Applicant requested about a three-month delay for the hearing to complete his financial plans. In late      1
August, he hired counsel who needed time to prepare for the case. 
1
                                                             
                           
                        DEPARTMENT OF DEFENSE
         DEFENSE OFFICE OF HEARINGS AND APPEALS
          
            
In the matter of: )
)
         )
)
)       ISCR Case No. 11-13048
Applicant for Security Clearance
Appearances
For Government: Philip Katauskas, Esq., Department Counsel
For Applicant: Alan V. Edmunds, Esq.
                                                                            
______________
Decision
______________
LYNCH, Noreen, A., Administrative Judge:
The Defense Office of Hearings and Appeals (DOHA) issued Applicant a
Statement of Reasons (SOR) alleging security concerns arising under Guideline F
(Financial Considerations) and Guideline E (Personal Conduct). The SOR was dated
February 23, 2012. 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 in September 2006. 
Applicant timely answered the SOR and requested a hearing before an
administrative judge. The case was assigned to me on June 14, 2012. DOHA issued a
notice of hearing on July 6, 2012, scheduling the hearing for September 6, 2012.  On1
August 24, 2012, an amended notice of hearing scheduled the case for September 25,
2
2012. Due to a scheduling conflict the case was rescheduled. An amended notice of
hearing dated September 7, 2012, scheduled the hearing for October 2, 2012.
Government Exhibits (GX) 1-14 were admitted into evidence, without objection.
Applicant testified, presented one witness, and submitted Applicant Exhibits (AX) A-AA,
which were admitted without objection. I kept the record open until October 12, 2012 for
additional documents. Applicant timely submitted five documents, which were marked
as (AX) BB-FF. DOHA received the transcript (Tr.) on October 10, 2012. Based on a
review of the pleadings, testimony, and exhibits, eligibility for access to classified
information is denied.
Findings of Fact
In his answer to the SOR, Applicant admitted  factual allegations under Guideline
F (Financial Considerations), with the exception of three. Applicant denied the
allegations under  Guideline E (Personal Conduct) with explanations. 
Applicant is a 52-year-old lead engineer of a defense contractor. (Tr. 48) He is a
retired naval o-fficer and helicopter pilot. He received his undergraduate degree in 1982
and has completed post-graduate work. (AX N, V) Applicant has held a security
clearance since 1984. (GX 1) He has been with his current employer since July 2012.
(Tr. 104)
Applicant married in 1986 and divorced in April 2005. As a result of the marriage,
they had three children. His first marriage ended as a result of the death of his three-
year-old child. He explained that while he was deployed, his wife allowed their son to
step outside where the child drowned in the pool. (Tr. 56) He states that this was the
end of the marriage.
Applicant’s separation and divorce was difficult both emotionally and financially.
After his son’s death in 1994, his wife, who blamed herself completely, was in conflict
with Applicant in the marriage. The huge rift led to the separation and divorce. He also
claimed that when the marriage dissolved, his wife recast him as a bad father and
turned the children against him.
Applicant remarried in May 2005. He and his second wife have five children. Two
other children died shortly after birth. (Tr. 60) He and his wife moved to another state to
start a business. The business ended in 2006.
In May 2008, Applicant was brutally beaten and left to die. He was in a coma for
three weeks, and spent six months in a hospital. He suffered massive brain damage
and was unable to work for 18 months. He was not released for work as the physicians
did not believe he would live very long. Despite the odds, he fought hard to walk again
and refused disability payments. He wanted to return to his work. Applicant worked
sporadically and had contract work which ended in 2009. He had steady work from
2010 to 2012. (Tr. 105)
3
He searched for work but still could not maintain his daily expenses such as rent.
He was taken to court for nonpayment of rent in 2006, 2009, and evicted in 2010. He
exhausted his savings.
Financial Considerations
Applicant admitted that at the start of the investigation, he had failed to file his
income taxes for 2008, 2009, and 2010. In 2011, he filed them, receiving a refund for
those years. (Answer to SOR with attachment) He states that this was due in part to his
recovery from his 2008 accident.  In 2012, he entered into an agreement with the IRS to
resolve his previous tax debt from 2004 and 2005. (AX BB) The tax returns from 2004
and 2005 that Applicant originally submitted were rejected by the IRS. (Tr. 124)
Applicant explained that he owed the IRS about $198,000, which included
interest and penalties. He blamed the debt on the fact that he was not allowed to claim
his dependent children on his returns for those years. He also acknowledged that while
the correct action would have been to address the problem, he avoided it until the IRS
took garnishment actions. He was candid that he had no incentive to pay the taxes
when he learned about them and neglected them. (Tr. 125) He has now entered into an
installment agreement. As of July 20, 2012, his monthly payment is $177, which will
increase to $710 in 2013. This amount will increase again later in 2013. The installment
plan is three years. He still believes it was the result of the illegal and immoral actions of
others. (TR. 50) Appellant submitted documentation that he pays the monthly amount
through USAtax.com. He has paid August and September 2012. (AX CC-DD)
Applicant denied a history of failing to pay rent in a timely manner.  He denied
the court actions in 2006, 2009, and 2010. However, in his February 23, 2012, answer
to the SOR, he stated that he was in negotiations with the apartment complex through
legal counsel. He did not submit any documentation to support his claim.
Applicant states that he paid the debts alleged in SOR ¶ 1.e ($15) and 1.f ($15).
He did not provide any documentation to support his claim. He also noted that two
accounts are duplicates. (Tr. 55) SOR ¶¶ 1.g and 1.l are the same and 1.k is the same
as 1.m.
Applicant’s 2005 divorce resulted in delinquent debts. Applicant repeatedly
stated that he “inherited debt from the marriage.” However, he testified that they were
mutual debts that were awarded to him. (Tr. 95) He did not attempt to resolve them until
after the security clearance process started. Granted, he had a failed business in 2006,
but he chose to remarry and start a new family. His new wife had two children from a
previous marriage. (Tr.60) They took a honeymoon to a resort. (Tr. 87) From 2006 until
2008, he was employed but did not make any attempts to pay any debts. Applicant
admitted that he did not make any attempt to pay the delinquent marital debts from
2005 to 2008. After his tragic injury in 2008, he was unemployed for almost a year. He
worked for a contractor in 2009. He also had full employment from 2010. Despite the
steady income, he has not resolved the delinquent debts.
4
The SOR alleges sixteen unresolved delinquent accounts totaling $82,000.
Applicant attributes these debts to the 2005 divorce. He recounts legal fees, alimony,
and child support. He also refers to a failed commercial business. He spent his savings
and investments in an attempt to make the business viable. The business ended in
August 2006. He states that he was unaware of some of the debts concerning rent. He
also noted that he does not deny the validity of the debts but rather the amounts.
(Tr.97)
Applicant testified that he is in negotiations with creditors through his attorney.
He also testified that he just hired the attorney because he was thinking about
bankruptcy. (Tr. 81) Then he believed he would not need a security clearance in July
2012 and deferred any actions. He was planning to defer any action if he did not need a
security clearance. Applicant did not submit any post-hearing documentation that
supported his statement that he has been working with an attorney who is in the
process of resolving the delinquent debts. Applicant also stated that he was working
with an attorney from February 2012 concerning bankruptcy but decided that was not a
good option. (Tr. 115) 
Applicant explained that after the 2008 injury, he could not keep up with his daily
expenses. His wife did not work and he worked sporadically after that time. He stated
that he used his savings and pawned items so that he could feed his family. (Tr.72)
They went to food banks so that they would have sufficient food. 
Applicant currently earns approximately $130,000 a year. He also has a naval
pension of $1,300 a month. After living expenses and debt repayment, he has a net
remainder of $2,497. These figures are taken from Applicant’s personal financial
statement. (GX 3) 
Personal Conduct
Applicant completed an SF 86 on August 11, 2009. He responded to Section
13C Employment Record in the following manner. Applicant worked for WBB from 1998
until 2005. (Tr. 108) He noted a  reprimand for violating a security policy or rule. He did
not note any firing or discharge from employment. He stated that in 2005, he left his job
from WBB for mutual reasons in his November 2010 affidavit. He did not believe he had
been terminated. (AX AA) He reaffirmed his claim in his May 31, 2011 subject interview
with an investigator that he was not terminated from his employment with WBB.
 The employer’s record noted that Applicant was discharged. (GX 8). The state
unemployment record also listed discharge/separation on their form. (GX 9) However,
Applicant produced an email from the President of WBB. (AX aa) Applicant had an
agreement with the President of the company who knew that Applicant wanted to go on
to a different project after eight years at the company. The President did not indicate
that Applicant was fired. At the time, Applicant did not see any human resources
documentation concerning his leaving the company. (Tr.44) He provided an email that
confirms the conversation and the belief that he left. Thus, he did not believe he was
terminated and had nothing to disclose under Section 13C. (AX AA)
5
Applicant claimed that he did not leave a rental apartment in ruins despite a
letter from the landlord stating the contrary. (GX 5 ) This was during his November 16,
2010 interview. 
Applicant denied in a May 31, 2011 interview that he had abandoned an
apartment and left significant damage to the unit. Applicant also denied that he had
damaged any rental properties during his answers to September 2011 DOHA
interrogatories. When Applicant responded to the September 27, 2011 interrogatories
he again denied that he had damaged property in 2007.
In 2004, Applicant’s adult daughter from his first marriage filed a claim of child
sexual abuse against Applicant. The case was referred to Child Protective Service
(CPS) and investigated. The daughter later recanted the story that she told to her
psychiatrist. The child sexual abuse charges were unsubstantiated and dropped. (GX 4)
Recommendations
A colleague of Applicant who he has known him for three years attests to his
dedication to country, integrity and qualifications. He is aware of the financial issues
alleged as a security concern and has no reservations about a favorable
recommendation for Applicant. (Tr.25) 
 Applicant submitted many letters of reference from his naval career. (AX A -AX
K). He has numerous certificates and awards from his naval career. (AX Q) He also
submitted a 2011 Annual Appraisal which noted that he surpassed goals for the year
and is an outstanding and valuable member of the team. (AX FF)
Policies
When evaluating an applicant’s suitability for a security clearance, an
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. These guidelines are not inflexible
rules of law. Instead, recognizing the complexities of human behavior, they are applied
in conjunction with the factors listed in the adjudicative process. An administrative
judge’s overarching adjudicative goal is a fair, impartial, and commonsense decision.
Under AG ¶ 2(c), this process is a conscientious scrutiny of a number of variables
known as the “whole-person concept.” An 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.
 See also ISCR Case No. 94-1075 at 3-4 (App. Bd. Aug. 10, 1995).      2
 Department of the Navy v. Egan, 484 U.S. 518, 531 (1988).      3
 ISCR Case No. 93-1390 at 7-8 (App. Bd. Jan. 27, 1995).      4
 See also EO 12968, Section 3.1(b) (listing multiple prerequisites for access to classified or sensitive      5
information), and EO 10865 § 7.
 ISCR Case No. 93-1390 at 7-8 (App. Bd. Jan. 27, 1995).      6
 Id.      7
6
The Government must present evidence to establish controverted facts alleged
in the SOR. An applicant is responsible for presenting “witnesses and other evidence to
rebut, explain, extenuate, or mitigate facts admitted by applicant or proven by
Department Counsel. . . .”  The burden of proof is something less than a2
preponderance of evidence.  The ultimate burden of persuasion is on the applicant.  3 4
A person seeking access to classified information enters into a fiduciary
relationship with the Government based on 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 classified information. Such
decisions entail a certain degree of legally permissible extrapolation of 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.”  “The clearly consistent standard indicates that security clearance5
determinations should err, if they must, on the side of denials.”  Any reasonable doubt6
about whether an applicant should be allowed access to sensitive information must be
resolved in favor of protecting such information.  The decision to deny an individual a7
security clearance does not necessarily reflect badly on an applicant’s character. It is
merely an indication that the applicant has not met the strict guidelines the President
and the Secretary of Defense established for issuing a clearance.
Analysis
Guideline F, Financial Considerations
AG ¶ 18 expresses the security concern pertaining to financial considerations:
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
7
questions about an individual's reliability, trustworthiness and ability to
protect classified information. An individual who is financially over-
extended is at risk of having to engage in illegal acts to generate funds.
Compulsive gambling is a concern as it may lead to financial crimes
including espionage. Affluence that cannot be explained by known
sources of income is also a security concern. It may indicate proceeds
from financially profitable criminal acts.
AG ¶ 19 describes conditions that could raise a security concern and may be
disqualifying:
(a) inability or unwillingness to satisfy debts;
(b) indebtedness caused by frivolous or irresponsible spending and the
absence of any evidence of willingness or intent to pay the debt or
establish a realistic plan to pay the debt;
(c) a history of not meeting financial obligations;
(d) deceptive or illegal financial practices such as embezzlement,
employee theft, check fraud, income tax evasion, expense account fraud,
filing deceptive loan statements, and other intentional financial breaches
of trust;
(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;
(f) financial problems that are linked to drug abuse, alcoholism, gambling
problems, or other issues of security concern;
(g) failure to file annual Federal, state, or local income tax returns as
required or the fraudulent filing of the same;
(h) unexplained affluence, as shown by a lifestyle or standard of living,
increase in net worth, or money transfers that cannot be explained by
subject's known legal sources of income; and
(i) compulsive or addictive gambling as indicated by an unsuccessful
attempt to stop gambling, "chasing losses" (i.e. increasing the bets or
returning another day in an effort to get even), concealment of gambling
losses, borrowing money to fund gambling or pay gambling debts, family
conflict or other problems caused by gambling.
Applicant admits to not filing his taxes in a timely manner and the delinquent
debts on the SOR. He also acknowledged that it was not a priority from 2005 until 2008
8
to pay the marital debts. Consequently, the evidence is sufficient to raise disqualifying
conditions ¶¶ 19(a), 19(c), and 19(g).
AG ¶ 20 provides conditions that could mitigate security concerns:
(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;
(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;
(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;
(d) the individual initiated a good-faith effort to repay overdue creditors or
otherwise resolve debts;
(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; and
(f) the affluence resulted from a legal source of income.
Applicant has approximately $82,000 in unresolved delinquent debt. He states
that much of the delinquent debt is marital debt from the 2005 divorce, including legal
fees. He did not file taxes for certain years. He has just started his IRS installment
agreement. He was divorced in 2005 which created some financial hardship. He had
been gainfully employed from 1998 (after retiring from the military) until 2005. He
remarried in 2005 and started a new family. He did have difficulty when he started a
new business venture. The business failed in 2006 and he did not generate much
income. He suffered a tragic injury in 2008 which resulted in almost one year
unemployment. However, from 2009 or 2010 until the present, he has been gainfully
employed. He acknowledged that he did not have financial counseling  He has been
gainfully employed since 2010, and claims he has paid two small accounts, but he did
not have proof of payment. He claimed he consulted a bankruptcy attorney in February
2012 and decided against bankruptcy. He then stated that he was in negotiations with
another attorney who was helping him resolve his delinquent debts. He did not produce
any documentation for this assertion.  He believed he would lose the contract and not
need his security clearance. He deferred any positive financial actions at that time.
Granted, the extensive injuries in 2008 and subsequent unemployment exacerbated his
financial situation.  However, he has not placed sufficient priority on resolving the
9
delinquent debts after being employed in 2010.  I find that Applicant’s financial
considerations concerns are not mitigated. He receives partial credit under AG ¶¶ 19(a)
and 19(b).
Guideline E, Personal Conduct
AG ¶ 15 expresses the security concern pertaining to personal conduct:
Conduct involving questionable judgment, lack of candor, dishonesty, or
unwillingness to comply with rules and regulations can raise questions
about an individual’s reliability, trustworthiness, and ability to protect
classified information.
AG ¶ 16 describes conditions that could raise a security concern and may be
disqualifying:
(a) deliberate omission, concealment, or falsification of relevant facts from
any personnel security questionnaire, personal history statement, or
similar form used to conduct investigations, determine employment
qualifications, award benefits or status, determine security clearance
eligibility or trustworthiness, or award fiduciary responsibilities;
(b) deliberately providing false or misleading information concerning
relevant facts to an employer, investigator, security official, competent
medical authority, or other official government representative;
(c) credible adverse information in several adjudicative issue areas that is
not sufficient for an adverse determination under any other single
guideline, but which, when considered as a whole, supports a whole-
person assessment of questionable judgment, untrustworthiness,
unreliability, lack of candor, unwillingness to comply with rules and
regulations, or other characteristics indicating that the person may not
properly safeguard protected information;
(d) credible adverse information that is not 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 indicating that the
person may not properly safeguard protected information. This includes
but is not limited to consideration of:
(1) untrustworthy or unreliable behavior to include breach of
client confidentiality, release of proprietary information,
unauthorized release of sensitive corporate or other
government protected information;
10
(2) disruptive, violent, or other inappropriate behavior in the
workplace; 
(3) a pattern of dishonesty or rule violations; and
(4) evidence of significant misuse of Government or other
employer's time or resources.
(e) personal conduct, or concealment of information about one's conduct,
that creates a vulnerability to exploitation, manipulation, or duress, such
as (1) engaging in activities which, if known, may affect the person's
personal, professional, or community standing, or (2) while in another
country, engaging in any activity that is illegal in that country or that is
legal in that country but illegal in the United States and may serve as a
basis for exploitation or pressure by the foreign security or intelligence
service or other group;
(f) violation of a written or recorded commitment made by the individual to
the employer as a condition of employment; and
(g) association with persons involved in criminal activity. 
As discussed above, Applicant did not believe that he was fired or terminated
from WBB in 2005. He answered Question 13C to the best of his knowledge. He
produced documentation that it was agreed that he left under mutual agreement. The
President of the company confirmed Applicant’s explanation. Applicant did not falsify
his SF 86 or the November 2010 affidavit or the May 2011 interview concerning the
WBB employment.  Applicant was credible in his explanation concerning the CPS child
sexual abuse charge. The charge was not substantiated and later dropped due to his
adult daughter’s recantation. Assuming that any of the disqualifying conditions apply,
Applicant has mitigated the security concerns.   
AG ¶ 17 provides conditions that could mitigate security concerns:
(a) the individual made prompt, good-faith efforts to correct the omission,
concealment, or falsification before being confronted with the facts;
(b) the refusal or failure to cooperate, omission, or concealment was
caused or significantly contributed to by improper or inadequate advice of
authorized personnel or legal counsel advising or instructing the individual
specifically concerning the security clearance process. Upon being made
aware of the requirement to cooperate or provide the information, the
individual cooperated fully and truthfully;
(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 it is
11
unlikely to recur and does not cast doubt on the individual's reliability,
trustworthiness, or good judgment;
(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;
(e) the individual has taken positive steps to reduce or eliminate
vulnerability to exploitation, manipulation, or duress;
(f) the information was unsubstantiated or from a source of questionable
reliability; and
(g) association with persons involved in criminal activity has ceased or
occurs under circumstances that do not cast doubt upon the individual's
reliability, trustworthiness, judgment, or willingness to comply with rules
and regulations.
Applicant denied all allegations under personal conduct. I find that he was
credible and has refuted the falsification allegations. He also was credible concerning
the child sexual abuse charge which was dropped. As to the allegations of damaged
property, I find him credible as to his explanation. He denies  that he left the properties
in a bad condition. After considering the mitigating conditions outlined in AG ¶ 17, I
conclude Applicant has  mitigated the security concern under personal conduct. 
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 the 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
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. As noted above, the
ultimate burden of persuasion is on the applicant seeking a security clearance. 
12
I considered the potentially disqualifying and mitigating conditions in light of all
the facts and circumstances surrounding this case, as well as the whole-person factors.
Applicant is a 52-year-old professional engineer. He has had a long and highly
decorated military career. He has held a security clearance since approximately 1984.
He is married and has five children. Applicant has been employed as a contractor for
many years.  He has many favorable employment recommendations. He is praised by
his current employer.
Applicant experienced divorce, unemployment, and a tragic accident in 2008. He
has made tremendous efforts to recover after his injury. He wants to contribute to his
country. He incurred delinquent debts from the 2005 divorce. He did not attempt to
resolve them. He did not  address his delinquent debts until after the security clearance
process started. He also admitted that he did not have an incentive to deal with the IRS
tax issues. He has just recently addressed the tax issues.
Granted, Applicant could not meet his current expenses after his 2008 accident.
He did make an effort to pay his current expenses to feed his family. He exhausted his
savings. However, he chose to ignore the earlier delinquent debts. He also decided not
to address or resolve the delinquent debts until he was under the threat of losing his
security clearance. I do not find that he has met his burden of proof with respect to the
financial considerations security concerns. Any doubts must be resolved in favor of the
Government. 
As to personal conduct, the allegations of falsifications were successfully refuted.
Applicant produced information that he did not believe he was terminated from WBB in
2005. Thus, on his security clearance application and subsequent interviews, he
believed he had nothing to disclose. This same reasoning applies to the CPS child
sexual allegation. Applicant has refuted the allegation. He was credible in his denial of
the damage to the rental units. 
 
Formal Findings
Formal findings for or against Applicant on the allegations set forth in the SOR,
as required by section E3.1.25 of Enclosure 3 of the Directive, are:
Paragraph 1, Guideline F: AGAINST APPLICANT
Subparagraphs 1.a-1.r: Against Applicant
Paragraph 2, Guideline E: FOR APPLICANT
Subparagraphs 2.a-2.g: For Applicant
13
Conclusion
In light of all of the circumstances presented by the record in this case, it is not
clearly consistent with the national interest to grant Applicant a security clearance.
Clearance is denied. 
                                                     
NOREEN A. LYNCH.
Administrative Judge