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                              DEPARTMENT OF DEFENSE
               DEFENSE OFFICE OF HEARINGS AND APPEALS
          
            
In the matter of: )
)
)       ISCR Case No. 11-11232
)
)
Applicant for Security Clearance )
Appearances
For Government: Braden M. Murphy, Esquire, Department Counsel
For Applicant: Pro se
______________
Decision
______________
WHITE, David M., Administrative Judge:
Applicant was suspended several times before termination of his previous
Federal employment after his arrest for smuggling in 2005. He denied the arrest and
omitted the resulting incarceration on his security clearance application. He admittedly
owes about $40,000 in delinquent debts and fines. The evidence is insufficient to
mitigate resulting security concerns. Based upon a review of the pleadings, testimony,
and exhibits, eligibility for access to classified information is denied. 
Statement of the Case
Applicant submitted a security clearance application (SF-86) on April 5, 2011. On
May 2, 2013, the Department of Defense issued a Statement of Reasons (SOR) to
Applicant, detailing security concerns under Guideline E (Personal Conduct), Guideline
J (Criminal Conduct), and Guideline F (Financial Considerations). 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 for Determining Eligibility for
Access to Classified Information, effective within the Department of Defense after
September 1, 2006. 
GE 6 was admitted for limited purposes, as discussed at Tr. 32-34, 36-37, 95-97.1
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Applicant answered the SOR in writing on May 22, 2013 (AR), and requested a
hearing before an administrative judge. Department Counsel was prepared to proceed
on September 27, 2013. The case was assigned to me on October 21, 2013. During
initial scheduling discussions, I granted Applicant’s request to delay his hearing from my
intended date of December 9, 2013, until January 14, 2014, due to family medical
issues. The Defense Office of Hearings and Appeals (DOHA) issued a Notice of Video
Teleconference Hearing for that date on November 27, 2013. On January 3, 2014, I
granted Applicant’s second request for a continuance because he secured a 30-day
engagement to sail onboard a Military Sealift Command ship. On January 9, 2014,
DOHA issued an Amended Notice of Video Teleconference Hearing, and I convened
the hearing, as rescheduled, on February 12, 2014. I granted Department Counsel’s
request to amend SOR ¶¶ 1.g and 1.i, in order to correctly reflect the year of Applicant’s
arrest by Canadian authorities, to which Applicant did not object. The Government
offered Exhibits (GE) 1 through 11, which were admitted without objection.   Applicant1
offered Exhibits (AE) A through E, which were also admitted without objection, and
testified on his own behalf. DOHA received the transcript of the hearing (Tr.) on
February 24, 2014.
Findings of Fact
Applicant is a 57-year-old potential employee of a defense contractor, and a
former employee of U.S. Customs and Border Protection (CBP) in the Department of
Homeland Security. He is married for the second time, and has no children. His wife is a
Canadian citizen who was born in Southeast Asia. He has earned two bachelor’s
degrees, and taken some post-graduate courses. He has no military service, but has
been eligible for a security clearance during his previous Government employment. He
is a permanent resident of Canada, where he has lived since late 1997. (GE 1; GE 11 at
2; Tr. 7-10, 55, 107-108.) 
In his response to the SOR, Applicant admitted the truth of SOR ¶¶ 1.c through
1.h, 2.a, and 3.a through 3.e. He denied SOR ¶¶ 1.a, 1.b, 1.i, and 2.b, with brief
explanations. Applicant’s admissions, including his November 8, 2012 affidavit to DOHA
(GE 4), are incorporated in the following findings.
Applicant worked as a U.S. Customs and Border Protection Inspector from 1986
to 2005. From September 1997 to June 2005, he was stationed at an international
airport and a border crossing in Canada. He was arrested by Canadian police for
impaired driving at about 2:30 am on October 30, 1998. He had been driving erratically
after leaving a bar, and his breathalyzer test results of .09 exceeded the .08 limit for
intoxication under Canadian law. The arresting officer reported that Applicant was
uncooperative, had to be restrained, and claimed that he had diplomatic immunity as a
U.S. Customs Officer. Canadian authorities declined prosecution, and Applicant
received only a 24-hour prohibition from driving. In June 1999, Applicant’s agency
received an anonymous letter stating that he had used his diplomatic passport to avoid
W ith 200 cigarettes per carton the total involved 269,800 cigarettes. The total federal and provincial taxes2
evaded was $73,941 (Canadian). (GE 7 Group 5 pages 10-11 of 15.)
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being charged for driving while intoxicated. After an investigation, his agency’s
Disciplinary Review Board proposed a 30-day suspension for charges of Misuse of
Position, Failure to Report Arrest, and Consuming Alcohol While in Uniform. On
September 30, 2003, after a hearing during which Applicant denied the charges, the
deciding agency official sustained only the Misuse of Position and Failure to Report
Arrest charges and mitigated the penalty to a five-day suspension. Applicant appealed
under union arbitration provisions. Following a hearing on December 1, 2004, the
arbitrator found that the agency proved the Failure to Report Arrest charge, but failed to
prove Misuse of Position by preponderant evidence. He further found that the imposed
discipline was not “timely” and “prompt,” thereby violating the union bargaining
agreement. He accordingly determined that the five-day suspension was not
reasonable, entitling Applicant to back pay, but that a letter of reprimand was
appropriate. Despite being invited to do so, Applicant offered no authority in support of
his assertion that the arbitration results required that his disciplinary action and the
underlying incident be removed from his personnel records, and could not be
subsequently considered in connection with his eligibility for a security clearance. (AR;
GE 4 at 3; GE 9 at 1-5; AE A; Tr. 39-40, 43-45, 59-64.)  
Although Applicant denied the SOR allegation and did not recall it during his
hearing testimony, the Government proved that he was suspended for 14 days by a
letter dated September 27, 2004, for Unprofessional Conduct. These charges involved
two separate incidents in May 2004, during which Applicant was on inspector duty at the
border and made inappropriate advances toward a teenage student and comments of a
sexual nature to a mother in the presence of her seven-year-old daughter. (AR; GE 9 at
6-12; Tr. 64-67.) Applicant also admitted his five-day suspension from duty in October
2004 for Unprofessional Conduct after insulting and falsely accusing two travelers of
lying about their reason for crossing the border during July 2004; and his two-day
suspension in February 2005 for Reporting for Duty Under the Influence of Alcohol. (AR;
GE 9 at 13-23; Tr. 67.) 
On March 11, 2005, Applicant was arrested by Canadian customs agents for
entering Canada with a large number of undeclared cigarettes that he claims were
intended as gifts for his wife’s family in a third country. After an extensive investigation,
he was charged with a number of criminal, customs, and excise offenses. Eventually, he
was convicted on February 9, 2009, of eight counts alleging offenses under the
Canadian Customs Act and the Canadian Excise Act, 2001. The offenses of which he
was convicted covered a total of 54 border crossings during which he illegally smuggled
1,349 cartons  of cigarettes, related false or deceptive statements by failing to declare2
them, and subsequent illegal possession of unstamped tobacco. The time periods
involved ran from July 2003 to March 2005. On June 23, 2009, Applicant was
sentenced to 12 months incarceration and fined $16,993 (Canadian). The judge found
Applicant’s offenses to be aggravated by the “extended period over which they
occurred, the ongoing planning and deliberation required, the amounts involved, the
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absence of any expression of responsibility by [Applicant], and [the judge’s] conclusion
that the offences are aggravated by reason of his position as a U.S. Customs official
with a responsibility to uphold the integrity of the Canada/U.S. Customs regime.” (GE 7
Group 5 page 14 of 15.) Applicant did not appeal this conviction or sentence. He was
released from incarceration on February 22, 2010, after serving eight months and
receiving four months of credit for good time. He has not paid any portion of the fine. He
testified that he is financially unable and has made no effort to do so. (AR; GE 4; GE 7;
AE E; Tr. 67-78.)  
After Applicant’s March 11, 2005 arrest, Canadian government officials
complained to his U.S. Customs and Border Protection supervisors about his conduct.
Applicant’s employment with that agency was terminated “for conduct unbecoming,”
effective June 30, 2005. Applicant appealed this removal action to the Merit Systems
Protection Board, but his appeal was dismissed on January 19, 2006, as untimely filed.
(AR; GE 1 at 15; GE 4; GE 10; Tr. 67.)
Applicant admitted that he falsified material facts in response to several
questions on his April 5, 2011 SF-86 by deliberately denying having been arrested
during the preceding seven years, and failing to disclose his March 2005 arrest or his
2009 conviction and subsequent eight months of incarceration in Canada. His claims of
confusion over whether to report these matters in another country after his employer
reported that his finger prints “came back clean” were unpersuasive given his law
enforcement experience and extensive education. I conclude that these falsifications
and omissions were deliberate and intended to conceal what he knew to be significant
adverse information in connection with his security clearance eligibility. (AR; Tr. 79-90.)
Applicant was interviewed by an Office of Personnel Management (OPM)
investigator on May 10, 2011. The interviewer prepared only an unsworn summary of
the interview, and did not obtain a statement sworn to or adopted by Applicant.
Applicant subsequently declined to adopt the statement when requested to do so in a
DOHA Interrogatory, and declined to adopt it during the hearing. Accordingly, GE 6 was
not admitted as substantive evidence of the truth of the interviewer’s summary.
Applicant admitted that the interview was contentious, although he could not recall
details, and testified that the OPM investigator terminated the interview for the stated
reason that Applicant was being uncooperative. (AR; GE 6; GE 7; Tr. 32-35, 39-42, 90-
101.)   
Applicant admitted that he has made no payments toward, or other arrangements
to resolve, the four delinquent credit card debts totaling $22,186 as alleged in SOR ¶¶
3.a through 3.d. As noted above, his $16,993 (Canadian) fine that was imposed in June
2009 also remains unpaid. Except for a couple brief periods working aboard ships,
Applicant has been unemployed since June 2005 and has been living off the proceeds
of a house he sold in 2005. His wife worked as an early childhood educator until
December 2013, but is no longer employed either. They have about $19,000 in
checking and savings, but Applicant testified that he has no intention of trying to pay or
otherwise resolve these delinquent debts. (AR; GE 1; AE B; AE C; Tr. 45-46 101-107.)
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The second mate on the Military Sealift Command ship in which Applicant
recently served for about 30 days wrote a letter describing him as a sober and reliable
watchstander who is always safety minded and conscientious of his surroundings. The
second mate believes that, in time, Applicant will make a fine deck officer. (AE B.)
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 (DCs) and mitigating conditions (MCs), which are to be used in
evaluating an applicant’s eligibility for access to classified information.
These guidelines are not inflexible rules of law. Instead, recognizing the
complexities of human behavior, these guidelines are applied in conjunction with the
factors listed in AG ¶ 2 describing the adjudicative process. The administrative judge’s
overarching adjudicative goal is a fair, impartial, and commonsense decision. According
to AG ¶¶ 2(a) and 2(c), the entire process is a conscientious scrutiny of applicable
guidelines in the context of a number of variables known as the whole-person concept.
The administrative judge must consider all available, reliable information about the
person, past and present, favorable and unfavorable, in making a decision.
The protection of the national security is the paramount consideration. AG ¶ 2(b)
requires that “[a]ny doubt concerning personnel being considered for access to
classified information will be resolved in favor of the 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, “[t]he applicant is
responsible for presenting witnesses and other evidence to rebut, explain, extenuate, or
mitigate facts admitted by the applicant or proven by Department Counsel, and has the
ultimate burden of persuasion as to obtaining a favorable clearance decision.” Section 7
of Executive Order 10865 provides: “[a]ny determination under this order adverse to an
applicant shall be a determination in terms of the national interest and shall in no sense
be a determination as to the loyalty of the applicant concerned.”
A person applying for access to classified information seeks to enter 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
safeguard classified information. Such decisions entail a certain degree of legally
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permissible extrapolation as to potential, rather than actual, risk of compromise of
classified information.
Analysis
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. Of special interest is any failure to provide truthful
and candid answers during the security clearance process or any other
failure to cooperate with the security clearance process.
The following will normally result in an unfavorable clearance action or
administrative termination of further processing for clearance eligibility:
(a) refusal, or failure without reasonable cause, to undergo
or cooperate with security processing, including but not
limited to meeting with a security investigator for subject
interview, completing security forms or releases, and
cooperation with medical or psychological evaluation;
(b) refusal to provide full, frank and truthful answers to lawful
questions of investigators, security officials, or other official
representatives in connection with a personnel security or
trustworthiness determination.
AG ¶ 16 describes four conditions that could raise a security concern and may be
disqualifying with relation to the allegations in this case:
(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; 
(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;
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(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:
    (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; and
(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.
Applicant’s multiple incidents of unprofessional conduct while on duty as a CBP
inspector, alcohol-related misconduct, failures to report arrests to his CBP supervisors
and on his SF-86, and violations of Canadian Customs and Excise Acts while smuggling
cigarettes on at least 54 different occasions clearly establish significant security
concerns under each of these disqualifying conditions. He also deliberately concealed
his eight months of incarceration when completing his SF-86. He jeopardized his
community and professional standing as a CBP inspector through his extensive
smuggling activities, subjecting him to coercion and duress by those with whom he dealt
in the smuggled goods. His pattern of dishonest and untrustworthy behavior also raises
substantial concerns under the provisions of AG ¶ 15 cited above. Applicant’s conduct
supports a whole-person assessment of questionable judgment, untrustworthiness,
unreliability, lack of candor, and unwillingness to comply with rules and regulations.
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AG ¶ 17 provides conditions that could mitigate security concerns. Four have
potential applicability to the security concerns raised by the facts in this case:
(a) the individual made prompt, good-faith efforts to correct the omission,
concealment, or falsification before being confronted with the facts;
(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
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; and
(e) the individual has taken positive steps to reduce or eliminate
vulnerability to exploitation, manipulation, or duress.
Applicant did not attempt to correct his SF-86 falsifications until confronted with
the facts, so mitigation under MC 17(a) was not shown. His pattern of disruptive,
deceptive, and irresponsible behavior in violation or defiance of expected norms
occurred during his most recent employment in a security-sensitive position, and he
demonstrated no intervening basis to conclude that it does not reflect his current
reliability, trustworthiness, and judgment. Nor did he demonstrate steps to reduce
vulnerability to manipulation or duress by his wife’s foreign family or others with whom
he was involved in smuggling. Thus, mitigation was not established under MC 17(c),
17(d), or 17(e).
Guideline J, Criminal Conduct
AG ¶ 30 expresses the security concern pertaining to criminal conduct: 
Criminal activity creates doubt about a person's judgment, reliability, and
trustworthiness. By its very nature, it calls into question a person's ability
or willingness to comply with laws, rules and regulations.
AG ¶ 31 describes conditions that could raise a security concern and may be
disqualifying. The Criminal Conduct DCs raised by the facts of this case are:
(a) a single serious crime or multiple lesser offenses; and 
(c) allegation or admission of criminal conduct, regardless of whether the
person was formally charged, formally prosecuted or convicted.
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Applicant was convicted of eight counts of Canadian Customs Act and Excise Act
violations involving 54 smuggling incidents between July 2003 and March 2005.
Although not technically violations of the Canadian criminal code, these were illegal acts
punishable by substantial incarceration and fines, and constituted “multiple lesser
offenses.” These occurred while he was employed in a position of trust as a U.S. CBP
inspector. He also admitted to false denials and omissions in response to two questions
on his SF-86, in violation of 18 U.S.C. § 1001. These offenses support security
concerns under the foregoing DCs. 
AG ¶ 32 provides conditions that could mitigate security concerns:
(a) so much time has elapsed since the criminal behavior happened, or it
happened under such unusual circumstances that it is unlikely to recur
and does not cast doubt on the individual's reliability, trustworthiness, or
good judgment;
(b) the person was pressured or coerced into committing the act and those
pressures are no longer present in the person's life;
(c) evidence that the person did not commit the offense; and
(d) there is evidence of successful rehabilitation; including but not limited
to the passage of time without recurrence of criminal activity, remorse or
restitution, job training or higher education, good employment record, or
constructive community involvement.
Applicant’s offenses are numerous, recent, and involve intentional dishonesty on
issues related to positions of trust with the Government. Applicant’s trustworthiness,
judgment, and willingness to comply with laws, rules, and regulations remain in doubt.
He produced no evidence of successful rehabilitation, or that reason now exists to
believe that recurrence of misconduct is unlikely. He accordingly failed to meet his
burden to establish mitigation under any of these MCs.
Guideline F, Financial Considerations
The security concerns under the guideline for financial considerations are set out
in AG ¶ 18, which reads in pertinent part:      
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. 
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The record evidence raises security concerns under two Guideline F DCs, as set
forth in AG ¶ 19: 
(a) inability or unwillingness to satisfy debts; and
(c) a history of not meeting financial obligations. 
Applicant admittedly owes four delinquent credit card debts, totaling over
$22,000, and almost $17,000 (Canadian) in overdue fines. He testified that he cannot
afford to repay these debts, and does not intend to resolve them. These facts raise
substantial security concerns under DCs 19(a) and (c), and shift the burden to Applicant
to rebut, extenuate, or mitigate those concerns.
The guideline includes five conditions in AG ¶ 20 that could mitigate security
concerns arising from Applicant’s financial difficulties:
(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; and
(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.
Applicant’s substantial delinquent debts arose as a consequence of his voluntary
choices, and are ongoing. He offered insufficient evidence from which to conclude that
such disregard of his financial obligations is unlikely to recur, or does not cast doubt on
his current reliability or judgment. He failed to demonstrate substantial mitigation under
MC 20(a). 
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Applicant also offered insufficient evidence to support mitigation under MC 20(b).
He neither showed that his serious indebtedness was caused by circumstances beyond
his control, nor demonstrated responsible action under the circumstances. 
Applicant provided no evidence of financial counseling, and established no clear
indication that his delinquent debts are being resolved or that his financial situation is
under control for the future. He made no effort to establish a good-faith track record of
repayment. Mitigation under MC 20(c) or 20(d) was therefore not shown. He admitted
owing all SOR-alleged debts, so no mitigation exists under MC 20(e).
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 the applicant’s
conduct and all relevant circumstances. The administrative judge should consider the
nine adjudicative process factors listed at AG ¶ 2(a): 
(1) the nature, extent, and seriousness of the conduct; (2) the
circumstances surrounding the conduct, to include knowledgeable
participation; (3) the frequency and recency of the conduct; (4) the
individual’s age and maturity at the time of the conduct; (5) the extent to
which participation is voluntary; (6) the presence or absence of
rehabilitation and other permanent behavioral changes; (7) the motivation
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.   
I considered the potentially disqualifying and mitigating conditions in light of all
pertinent facts and circumstances surrounding this case. Applicant earned multiple
suspensions from his prior Federal employment for misconduct on and off duty, and
was eventually fired after being arrested by Canadian authorities for smuggling while
employed as a U.S. CBP inspector. His substantial delinquent debt resulted from
voluntary choices he made, and he demonstrated no effort to resolve any of it. This
establishes a long and recurring pattern of misconduct, abuse of trust, avoiding
voluntarily incurred commitments, and failure to meet his lawful obligations. 
Applicant is an educated and mature individual. His conduct of security concern
was voluntary, and he offered no reason that he should not be considered accountable
for his decisions and actions. He did not demonstrate a change in personal attitude or
financial circumstances that would support a finding of permanent behavioral change, or
a finding that recurrence of untrustworthiness and questionable judgment is unlikely. His
track record of living beyond his means and willingness to engage in illegal conduct
reveals an ongoing susceptibility to coercion or duress. Overall, the record evidence
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creates substantial doubt as to Applicant’s present eligibility and suitability for a security
clearance.
Formal Findings
Formal findings for or against Applicant on the allegations set forth in the SOR,
as required by ¶ E3.1.25 of Enclosure 3 of the Directive, are:
Paragraph 1, Guideline E: AGAINST APPLICANT
Subparagraph 1.a: Against Applicant
Subparagraph 1.b: Against Applicant
Subparagraph 1.c: Against Applicant
 Subparagraph 1.d: Against Applicant
Subparagraph 1.e: Against Applicant
Subparagraph 1.f: Against Applicant
 Subparagraph 1.g: Against Applicant
Subparagraph 1.h: Against Applicant
Subparagraph 1.i: Against Applicant
Paragraph 2, Guideline J: AGAINST APPLICANT
Subparagraph 2.a: Against Applicant
Subparagraph 2.b: Against Applicant
Paragraph 3, Guideline F: AGAINST APPLICANT
Subparagraph 3.a: Against Applicant
Subparagraph 3.b: Against Applicant
Subparagraph 3.c: Against Applicant
 Subparagraph 3.d: Against Applicant
Subparagraph 3.e: Against Applicant
Conclusion
In light of all of the circumstances presented by the record in this case, it is not
clearly consistent with the national interest to grant Applicant eligibility for a security
clearance. Eligibility for access to classified information is denied.
                                              
DAVID M. WHITE
Administrative Judge