony of one witness, and submitted Applicant’s Exhibits 
(AX) A through C, which were admitted without objection. I kept the record open until 
July 9, 2012, to enable Applicant to submit additional documentary evidence. He timely 
submitted AX D and E. Department Counsel’s comments concerning AX D and E are 
attached to the record as Hearing Exhibit I. DOHA received the transcript (Tr.) on June 
29, 2012. 
 
Findings of Fact 
 
 In his answer to the SOR, Applicant admitted the allegations in SOR ¶¶ 1.a-1.c, 
1.e, 1.f, 1.h-1.k, 1.n-1.u, 1.w, 1.y-1.dd, 1.hh, 1.kk-1.rr, 1.ww-1.yy, 1.bbb, 1.ddd, and 
1.eee. He did not respond to SOR ¶¶ 1.tt-1.vv. He denied SOR ¶¶ 1.d, 1.g, 1.l, 1.m, 1.v, 
1.x, 1.ee-1.gg, 1.ii-1.jj, 1.ss, 1.zz, 1.aaa, and 1.ccc. His admissions in his answer and at 
the hearing are incorporated in my findings of fact.  
 
 Applicant is a 36-year-old mission controller employed by a federal contractor 
since May 2009. He served in the U.S. Air Force from November 1995 to September 
2000, and he held a security clearance and eligibility for access to sensitive 
compartmented information during his military service. During his first enlistment, he 
received outstanding performance reports and received a Good Conduct Medal and Air 
Force Achievement Medal. (GX 3 at 8-12.) He reenlisted and received a $15,000 
reenlistment bonus. He was reassigned and began having conflicts with his new chain 
of command, which began when his dress uniform was lost during the move and he 
wore the wrong uniform at the ceremony during which he was given the Air Force 
Achievement Medal for his previous service. After several other conflicts with authority, 
he was discharged before completing his enlistment, and he received a general 
discharge under honorable conditions. (GX 3 at 22-26; Tr. 37-39.) Because he did not 
complete his enlistment, he was required to pay back about $6,000 of his reenlistment 
bonus. He did not have sufficient funds to repay the bonus, and it eventually was 
collected by seizing his federal income tax refunds. (GX 3 at 6-7.) 
 
 Applicant was unemployed from September to December 2000. He worked in a 
fast-food restaurant from January 2001 to January 2006, when he was laid off. He 
worked as a part-time security officer for a night club from February to November 2006 
and a part-time rural mail carrier for the U.S. Postal Service from June to November 
2006. He was a full-time mail carrier from November 2006 to July 2008. He was injured 
in September 2007 and placed on administrative leave at reduced pay while the 
circumstances of his injury were investigated. (GX 3 at 21-22.) He worked as a network 
controller for a federal contractor from March 2008 until May 2009, when he began his 
current job as a mission controller.  
 
3 
 
 
 Applicant married in March 1999. His wife had two children when they met. (Tr. 
82.) Those children are now ages 16 and 14. They had two more children together, now 
ages 12 and 8. Applicant’s niece, age 18, also resides with them. (Tr. 34.) Applicant and 
his wife had custody of his two younger brothers until one joined the Air Force and the 
other went to college. (Tr. 84.)  
 
Around June 2001, he and his wife began to have serious marital problems due 
to her alcohol and drug abuse. There were several domestic disturbances and mutual 
accusations of marital infidelity. Applicant was jailed once for violating a restraining 
order. They separated in April 2004. In late 2004, Applicant’s wife entered a drug 
treatment program and received psychiatric care for a bipolar condition. Applicant and 
his wife began seeing each other again in early 2004 and have been living together 
since September 2005. (GX 2 at 15-20.) Applicant’s wife does not work outside the 
home.  
 
 The SOR alleges 57 delinquent debts totaling more than $35,000. Some date 
back to 2003, but most became delinquent between 2006 and early 2010. In response 
to DOHA interrogatories in December 2011, he submitted evidence that the debt 
alleged in SOR ¶ 1.ll was resolved in February 2010. (GX 3 at 13.) In his response to 
the SOR, Applicant submitted evidence that the debts alleged in SOR ¶¶ 1.aa and 1.kk 
were resolved before the SOR was issued and the debt alleged in SOR ¶ 1.e was 
resolved after issuance of the SOR.  
 
 In mid-April 2012, after receiving the SOR, Applicant enrolled in a debt 
management program. A debt counselor reviewed his current income, expenses, 
assets, and liabilities, and prepared a customized budget and an action plan for 
resolving delinquent debts. (AX C.) Applicant decided not to proceed with this debt 
management plan because it required monthly payments of over $600 and did not 
provide for missed payments. (Tr. 47-48.) Instead, he formulated his own budget and 
payment plan. They had not been reduced to writing as of the date of the hearing. (Tr. 
48-49.  
 
After the hearing, Applicant reduced his budget to writing and submitted it. It 
reflects a monthly remainder of $491 that is available to resolve his delinquent debts. 
(AX D at 2-3.) He had previously submitted a personal financial statement in response 
to DOHA interrogatories, reflecting a net monthly remainder of about $112. (GX 3 at 
62.) His new budget reflects a pay raise, an increase in his military disability pay, and 
reduced expenses due to the payoff of his car loan. (Tr. 68-70.)  
 
After the hearing, Applicant also reduced to writing and submitted a plan 
providing for monthly payoffs of selected debts beginning in July 2012 and ending in 
April 2016. (AX D at 3-13; AX E.) The payment plan includes all debts alleged in the 
SOR, except those that have been resolved or disputed. Applicant did not present any 
evidence that his creditors have agreed to the payment plan.  
 
 
4 
 
 
In late April 2012, Applicant retained an attorney to determine the validity of the 
unsatisfied judgments alleged in SOR ¶¶ 1.b and 1.kk, even though he apparently had 
satisfied the judgment alleged in SOR ¶ 1.kk in February 2008. (Answer to SOR; AX A.) 
On June 23, 2012, two days after the hearing, Applicant sent letters to all three credit 
bureaus, disputing the debts alleged in SOR ¶ 1.g, 1.l, 1.m, 1.v, 1.tt, 1.zz, and 1.ccc on 
the ground that he has never had accounts with those creditors. He disputed the debt 
alleged in SOR ¶ 1.ss because it is a duplicate of the debt alleged in SOR ¶ 1.t. (GX 4 
at 2; GX 6 at 7.) He disputed the medical debt alleged in SOR ¶ 1.x on the ground that 
this debt should have been covered by Workmen’s Compensation. He disputed the 
medical debts alleged in SOR ¶¶ 1.ee, 1.ff, 1.ii, 1.jj, 1.uu, and 1.vv. He testified that 
these medical debts were incurred at a location where he has not lived since childhood, 
and he believes that they are his father’s debts. He and his father have the same name, 
except for the “Junior” in Applicant’s name. (Tr. 56-57.) He disputed the debts alleged in 
SOR ¶¶ 1.kk, and 1.nn, on the ground that he contacted the creditors and was informed 
that they have no unpaid accounts in his name. (AX D at 9-13.) As of the date the 
record closed, the credit bureaus had not responded to his dispute letters. 
 
The table below summarizes the evidence concerning the debts alleged in the 
SOR. 
 
SOR Debt Amount Answer 
to SOR
Status Evidence 
1.a Credit card 
(judgment) 
$2,822 Admit Payment plan AX E 
1.b Car repossession 
(judgment) 
$12,305 Admit Payment plan AX E 
1.c Medical $1,700 Admit Payment plan AX E 
1.d Collection $351 Deny Disputed, no account with creditor AX D 
1.e Medical $30 Admit Paid, 4-24-12 Answer 
1.f Medical $100 Admit Payment plan AX E 
1.g Internet service $330 Deny Disputed, no account with creditor AX D 
1.h Medical $62 Admit Payment plan AX E 
1.i Medical $62 Admit Payment plan AX E 
1.j Medical $140 Admit Payment plan AX E 
1.k Utilities $836 Admit Payment plan AX E 
1.l Cell phone $1,127 Deny Disputed, no account with creditor AX D 
1.m Optical $97 Deny Disputed, no account with creditor AX D 
1.n Payday loan $1,220 Admit Payment plan AX E 
1.o Medical $370 Admit Payment plan AX E 
1.p Medical $100 Admit Payment plan AX E 
1.q Medical $100 Admit Payment plan AX E 
1.r Medical $100 Admit Payment plan AX E 
1.s Medical $100 Admit Payment plan AX E 
1.t Credit card $529 Admit Payment plan AX E 
1.u Car insurance $165 Admit Payment plan AX E 
1.v Cable service $869 Deny Disputed, no account with creditor AX E 
1.w Cable service $573 Admit Payment plan AX E 
1.x Medical $1,382 Deny Disputed, covered by Workmen’s 
Compensation 
AX E 
1.y Bad check $123 Admit Payment plan AX E 
 
5 
 
 
1.z Bad check $100 Admit Payment plan AX E 
1.aa Credit card $466 Admit Paid, 3-15-12 Answer 
1.bb Telephone $199 Admit Payment plan AX E 
1.cc Collection $360 Admit Payment plan AX E 
1.dd Loan $335 Admit Payment plan AX E 
1.ee Medical $76 Deny Disputed, requested verification AX D 
1.ff Medical $593 Deny Disputed, requested verification AX D 
1.gg Health club $336 Deny Unresolved, no dispute filed Answer 
1.hh Collection $406 Admit Payment plan AX E 
1.ii Medical $280 Deny Disputed, requested verification AX D 
1.jj Collection $123 Deny Disputed, requested verification AX D 
1.kk Judgment $583 Admit Paid 2-13-08; creditor’s records do 
not reflect an unpaid debt 
Answer;  
AX D 
1.ll Cell phone $541 Admit Resolved 2-26-10 GX 3 at 
13 
1.mm Medical $179 Admit Payment plan AX E 
1.nn Pizzeria $67 Deny Disputed, creditor’s records to not 
reflect an unpaid debt 
AX D 
1.oo Medical $44 Admit Payment plan AX E 
1.pp Collection $83 Admit Payment plan AX E 
1.qq Credit card $784 Admit Payment plan AX E 
1.rr Medical $520 Admit Payment plan AX E 
1.ss Credit card $529 Deny Disputed, duplicate of ¶ SOR ¶ 1.t AX D 
1.tt Music club $27 No 
response 
Disputed, no account with creditor AX D 
1.uu Medical $555 No 
response 
Disputed, requested verification AX D 
1.vv Medical $280 No 
response 
Disputed, requested verification AX D 
1.ww Video games $78 Admit Paid, 11-12-08 and 11-26-08 Answer 
1.xx Cell phone $250 Admit Payment plan AX E 
1.yy Collection $73 Admit Payment plan AX E 
1.zz Collection  $126 Deny Disputed, no account with creditor AX D 
1.aaa Collection  $908 Deny Unresolved Answer 
1.bbb Collection $480 Admit Payment plan AX E 
1.ccc Collection $80 Deny Disputed, no account with creditor AX D 
1.ddd Trailer rental $318 Admit Payment plan AX E 
1.ccc Trash service $66 Admit Payment plan AX E 
 
 Applicant’s most recent performance report rated his performance as 3.67 on a 
4-point scale. A score of 3.00 is for employees meeting job requirements and a 4.00 is 
for employees exceeding job requirements. (AX B.) His supervisor, who has known him 
for five years, describes him as a person with high integrity, responsibility, and attention 
to detail. He considers Applicant a dependable person with good judgment and a 
mature outlook. (Attachment to Answer). 
 
 Applicant’s wife described him as someone who “will never shut his door to a 
family member or someone in need.” She testified that he is “a man of his word” and “a 
good guy.” (Tr. 84-87.) 
 
 
6 
 
 
 Applicant was involved in a car accident in February 2012, in which the other 
party was determined to be at fault. He expects to receive a settlement in a month or 
two, which he intends to use to resolve his debts. At the hearing, he testified that he 
does not know how much he will receive. (Tr. 32, 66.) However, in his post-hearing 
submission, he estimated that he will receive more than $35,000 (AX D at 13.) 
 
 Applicant has no savings. At the time of the hearing, he had about $700 in his 
checking account. He opened a retirement account in November 2011, but he did not 
testify regarding the amount he had accumulated in this account. (Tr. 71-72.) 
 
Policies 
 
 “[N]o one has a ‘right’ to a security clearance.” Department of the Navy v. Egan, 
484 U.S. 518, 528 (1988). As Commander in Chief, the President has the authority to 
“control access to information bearing on national security and to determine whether an 
individual is sufficiently trustworthy to have access to such information.” Id. at 527. The 
President has authorized the Secretary of Defense or his designee to grant applicants 
eligibility for access to classified information “only upon a finding that it is clearly 
consistent with the national interest to do so.” Exec. Or. 10865, Safeguarding Classified 
Information within Industry § 2 (Feb. 20, 1960), as amended.   
 
Eligibility for a security clearance is predicated upon the applicant meeting the 
criteria contained in the AG. These guidelines are not inflexible rules of law. Instead, 
recognizing the complexities of human behavior, an administrative judge applies these 
guidelines in conjunction with an evaluation of the whole person. An administrative 
judge’s overarching adjudicative goal is a fair, impartial, and commonsense decision. An 
administrative judge must consider all available, reliable information about the person, 
past and present, favorable and unfavorable. 
 
 The Government reposes a high degree of trust and confidence in persons with 
access to classified information. This relationship transcends normal duty hours and 
endures throughout off-duty hours. Decisions include, by necessity, consideration of the 
possible risk that the applicant may deliberately or inadvertently fail to safeguard 
classified information. Such decisions entail a certain degree of legally permissible 
extrapolation about potential, rather than actual, risk of compromise of classified 
information. 
 
Clearance decisions must be made “in terms of the national interest and shall in 
no sense be a determination as to the loyalty of the applicant concerned.”  See Exec. 
Or. 10865 § 7. Thus, a decision to deny a security clearance is merely an indication the 
applicant has not met the strict guidelines the President and the Secretary of Defense 
have established for issuing a clearance. 
 
 Initially, the Government must establish, by substantial evidence, conditions in 
the personal or professional history of the applicant that may disqualify the applicant 
from being eligible for access to classified information. The Government has the burden 
 
7 
 
 
of establishing controverted facts alleged in the SOR. See Egan, 484 U.S. at 531.  
“Substantial evidence” is “more than a scintilla but less than a preponderance.”  See v. 
Washington Metro. Area Transit Auth., 36 F.3d 375, 380 (4th Cir. 1994). The guidelines 
presume a nexus or rational connection between proven conduct under any of the 
criteria listed therein and an applicant’s security suitability. See ISCR Case No. 92-1106 
at 3, 1993 WL 545051 at *3 (App. Bd. Oct. 7, 1993).   
 
 Once the Government establishes a disqualifying condition by substantial 
evidence, the burden shifts to the applicant to rebut, explain, extenuate, or mitigate the 
facts. Directive ¶ E3.1.15. An applicant has the burden of proving a mitigating condition, 
and the burden of disproving it never shifts to the Government. See ISCR Case No. 02-
31154 at 5 (App. Bd. Sep. 22, 2005).  
 
An applicant “has the ultimate burden of demonstrating that it is clearly consistent 
with the national interest to grant or continue his security clearance.” ISCR Case No. 
01-20700 at 3 (App. Bd. Dec. 19, 2002). “[S]ecurity clearance determinations should err, 
if they must, on the side of denials.” Egan, 484 U.S. at 531; see AG ¶ 2(b).  
 
Analysis 
 
Guideline F, Financial Considerations 
 
The concern under this guideline is set out in AG ¶ 18:  
 
Failure or inability to live within one=s means, satisfy debts, and meet 
financial obligations may indicate poor self-control, lack of judgment, or 
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. An individual who is financially 
overextended is at risk of having to engage in illegal acts to generate 
funds. 
 
 This concern is broader than the possibility that an applicant might knowingly 
compromise classified information in order to raise money. It encompasses concerns 
about an applicant’s self-control, judgment, and other qualities essential to protecting 
classified information. An individual who is financially irresponsible may also be 
irresponsible, unconcerned, or negligent in handling and safeguarding classified 
information. See ISCR Case No. 11-05365 at 3 (App. Bd. May 1, 2012). 
 
 Applicant’s credit reports, his admissions in response to the LOI, and his 
testimony at the hearing establish the following disqualifying conditions under this 
guideline:  
 
AG ¶ 19(a): inability or unwillingness to satisfy debts;  
 
AG ¶ 19(c): a history of not meeting financial obligations; and 
 
8 
 
 
AG ¶ 19(e): consistent spending beyond one’s means, which may be 
indicated by excessive indebtedness, significant negative cash flow, high 
debt-to-income ratio, and/or other financial analysis. 
 
 Security concerns based on financial considerations may be mitigated by any of 
the following conditions: 
 
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; 
 
AG ¶ 20(b): the conditions that resulted in the financial problem 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; 
 
AG ¶ 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; 
 
AG ¶ 20(d): the individual initiated a good-faith effort to repay overdue 
creditors or otherwise resolve debts; or  
 
AG ¶ 20(e): the individual has a reasonable basis to dispute the legitimacy 
of the past-due debt which is the cause of the problem and provides 
documented proof to substantiate the basis of the dispute or provides 
evidence of actions to resolve the issue. 
 
 AG ¶ 20(a) is not established. Applicant’s delinquent debts are ongoing, 
numerous, and not the result of circumstances making them unlikely to recur.  
 
 The first prong of AG ¶ 20(b) is established, because Applicant encountered 
several conditions beyond his control: his unemployment and underemployment after 
being discharged from the Air Force, his wife’s alcohol and drug abuse and the marital 
discord and breakup that resulted from it, the expense of maintaining two households 
while they were separated, and the numerous medical debts incurred by him and his 
family. However, the second prong of AG ¶ 20(b), requiring responsible conduct, is not 
established, because Applicant did not take meaningful steps to gain control of his 
financial situation until he received the SOR. 
 
 The first prong of AG ¶ 20(c) is established, because Applicant received 
counseling from the debt management program and advice from his attorney. However, 
the second prong is not established, because there are not yet “clear indications” that 
the problem is being resolved. Although Applicant has devised a plan for resolving his 
 
9 
 
 
debts, he has not shown that his creditors will agree to the plan and he had not made 
any payments under the plan as of the date the record closed. 
 
 AG ¶ 20(d) is established for the debts alleged in SOR ¶¶ 1.aa, 1.kk, and 1.ww, 
which were resolved before issuance of the SOR, but not for the remaining debts 
alleged in the SOR. Good faith means acting in a way that shows reasonableness, 
prudence, honesty, and adherence to duty or obligation. ISCR Case No. 99-0201, 1999 
WL 1442346 at *4 (App. Bd. Oct. 12, 1999). Evidence of past irresponsibility is not 
mitigated by payment of debts motivated primarily by the pressure of qualifying for a 
security clearance. Applicant did not contact the debt management company and 
consult with an attorney until after he received the SOR. The evidence indicates that his 
belated actions were not motivated by a sense of duty to his creditors, but by the 
realization that he could not obtain a security clearance until he resolved his financial 
problems. 
 
 AG ¶ 20(e) is established for the disputed debts alleged in SOR ¶¶ 1.d, 1.g, 1.l-
1.m, 1.v, 1.x, 1.ee-1.ff, 1.ii-1.jj, 1.nn, 1.ss-1.vv, 1.zz, and 1.ccc. Applicant’s reasons for 
disputing these debts are plausible, reasonable, and credible. The requirement for 
documentation of his actions to resolve the disputes is satisfied by copies of his letters 
sent to the three credit bureaus.  
 
Whole-Person Concept 
 
 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. In applying the whole-
person concept, an administrative judge must evaluate an applicant’s eligibility for a 
security clearance by considering the totality of the applicant’s conduct and all relevant 
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 
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.  
 
 I have incorporated my comments under Guideline F in my whole-person 
analysis. Some of the factors in AG ¶ 2(a) were addressed under that guideline, but 
some warrant additional comment. 
 
 Applicant is a compassionate man who has taken family members into his home 
even though he was struggling financially. He served in the Air Force for almost five 
 
10 
 
 
years, where he held a security clearance, apparently without incident. He was candid, 
sincere, and credible at the hearing. On the other hand, he has a long track record of 
neglecting his financial responsibilities. Although he has been employed continuously 
since November 2006 and has worked for his current employer since May 2009, he took 
virtually no action to gain control of his financial situation until he received the SOR. He 
has devised a realistic payment plan, but his creditors have not yet agreed to it, and he 
has not established a track record of financial responsibility.  
 
 After weighing the disqualifying and mitigating conditions under Guideline F, and 
evaluating all the evidence in the context of the whole person, I conclude Applicant has 
not mitigated the security concerns based on financial considerations. Accordingly, I 
conclude he has not carried his burden of showing that it is clearly consistent with the 
national interest to grant him eligibility for access to classified information. 
 
Formal Findings 
 
 I make the following formal findings on the allegations in the SOR: 
 
 Paragraph 1, Guideline F (Financial Considerations): AGAINST APPLICANT 
 
  Subparagraphs 1.a-1.c:    Against Applicant 
  Subparagraphs 1.d-1.e:    For Applicant 
  Subparagraph 1.f:     Against Applicant 
  Subparagraph 1.g:     For Applicant 
  Subparagraphs 1.h-1.k:    Against Applicant 
  Subparagraphs 1.l-1.m:    For Applicant 
  Subparagraphs 1.n-1.u:    Against Applicant 
  Subparagraph 1.v:     For Applicant 
  Subparagraph 1.w:     Against Applicant 
  Subparagraph 1.x:     For Applicant 
  Subparagraphs 1.y-1.z:    Against Applicant 
  Subparagraph 1.aa:     For Applicant 
  Subparagraphs 1.bb-1.dd:    Against Applicant 
  Subparagraphs 1.ee-1.ff:    For Applicant 
  Subparagraphs 1.gg-1.hh:    Against Applicant 
  Subparagraphs 1.ii-1.ll:    For Applicant 
  Subparagraph 1.mm:    Against Applicant 
  Subparagraph 1.nn:     For Applicant 
  Subparagraphs 1.oo-1.rr:    Against Applicant 
  Subparagraphs 1.ss-1.ww:    For Applicant 
  Subparagraphs 1.xx-1.yy:    Against Applicant 
  Subparagraph 1.zz:     For Applicant 
  Subparagraphs 1.aaa-1.bbb:   Against Applicant 
  Subparagraph 1.ccc:    For Applicant 
  Subparagraphs 1.ddd-1.eee:   Against Applicant 
 
 
11 
 
 
Conclusion 
 
 I conclude that it is not clearly consistent with the national interest to grant 
Applicant eligibility for a security clearance. Eligibility for access to classified information 
is denied. 
 
 
 
 
LeRoy F. Foreman 
Administrative Judge