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DEPARTMENT OF DEFENSE 
DEFENSE OFFICE OF HEARINGS AND APPEALS 
           
             
 
 
In the matter of: ) 
 ) 
 [Redacted] )  ISCR Case No. 11-00328 
 ) 
Applicant for Security Clearance ) 
 
 
Appearances 
 
For Government: Julie R. Mendez, Esq., Department Counsel 
For Applicant: Dennis J. Sysko, Esq. 
 
 
______________ 
 
Decision 
______________ 
 
 
FOREMAN, LeRoy F., Administrative Judge: 
 
This case involves security concerns raised under Guideline G (Alcohol 
Consumption). Eligibility for access to classified information is granted. 
 
Statement of the Case 
 
Applicant submitted a security clearance application on September 21, 2010. On 
June 29, 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 continue his 
access to classified information, and it recommended that his case be submitted to an 
administrative judge for a determination whether to continue or revoke his security 
clearance. DOHA set forth the basis for its action in a Statement of Reasons (SOR), 
citing security concerns under Guideline G. 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.  
 
 
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 Applicant received the SOR on July 10, 2012; answered it on July 26, 2012; and 
requested a hearing before an administrative judge. DOHA received the request on 
August 1, 2012. Department Counsel was ready to proceed on August 22, 2012, and 
the case was assigned to me on August 30, 2012. DOHA issued a notice of hearing on 
September 6, 2012, scheduling it for September 27, 2012. I convened the hearing as 
scheduled. Government Exhibits (GX) 1 through 8 were admitted in evidence without 
objection. Applicant testified, presented the testimony of one witness, and submitted 
Applicant’s Exhibits (AX) A through E,1 which were admitted without objection. DOHA 
received the transcript (Tr.) on October 4, 2012. 
 
Findings of Fact 
 
 In his answer to the SOR, Applicant admitted all the allegations in the SOR. His 
admissions in his answer and at the hearing are incorporated in my findings of fact.  
 
 Applicant is a 34-year-old employee of a defense contractor. He worked as an 
intern with his current employer from July 1999 to August 2000. He received a 
bachelor’s degree in management science in May 2001, and he began full-time 
employment in December 2001. (GX 1 at 12-13.) He received a security clearance in 
June 2004. (GX 1 at 37-38.) In May 2011, he was promoted and assigned to a 
sensitive, high-visibility program providing direct support to troops deployed in a combat 
zone. The program requires conference calls with deployed units seven days a week 
and frequent briefings for high-level officials. (Tr. 29-30.)  
 
 Applicant and his wife work for the same defense contractor. Applicant’s wife 
received a security clearance in 2007. (Tr. 90.) They met at work, began dating in 2005, 
started living together in 2006, and married in May 2008. They have a 22-month-old son 
and are expecting another child in January 2013.  
 
 Applicant began consuming alcohol in high school. In the early morning of 
September 14, 1996, his first month in college, he was cited for public intoxication after 
the police found him lying beside a road, heavily intoxicated. He was held in jail for 
about six hours and released on his own recognizance. In October 1996, he paid a $25 
fine and was required to perform 30 hours of community service. (GX 8; Tr. 34.) 
 
In June 1997, Applicant was cited for underage possession of alcohol after police 
were called to quell a loud party at which he and other underage friends were 
consuming alcohol. The case was disposed of by nolle prosequi. (GX 7; Tr. 35.) 
 
 In December 2002, Applicant was cited for possession of an open container of 
alcohol in public as he and friends were walking home from a tailgate party. He was not 
intoxicated. After he completed eight hours of community service, the case was 
disposed of by nolle prosequi. (GX 2 at 6; GX 6; Tr. 36.) 
 
                                                          
1 AX E consists of ten documents, marked as AX E-1 through AX E-10.  
 
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 In April 2003, Applicant was stopped for speeding (40 miles per hour in a 25-
mile-per-hour zone). The police officer smelled alcohol and noticed that Applicant’s 
speech was slurred. Applicant failed a field sobriety test and registered a blood-alcohol 
content (BAC) of .11 in a breath test. He was charged with driving under the influence 
(DUI). He pleaded guilty and was sentenced to 30 days in jail (suspended), a $750 fine 
($500 suspended), and placed on probation for 12 months. He was required to attend 
an alcohol safety action program (ASAP) and his driver’s license was suspended for 12 
months. (GX 5.) 
 
 In September 2004, Applicant was arrested for DUI. He pleaded guilty, paid a 
$250 fine, and received probation before judgment. The charges were dismissed after 
he completed community service. His driver’s license was suspended for 12 months, 
and he was required to obtain alcohol counseling. From February to June 2005, he 
attended a one-hour group counseling session once a week. He received no diagnosis 
or prognosis. (GX 2 at 5, 25-26.) 
 
 Applicant testified that his September 2004 DUI caused him to realize that he 
needed to change his behavior. He was in a serious relationship with his future wife, 
remodeling a house, assuming more responsibility at work, and making new friends 
among his coworkers. (Tr. 39.) His wife testified that their weekends moved away from 
the college-party lifestyle to a more “domesticated” lifestyle, in which they took care of 
the house, did the laundry, and cared for their son. (Tr. 92-93.) She also testified, “If we 
do have a social event, it’s typically with people that we’re working with. I mean we work 
-- we have very intense jobs and we’re surrounding ourselves with people who share 
those common values.” (Tr. 98-99.) Applicant moderated his alcohol consumption and 
had no alcohol-related incidents for six years. 
 
 On September 1, 2010, while on temporary duty away from home, Applicant was 
arrested for aggravated DUI (a BAC of .16 or more) and careless driving. (GX 4.) This 
arrest occurred after he arrived at the temporary duty station late in the evening and 
learned that the mission had been cancelled. He drove to a restaurant about two miles 
from his hotel, where he expected to meet a colleague for dinner. The colleague never 
arrived. Applicant ate dinner and consumed one drink of hard liquor and several beers 
while watching sports on television. He waited about an hour before leaving the 
restaurant, in order to allow the effects of the alcohol to wear off. He drove away from 
the restaurant, heading for his hotel, and was stopped by a police officer for speeding, 
weaving, and tailgating. He failed a field sobriety test and his breath test registered a 
BAC between .17 and .18. He was held in jail overnight. The next morning, he notified 
his facility security officer, supervisor, and wife of his arrest and detention. (Tr. 45.) He 
disclosed his arrest when he submitted his security clearance application three weeks 
later. (GX 1 at 34.) 
 
Applicant’s wife testified that after he was released and returned home, he told 
her: “This is the way it is going to be. This is what we are going to do. And we’re going 
to move forward.” (Tr. 96.) Applicant began attending Alcoholics Anonymous (AA) 
meetings four or five times a week. (Tr. 45.) In September and October 2010, he 
 
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voluntarily obtained weekly counseling from a medical professional recommended by 
his employer. He received no diagnosis or prognosis. (GX 2 at 5, 12.)  
 
In November 2010, Applicant returned to the site of his DUI arrest for his trial, 
accompanied by his father. He pleaded guilty to DUI and was placed on probation for 
one year. He was required to perform 24 hours of community service, attend an alcohol 
education class, and attend a victim-impact panel. He continued to attend AA meetings 
until November 2011. (GX 2 at 21; GX 4; Tr. 42-44.) He completed all the court-ordered 
requirements. (AX A; AX B.)  
 
 Applicant abstained from alcohol until January 2011. He testified that abstaining 
from alcohol was much easier than he thought it would be. He then began occasionally 
consuming one or two drinks at a sitting. He testified that, after a long conversation with 
his wife, he decided to “have a couple of drinks every now and then” to demonstrate 
that he could be a responsible drinker. Applicant’s wife was familiar with the effects of 
alcohol abuse on a family before she married Applicant, because her brother had 
serious alcohol problems. (Tr. 113-14.) 
 
At the hearing, Applicant estimated that he consumed alcohol in moderation on 
about ten occasions after January 2011. He decided to stop drinking on July 4, 2012, 
because he discovered that he no longer enjoyed it. He decided that “the hassle of 
making sure that everything is perfectly aligned” before consuming alcohol “doesn’t 
seem worth it.” He had not resumed his alcohol consumption as of the date of the 
hearing. He resumed his AA participation in July 2012 and now attends about one 
meeting a week. (Tr. 51-53, 79.)  
 
Applicant testified that he and his wife socialize with young parents and 
professionals, and their social life is focused on “children and naptime and getting in 
bed at an early time.” (Tr. 54-55.) He avoids bars, and on occasion has declined social 
invitations to alcohol-centered events. (Tr. 84-85.) His wife described him as “an 
amazing father and an amazing husband.” (Tr. 106.)   
 
 Starting in February 2011, Applicant became the primary care-taker for his aged 
and disabled mother. About a year ago, Applicant’s wife, who was then seven or eight 
weeks pregnant, suffered a miscarriage, thrusting additional physical and emotional 
burdens on Applicant. In October 2011, his wife broke her foot, requiring that Applicant 
be the primary caregiver for her and their infant child. All these responsibilities have 
made Applicant focus on family responsibilities. (Tr. 55-58.) He testified that he stopped 
drinking while his wife was recovering because he “couldn’t be a position where 
someone needed a ride and [he] was not able to provide that ride.” (Tr. 58.)  
 
On September 4, 2012, Applicant obtained an evaluation from a licensed clinical 
alcohol and drug counselor, but it did not include a diagnosis or prognosis. The 
counselor recommended that Applicant totally abstain from alcohol. (AX C.) On 
September 19, 2012, Applicant executed a “Statement of Intent” to never abuse alcohol 
 
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in the future, and he stated that he consented to automatic revocation of his security 
clearance if there should be “any violation with regard to alcohol use.” (AX D.)  
 
 Applicant’s senior manager, who had daily contact with him from July 2009 to 
October 2010 and weekly contact from October 2010 to the present, submitted a letter 
supporting continuance of Applicant’s security clearance. He described Applicant’s 
performance as “exemplary.” He stated that Applicant’s “work is impeccable, the results 
are consistently lauded by his clients, and he maintains a reputation for outstanding and 
professional work both within our company and with his clients.” He described Applicant 
as a reliable, trustworthy, and valuable employee. (AX E-1.) 
 
 A retired Army lieutenant colonel, who has 22 years of military service and 19 
years as a defense contractor, has known Applicant since his initial employment as an 
intern. He considers Applicant an exceptionally talented, hard-working, dedicated, 
trustworthy, and mature employee. (AX E-2.)  
 
 A friend who has known Applicant since elementary school and was his college 
classmate introduced him to AA in September 2010. He described Applicant as a good 
friend and a dedicated spouse and father, with “good values to the core.” He believes 
that Applicant has been proactive in addressing his alcohol problems and now has the 
tools to move forward with his life. (AX E-3.)  
 
Another long-time friend and professional colleague stated that Applicant retains 
his “upmost respect, trust, and confidence.” He has personally observed Applicant’s 
actions to overcome his alcohol-related problems, and recommends that his clearance 
be continued. (AX E-5.)  
 
A friend since college, who is now a senior federal employee, is one of a group of 
five friends (including Applicant) who meet regularly for breakfast. He considers 
Applicant professionally competent, capable, a person of high integrity, and a “friend of 
the highest caliber.” He states that Applicants “trajectory in life is one of progress and 
improvement. (AX E-7.) 
 
 A former colleague from 2000-2004, who is now a senior civilian employee of the 
Army, regards Applicant as dependable and trustworthy. He is aware that Applicant 
“had a DWI a few years back,” but he is confident that Applicant has overcome his 
problems with alcohol and can be entrusted with classified information. (AX E-4.) 
 
 Another colleague, who has known Applicant for about four years, states that 
Applicant “demonstrates strong technical competence, depth of subject matter 
expertise, and [a] work ethic matched by few of his peers.” He has watched Applicant 
demonstrate his maturity, sound judgment, and respect for others. He regards Applicant 
as a mentor, a friend, and a dedicated family man. (AX E-6.) 
 
 A coworker, for whom Applicant has been a mentor for the past three years, has 
great trust and confidence in Applicant’s guidance on professional as well as personal 
 
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matters. He states that he “cannot speak highly enough” regarding Applicant’s loyalty, 
trustworthiness, good character, and integrity. (AX E-8.) 
 
 A currently-serving federal law enforcement agent, who worked for Applicant’s 
employer from 1998 to 2002, encouraged Applicant to work for their employer because 
they needed an intelligent, dependable, and hard-working individual for a specific 
project. He found that Applicant was mature, truthful, and trustworthy. (AX E-9.) 
 
 A former client of Applicant’s employer, who is now a senior federal employee 
and has known Applicant for more than eight years, stated that he has observed a 
“drastic change” in Applicant’s behavior over the past 18 months. He states that 
Applicant has become a role model and has recognized the importance of being a 
father. (AX E-10.) 
 
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 and 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. 
 
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 Initially, the Government must establish, by substantial evidence, conditions in 
the personal or professional history of the applicant that may disqualify the applicant 
from being eligible for access to classified information. The Government has the burden 
of establishing controverted facts alleged in the SOR. See Egan, 484 U.S. at 531.  
“Substantial evidence” is “more than a scintilla but less than a preponderance.”  See v. 
Washington Metro. Area Transit Auth., 36 F.3d 375, 380 (4th Cir. 1994). The guidelines 
presume a nexus or rational connection between proven conduct under any of the 
criteria listed therein and an applicant’s security suitability. See ISCR Case No. 92-1106 
at 3, 1993 WL 545051 at *3 (App. Bd. Oct. 7, 1993).   
 
 Once the Government establishes a disqualifying condition by substantial 
evidence, the burden shifts to the applicant to rebut, explain, extenuate, or mitigate the 
facts. Directive ¶ E3.1.15. An applicant has the 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 G, Alcohol Consumption 
 
 The SOR alleges Applicant was charged with aggravated DUI and careless 
driving in September 2010 and pleaded guilty to DUI (SOR ¶ 1.a); charged with DUI in 
September 2004 and received probation before judgment (SOR ¶ 1.b); charged with 
DUI in April 2003 and pleaded guilty (SOR ¶ 1.c); cited for possession of an open 
container of alcohol in December 2002 (SOR ¶ 1.d); cited for underage possession of 
alcohol in June 1997 (SOR ¶ 1.e); and cited for public intoxication in September 1996 
(SOR ¶ 1.f).  
 
The concern under this guideline is set out in AG ¶ 21: “Excessive alcohol 
consumption often leads to the exercise of questionable judgment or the failure to 
control impulses, and can raise questions about an individual's reliability and 
trustworthiness.” The following disqualifying conditions under this guideline are 
potentially relevant: 
 
AG ¶ 22(a): alcohol-related incidents away from work, such as driving 
while under the influence, fighting, child or spouse abuse, disturbing the 
peace, or other incidents of concern, regardless of whether the individual 
is diagnosed as an alcohol abuser or alcohol dependent;  
 
 
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AG ¶ 22(c): habitual or binge consumption of alcohol to the point of 
impaired judgment, regardless of whether the individual is diagnosed as 
an alcohol abuser or alcohol dependent;  
 
AG ¶ 22(d): diagnosis by a duly qualified medical professional (e.g., 
physician, clinical psychologist, or psychiatrist) of alcohol abuse or alcohol 
dependence; 
 
AG ¶ 22(e): evaluation of alcohol abuse or alcohol dependence by a 
licensed clinical social worker who is a staff member of a recognized 
alcohol treatment program;  
 
AG ¶ 22(f): relapse after diagnosis of alcohol abuse or dependence and 
completion of an alcohol rehabilitation program; and 
 
AG ¶ 22(g): failure to follow any court order regarding alcohol education, 
evaluation, treatment, or abstinence. 
 
The evidence set out in the above “Findings of Fact” establishes AG ¶¶ 22(a) and 
(c). AG ¶¶ 22(d) and (e) are not established, because Applicant has never had a 
diagnosis or evaluation of alcohol abuse or alcohol dependence. His DUI arrest in 
September 2010 was a “relapse” within the meaning of AG ¶ 22(f), but this disqualifying 
condition is not fully established because he has not received a diagnosis of alcohol 
abuse or dependence. AG ¶ 22(f) is not established because Applicant complied with all 
court orders that followed his alcohol-related behavior. 
 
 Security concerns under this guideline may be mitigated if “so much time has 
passed, or the behavior was so infrequent, or it happened under such unusual 
circumstances that it is unlikely to recur or does not cast doubt on the individual's 
current reliability, trustworthiness, or good judgment.” AG ¶ 23(a). The first prong of this 
mitigating condition (“so much time has passed”) focuses on whether the conduct was 
recent. There are no Abright line@ rules for determining when conduct is Arecent.@ The 
determination must be based on a careful evaluation of the totality of the evidence. If 
the evidence shows Aa significant period of time has passed without any evidence of 
misconduct,@ then an administrative judge must determine whether that period of time 
demonstrates Achanged circumstances or conduct sufficient to warrant a finding of 
reform or rehabilitation.@ ISCR Case No. 02-24452 at 6 (App. Bd. Aug. 4, 2004). 
 
 Applicant’s last alcohol-related incident was two years ago, which is a significant 
period of time. Six years of responsible alcohol use preceded his September 2010 
arrest. He has alternated between responsible use and abstinence since his September 
2010 arrest. He decided in July 2012 that abstinence was the best course of action for 
him, because he no longer enjoyed consuming alcohol and it was easier than carefully 
monitoring his consumption. I conclude that the first prong of AG ¶ 23(a) is established. 
The second prong (“so infrequent”) is not established, nor is the third (“it happened 
 
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under such unusual circumstances that it is unlikely to recur or does not cast doubt on 
the individual's current reliability, trustworthiness, or good judgment”). 
 
 Security concerns also may be mitigated if “the individual acknowledges his or 
her alcoholism or issues of alcohol abuse, provides evidence of actions taken to 
overcome this problem, and has established a pattern of abstinence (if alcohol 
dependent) or responsible use (if an alcohol abuser).” AG ¶ 23(b). Although Applicant 
has never received a diagnosis or evaluation of alcohol dependence or alcohol abuse, 
he has acknowledged that he has an alcohol problem. He voluntarily sought alcohol 
counseling in September and October 2010. He abstained for 11 months, tried 
responsible use without incident, but decided on his own that abstinence was his best 
course of action. He participated frequently in AA until November 2011, and he has 
recently resumed participation. I conclude that AG ¶ 23(b) is established. 
 
 Finally, security concerns under this guideline may be mitigated under AG ¶ 
23(d) if: 
 
[T]he individual has successfully completed inpatient or outpatient 
counseling or rehabilitation along with any required aftercare, has 
demonstrated a clear and established pattern of modified consumption or 
abstinence in accordance with treatment recommendations, such as 
participation in meetings of Alcoholics Anonymous or a similar 
organization and has received a favorable prognosis by a duly qualified 
medical professional or a licensed clinical social worker who is a staff 
member of a recognized alcohol treatment program. 
 
This mitigating condition is partially established. Applicant has successfully completed 
outpatient counseling. He did not receive any treatment recommendations until 
September 2012. He has modified his alcohol consumption and recently decided to 
abstain. He is participating in AA. However, he did not present evidence of a favorable 
prognosis. 
 
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 
 
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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 G 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 mature, well-educated, talented employee. He was candid, sincere, 
thoughtful, and remorseful at the hearing. After his September 2004 DUI, he obtained 
counseling, became seriously involved with the woman who became his wife, and 
moderated his alcohol consumption. His September 2010 DUI differed from his previous 
alcohol-related episodes, because it involved solitary drinking rather than social 
drinking, but the common denominator with his prior episodes was his inability or 
unwillingness to stop drinking before becoming intoxicated. Since September 2010, he 
has acted responsibly. He has a new circle of friends who are more interested in family 
and work than in partying and drinking. He has strong support from his wife, who has 
previously dealt with her brother’s alcohol problems.  
 
 Applicant is a devoted father and husband. He has disclosed his alcohol problem 
to his colleagues, supervisors, family members and friends, minimizing the potential for 
pressure, coercion, exploitation, or duress. His “Statement of Intent” does not fall within 
any of the mitigating conditions under Guideline G, but it is analogous to the Statement 
of Intent for drug involvement in AG ¶ 26(b)(4) under Guideline H. It is a strong 
demonstration of his intent to refrain from further alcohol abuse. I am satisfied that 
recurrence is unlikely. 
 
 After weighing the disqualifying and mitigating conditions under Guideline G, 
evaluating all the evidence in the context of the whole person, and mindful of my 
responsibility to decide close cases in favor of national security, I conclude Applicant 
has mitigated the security concerns based on alcohol consumption. Accordingly, I 
conclude he has carried his burden of showing that it is clearly consistent with the 
national interest to continue his eligibility for access to classified information. 
 
Formal Findings 
 
 I make the following formal findings on the allegations in the SOR: 
 
 Paragraph 1, Guideline G (Alcohol Consumption): FOR APPLICANT 
 
  Subparagraphs 1.a-1.f:    For Applicant 
 
 
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Conclusion 
 
 I conclude that it is clearly consistent with the national interest to continue 
Applicant’s eligibility for a security clearance. Eligibility for access to classified 
information is granted. 
 
 
 
 
LeRoy F. Foreman 
Administrative Judge