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DEPARTMENT OF DEFENSE 
DEFENSE OFFICE OF HEARINGS AND APPEALS 
           
             
 
 
In the matter of: ) 
 ) 
 [Redacted] )  ISCR Case No. 12-04992 
 ) 
Applicant for Security Clearance ) 
 
 
Appearances 
 
For Government: Eric H. Borgstrom, Esq., Department Counsel 
For Applicant: Zlatko Hadzismajlovic, Esq. 
 
 
______________ 
 
Decision 
______________ 
 
 
FOREMAN, LeRoy F., Administrative Judge: 
 
This case involves security concerns raised under Guideline B (Foreign 
Influence). Eligibility for access to classified information is granted. 
 
Statement of the Case 
 
Applicant submitted a security clearance application on February 2, 2012. On 
November 26, 2013, the Department of Defense (DOD) sent her a Statement of 
Reasons (SOR) alleging security concerns under Guideline B. The DOD acted under 
Executive Order 10865, Safeguarding Classified Information within Industry (February 
20, 1960), as amended; DOD Directive 5220.6, Defense Industrial Personnel Security 
Clearance Review Program (January 2, 1992), as amended (Directive); and the 
adjudicative guidelines (AG) implemented by DOD on September 1, 2006.  
 
 Applicant received the SOR on December 4, 2013; answered it on December 19, 
2013; and requested a hearing before an administrative judge. Department Counsel 
was ready to proceed on February 13, 2014, and the case was assigned to an 
administrative judge on February 21, 2014. The Defense Office of Hearings and 
 
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Appeals (DOHA) issued a notice of hearing on March 21, 2014, scheduling the hearing 
to be conducted by video teleconference on April 24, 2014.  
 
On April 21, 2014, Applicant requested that the hearing be postponed until May 
30, 2014, or any date thereafter. The hearing was tentatively scheduled for May 30, 
2014, with a view toward combining it with other hearings in the same location. The 
case was reassigned to me on May 20, 2014. On May 27, 2014, DOHA issued a 
second notice of hearing, scheduling the hearing for July 10. 2014. I convened the 
hearing as scheduled. Government Exhibits (GX) 1 and 2 were admitted in evidence 
without objection. Applicant testified, presented the testimony of three witnesses, and 
submitted Applicant’s Exhibits (AX) A through L, which were admitted without objection. 
DOHA received the transcript (Tr.) on July 18, 2014. 
 
Administrative Notice 
 
Department Counsel requested that I take administrative notice of relevant facts 
about the People’s Republic of China (PRC). The request and supporting documents 
are attached to the record as Hearing Exhibits (HX) I. I took administrative notice as 
requested by Department Counsel. The facts administratively noticed are set out below 
in my findings of fact. 
 
 AX L is a report from the U.S. Census Bureau reflecting statistics on the number 
of foreign-born persons from the PRC who have been naturalized as U.S. citizens. 
Rather than admit AX L as an exhibit, I took administrative notice of the information in 
the exhibit, with the consent of both parties. I have administratively noticed that in 2011, 
there were 11.6 million foreign-born residents of the United States, of which about 2.2 
million were from China. In 2012, about 31,868 native-born Chinese citizens were 
naturalized as U.S. citizens.  
 
Findings of Fact 
 
 In her answer to the SOR, Applicant admitted all the allegations. Her admissions 
in her answer and at the hearing are incorporated in my findings of fact.  
 
 Applicant is a 28-year-old engineer employed by a defense contractor since 
December 2008. She has never held a security clearance. 
 
 Applicant was born in the PRC, came to the United States with her parents in 
October 1996, and became a U.S. citizen in March 2005, shortly after attaining the age 
of majority. She has no siblings. She graduated from a U.S. university in July 2008.  
 
Applicant’s parents were highly respected educators in the PRC until they 
became victims of the Cultural Revolution and immigrated to the United States. Her 
father now works as a cook in a restaurant and her mother is a home care attendant. 
(Tr. 38, 46-47.) Applicant’s father became a U.S. citizen in April 2004, and her mother 
became a U.S. citizen in December 2005. (AX C.) 
 
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 Applicant married a native-born U.S. citizen in October 2009. They met in 
college. They have no children. After Applicant and her husband married, they traveled 
to the PRC, along with Applicant’s parents and parents-in-law, to meet Applicant’s 
family members and celebrate the marriage. (Tr. 38, 47-48.) Applicant visited family 
members in the PRC in January 2008, June-July 2008, February 2010, and during the 
Lunar New Year in 2013. (GX 1 at 33-37; Tr. 31-38, 79.) 
 
 In Chinese culture, there is an expectation that Applicant remain in contact with 
family members. She has telephonic contact with her 89-year-old grandfather about 
once a month. He lives with her youngest aunt, who is a secretary in the public 
transportation department. She also has a brief conversation with her aunt when she 
calls her grandfather. Her conversations with her grandfather are short, not more than 
three minutes, and are intended to “lift his spirit up a little bit,” because he is in 
extremely poor health. Applicant asks her grandfather about his health, and he asks her 
when she will have children. (Tr. 61-62.)  
 
Applicant has contact with her other two aunts in the PRC, who are both retired, 
about once a year. (GX 2 at 11.) She exchanges text messages with three of her 
cousins in the PRC about once a month, using a “group chat” application. One of these 
cousins is a U.S. citizen living in the PRC, who owns a restaurant. One cousin is a 
music teacher in an elementary school, and one is a clerk in the police department. 
Their conversations involve sharing baby pictures, asking about the price of electronics 
in the United States, and World Cup soccer. Applicant has contact about once a year 
with three other cousins in the PRC. One is an owner of a paper company, one is an 
elementary school teacher, and one is unemployed. (GX 2 at 11.) Her six cousins know 
that she is an engineer, but they don’t know that she works for a defense contractor, 
because they don’t discuss work. (Tr. 62-64.) However, Applicant has a Linked-In page 
that identifies her employer. (Tr. 78.) 
 
Occasionally, Applicant’s family members in the PRC ask her and her husband to 
buy luxury goods that are less expensive in the United States, such as tablets, cell 
phones, cameras, and purses, and they usually comply with the requests. (Tr. 31-32, 
63.) Applicant talks to her family members in Mandarin Chinese, which her husband 
does not understand. However, her husband has a translation application on his phone, 
which enables him to follow the conversation and make occasional comments. (Tr. 35.) 
 
 Applicant also has two paternal aunts and one paternal uncle who are citizens 
and residents of the United States. (Tr. 85.) One of her paternal aunts has held a 
security clearance for many years. (AX E.) 
 
Applicant’s father-in-law and mother-in-law are native-born U.S. citizens. Her 
father-in-law worked as an engineer for a defense contractor before attending law 
school and held a security clearance. He is now a senior vice-president and chief legal 
officer for a real estate development and investment management company. He 
considers Applicant and her husband frugal and financially careful. He describes 
Applicant as appearing “meek and timid, but underneath that sweet exterior is a steel 
 
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backbone with a strong moral compass.” He and his wife consider Applicant as one of 
their daughters. He testified that he believes Applicant would react to any effort at 
foreign influence with “a sense of outrage,” and that she would immediate report it to her 
husband, her supervisor and appropriate security authorities. (Tr. 50-52; AX D.) 
 
Applicant testified that she feels closer to her friends in the United States and her 
husband’s family, because she has more in common with them. (Tr. 66-67.) A close 
friend that she met in college nine years ago, a native-born U.S. citizen, rents a room in 
their house. He testified that Applicant’s friends are American; she watches American 
programs on the television; and he has seen nothing that would suggest that she would 
chose the interests of the PRC over the United States. (Tr. 90-94.) 
 
 Applicant and her husband work for the same employer and on the same project, 
designing various components for Navy ships. During their off-duty time, they participate 
in an “engineering build” club, composed of coworkers, where they exchange ideas 
about building ship components. Although they discuss work projects, they are not 
compensated. The president of the engineering-build club submitted an affidavit 
attesting to Applicant’s leadership and trustworthiness. (AX K.) 
 
After work, Applicant spends her free time watching television or playing with 
their three cats, and her husband works on his computer. They watch U.S. 
programming rather than Chinese or ethnic programming. (Tr. 39-42.)  
 
Applicant and her husband own their home and are financially secure. (AX F; AX 
G.) They have no property or financial assets in the PRC. (Tr. 82-83.) Applicant voted in 
the last presidential election in 2012 as well as state and local elections. (Tr. 80, 88.) 
 
 Using a four-point rating scale, Applicant’s performance appraisals for 2009 
through 2013 rated her as either meeting performance requirements (numerical score of 
2) or exceeding performance requirements (numerical score of 3). Her narrative reports 
described her as a fast learner, a team player, highly motivated, intuitive, versatile, and 
enthusiastic. (AX H.) She received a letter of appreciation from the Navy program 
manager for her exemplary dedication, commitment, and professionalism. (AX I.) She 
placed first in an engineering competition in February 2011. She was recognized as an 
employee of the week in December 2012 and employee of the month in June 2013 and 
January 2014. (AX J.) 
 
 The PRC has an authoritarian government dominated by the Communist Party. 
The United States and the PRC have been rivals since the Cold War. Despite political 
disagreements, the United States and the PRC have become major economic and 
trading partners. The PRC is pursuing a long-term, comprehensive modernization of its 
military forces to improve its capacity to fight short-duration, high-intensity regional 
conflicts as well as missions beyond its coastal borders. The PRC aggressively targets 
sensitive and protected U.S. technology and military information, using worldwide 
intelligence operations. It is one of the world’s most aggressive practitioners of 
economic espionage. It uses multiple government entities to acquire restricted U.S. 
 
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technologies and it encourages and rewards private individuals who obtain technology 
on its behalf. It is one of the leading destinations for illegal exports of restricted U.S. 
technology. 
 
 The PRC usually gathers intelligence by appealing to an individual’s desire to 
help the PRC. U.S. citizens of Chinese ancestry with family ties to the PRC are prime 
intelligence targets. The Department of Justice has successfully prosecuted numerous 
naturalized U.S citizens from the PRC for actual or attempted espionage and illegal 
export of sensitive technology to the PRC. 
 
 In recent years, the United States has sought a “healthy, stable, and reliable 
military-to-military relationship” with the PRC, as part of a “shared vision for a positive, 
cooperative, and comprehensive U.S.-China relationship.” U.S. Department of Defense, 
Office of the Secretary of Defense, Annual Report to Congress, Military and Security 
Developments Involving the People’s Republic of China 2013, at 1 (Executive 
Summary), Attachment II to HX I.1 Pursuant to this goal, the United States and the PRC 
have engaged in numerous military-to-military exchanges and conducted joint military 
exercises in counter-piracy, humanitarian and disaster relief, and search and rescue 
operations. Id. at 69-73. 
 
 The PRC has a poor human rights record. It suppresses political dissent, and it 
practices arbitrary arrest and detention, forced confessions, torture, and mistreatment of 
prisoners. Repression and coercion is focused primarily on organizations and 
individuals involved in rights advocacy and public interest issues. Efforts to silence and 
intimidate political activists are common. U.S. Department of State, Country Reports on 
Human Rights Practices for 2012: China (includes Tibet, Hong Kong, and Macau) at 1 
(Executive Summary), Attachment I to HX I. Travelers to the PRC can expect to be 
placed under surveillance, with their hotel rooms, telephones, and fax machines 
monitored and personal possessions, including computers, searched without their 
knowledge or consent. 
 
The PRC does not recognize dual nationality. PRC nationals who have settled 
abroad and been naturalized as foreign citizens lose their PRC citizenship. 
 
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 
                                                          
1 Pinpoint citations to these administratively-noticed facts are included in this decision because the basis 
for my administrative notice is based on the documents included in Department Counsel’s request for 
administrative notice, but these facts were not specifically mentioned in the request. 
 
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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. 
 
 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).  
 
 
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Analysis 
 
Guideline B, Foreign Influence 
 
 The SOR alleges that Applicant’s grandfather is a citizen and resident of China 
(SOR ¶ 1.a) and that her three aunts and five cousins are citizens and residents of 
China (SOR ¶ 1.b).  
 
The security concern under this guideline is set out in AG ¶ 6 as follows:  
 
Foreign contacts and interests may be a security concern if the individual 
has divided loyalties or foreign financial interests, may be manipulated or 
induced to help a foreign person, group, organization, or government in a 
way that is not in U.S. interests, or is vulnerable to pressure or coercion by 
any foreign interest. Adjudication under this Guideline can and should 
consider the identity of the foreign country in which the foreign contact or 
financial interest is located, including, but not limited to, such 
considerations as whether the foreign country is known to target United 
States citizens to obtain protected information and/or is associated with a 
risk of terrorism. 
 
 Two disqualifying conditions under this guideline are relevant to this case: 
 
AG ¶ 7(a): (contact with a foreign family member, business or professional 
associate, friend, or other person who is a citizen of or resident in a 
foreign country if that contact creates a heightened risk of foreign 
exploitation, inducement, manipulation, pressure, or coercion); and 
 
 AG ¶ 7(b): (connections to a foreign person, group, government, or 
country that create a potential conflict of interest between the individual’s 
obligation to protect sensitive information or technology and the 
individual’s desire to help a foreign person, group, or country by providing 
that information).  
 
 AG ¶ 7(a) requires substantial evidence of a “heightened risk.” The “heightened 
risk” required to raise one of these disqualifying conditions is a relatively low standard. 
“Heightened risk” denotes a risk greater than the normal risk inherent in having a family 
member living under a foreign government. The PRC’s aggressive program of targeting 
U.S. technology and military information establishes the “heightened risk” in AG ¶ 7(a) 
and the potential conflict of interest in AG ¶ 7(b). 
 
 Three mitigating conditions under this guideline are potentially relevant: 
 
AG ¶ 8(a): the nature of the relationships with foreign persons, the country 
in which these persons are located, or the positions or activities of those 
persons in that country are such that it is unlikely the individual will be 
 
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placed in a position of having to choose between the interests of a foreign 
individual, group, organization, or government and the interests of the U.S; 
 
AG ¶ 8(b): there is no conflict of interest, either because the individual’s 
sense of loyalty or obligation to the foreign person, group, government, or 
country is so minimal, or the individual has such deep and longstanding 
relationships and loyalties in the U.S., that the individual can be expected 
to resolve any conflict of interest in favor of the U.S. interest; and 
 
AG ¶ 8(c): contact or communication with foreign citizens is so casual and 
infrequent that there is little likelihood that it could create a risk for foreign 
influence or exploitation. 
 
 Guideline B is not limited to countries hostile to the United States. “The United 
States has a compelling interest in protecting and safeguarding classified information 
from any person, organization, or country that is not authorized to have access to it, 
regardless of whether that person, organization, or country has interests inimical to 
those of the United States.” ISCR Case No. 02-11570 at 5 (App. Bd. May 19, 2004).  
 
 Furthermore, “even friendly nations can have profound disagreements with the 
United States over matters they view as important to their vital interests or national 
security.” ISCR Case No. 00-0317, 2002 DOHA LEXIS 83 at **15-16 (App. Bd. Mar. 29, 
2002). Finally, we know friendly nations have engaged in espionage against the United 
States, especially in the economic, scientific, and technical fields. Nevertheless, the 
nature of a nation’s government, its relationship with the United States, and its human 
rights record are relevant in assessing the likelihood that an applicant’s family members 
are vulnerable to government coercion. The risk of coercion, persuasion, or duress is 
significantly greater if the foreign country has an authoritarian government, a family 
member is associated with or dependent upon the government, or the country is known 
to conduct intelligence operations against the United States. In considering the nature of 
the government, an administrative judge must also consider any terrorist activity in the 
country at issue. See generally ISCR Case No. 02-26130 at 3 (App. Bd. Dec. 7, 2006) 
(reversing decision to grant clearance where administrative judge did not consider 
terrorist activity in area where family members resided). 
 
An applicant with foreign family ties to a country that is hostile to the United 
States has a very heavy burden of persuasion to show that neither he nor his family 
members are subject to influence by that country. ISCR Case No. 11-01888 (App. Bd. 
Jun. 1, 2012), citing ISCR Case No. 07-00029 (App. Bd. Dec. 7, 2007). The totality of 
an applicant’s family ties to a foreign country as well as each individual family tie must 
be considered. ISCR Case No. 01-22693 at 7 (App. Bd. Sep. 22, 2003).  
 
 In several Guideline B cases involving the PRC that were decided shortly after 
the current adjudicative guidelines were implemented, the Appeal Board applied the 
heightened standard for mitigation applicable to countries hostile to the United States. 
See, e.g., ISCR Case No. 06-24575 (App. Bd. Nov. 9, 2007) (“very heavy burden”); 
 
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ISCR Case No. 03-09053 (App. Bd. Mar. 9, 2006) (“heavy burden”).2 These early 
decisions lumped the PRC is the same category of hostile countries as Iran. However, 
the description of a country as “hostile” is not immutable and eternal. Several former 
enemies of the United States are now among our closest allies. Recent U.S. policies 
regarding trade and military cooperation with the PRC raise the question whether the 
PRC and Iran should be in the same category for the purpose of Guideline B mitigation.  
 
However, the Appeal Board appears to have adhered to the heightened standard 
for mitigation in cases involving the PRC. See, e.g., ISCR Case No. 12-04780 (App. Bd. 
Nov. 13, 2013), 2013 DOHA Lexis 403 at *2 (“heavy burden” because of Applicant’s 
family ties in PRC). Accordingly, I have applied the heightened standard for mitigation to 
this case. I have also applied the recent Appeal Board guidance in ISCR Case No. 09-
01652 (App. Bd. Aug. 8, 2011): “Once a concern arises regarding an Applicant’s 
security clearance eligibility, there is a strong presumption against the grant or 
maintenance of a security clearance.” 
 
 Applying the foregoing considerations, I conclude that AG ¶ 8(a) is not 
established. The PRC’s aggressive espionage targeting the United States precludes a 
finding that a conflict of interest is unlikely. 
 
 I conclude that AG ¶ 8(b) is established. Applicant’s sense of obligation to her 
foreign family members is not “minimal.” However, Applicant’s deep and longstanding 
relationships and loyalties in the United States are sufficient to satisfy her “very heavy 
burden” of showing that she will resolve any conflict of interest in favor of the U.S. 
interest. Applicant has lived in the United States since childhood. Her career, friends, 
and interests are in the United States. She feels that she has nothing in common with 
her foreign family members. Her spouse, parents, two aunts, and an uncle are citizens 
and residents of the United States. She is very close to her father-in-law and mother-in-
law, who are citizens and residents of the United States. Her father-in-law believes that 
she would react with “outrage” to an attempt to exploit her foreign family connections.  
 
 AG ¶ 8(c) is partially established. There is a rebuttable presumption that contacts 
with an immediate family member in a foreign country are not casual. ISCR Case No. 
00-0484 at 5 (App. Bd. Feb. 1, 2002). This presumption does not apply to her 
grandfather, aunts, and cousins, who are not “immediate family members.”3 Even 
though it does not apply to her grandfather, the evidence shows that she has a strong 
sense of obligation to him. This mitigating condition is established for her light-hearted 
electronic exchanges with her cousins and her polite contacts with her aunts in the 
PRC. It is not established for her grandfather. 
                                                          
2 It is unclear whether the Appeal Board intended to distinguish between a “very heavy burden” and a 
“heavy burden.” 
 
3 The current adjudicative guidelines do not define “immediate family members.” However, the previous 
guidelines defined them as “spouse, father, mother, sons, daughters, brothers, sisters.” Directive ¶ 
E2.A2.1.3.1. Her security clearance application did not ask her to include grandparents, aunts, uncles, 
and cousins in the listing of relatives. GX 1 at 26-27.  
 
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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 B in my whole-person 
analysis. Some of the factors in AG ¶ 2(a) were addressed under that guideline, but 
some warrant additional comment. Applicant came to the United States as a young girl 
and has adopted the ideals and values of the United States. She has become totally 
immersed in the cultural, educational, and political environment of the United States. 
While she feels a sense of obligation to her grandfather, she feels that she has nothing 
in common with her extended family members in the PRC. She was candid, sincere, 
and credible at the hearing.  
 
 After weighing the disqualifying and mitigating conditions under Guideline B, and 
evaluating all the evidence in the context of the whole person, I conclude Applicant has 
mitigated the security concerns based on foreign influence. Accordingly, I conclude she 
has carried her heavy burden of showing that it is clearly consistent with the national 
interest to grant her eligibility for access to classified information. 
 
Formal Findings 
 
 I make the following formal findings on the allegations in the SOR: 
 
 Paragraph 1, Guideline B (Foreign Influence):  FOR APPLICANT 
 
  Subparagraphs 1.a-1.b:    For Applicant 
 
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Conclusion 
 
 I conclude that it is clearly consistent with the national interest to grant Applicant 
eligibility for a security clearance. Eligibility for access to classified information is 
granted. 
 
 
 
 
LeRoy F. Foreman 
Administrative Judge