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            DEPARTMENT OF DEFENSE 
DEFENSE OFFICE OF HEARINGS AND APPEALS 
 
 
 
 
In the matter of: ) 
) 
  )   ISCR Case No. 14-03799 
 ) 
Applicant for Security Clearance ) 
 
 
Appearances 
 
For Government: Eric H. Borgstrom, Esq., Department Counsel 
For Applicant: Pro se 
 
 
______________ 
 
Decision 
______________ 
 
 
MATCHINSKI, Elizabeth M., Administrative Judge: 
 
Applicant’s mortgage loan and some other consumer credit accounts became 
delinquent during his divorce. He is not being held liable for any mortgage debt after his 
home loan was foreclosed in December 2014, but he owes approximately $43,608 in credit 
card debt from his divorce, of which $25,319 was past due as of September 2015. 
Applicant has yet to demonstrate a track record of payments toward his delinquent debts. 
Clearance is denied. 
 
Statement of the Case 
 
 On May 20, 2015, the Department of Defense Consolidated Adjudications Facility 
(DOD CAF) issued a Statement of Reasons (SOR) to Applicant, detailing the security 
concerns under Guideline F, Financial Considerations, and explaining why it was unable to 
find it clearly consistent with the national interest to grant or continue security clearance 
eligibility for him. The DOD CAF took the action 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) effective 
within the DOD on September 1, 2006. 
 
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On June 4, 2015, Applicant answered the SOR allegations and requested a hearing 
before an administrative judge from the Defense Office of Hearings and Appeals (DOHA). 
On October 22, 2015, the case was assigned to me to conduct a hearing to determine 
whether it is clearly consistent with the national interest to grant or continue a security 
clearance for him. On November 3, 2015, I scheduled a hearing for December 1, 2015. 
 
I convened the hearing as scheduled. Five Government exhibits (GEs 1-5) and two 
Applicant exhibits (AEs A-B) were admitted into evidence without objection. Applicant 
testified on his behalf, as reflected in a transcript (Tr.) received on December 9, 2015. 
During the hearing, Department Counsel stipulated that Applicant was not legally liable for 
the credit card debt in SOR ¶ 1.c. 
 
I held the record open until January 4, 2016, for post-hearing submissions from 
Applicant. No documents were received by the deadline, so the record closed on January 
4, 2016. 
 
Summary of SOR Allegations 
 
 The SOR alleges under Guideline F that, as of May 20, 2015, Applicant’s mortgage 
loan was $3,696 past due with a balance of $202,543 (SOR ¶ 1.a). Additionally, he was 
delinquent on three consumer credit card accounts with balances of $12,875 (SOR ¶ 1.b), 
$9,673 (SOR ¶ 1.c), and $18,427 (SOR ¶ 1.e), and he had filed for a Chapter 13 
bankruptcy in February 2014 that was dismissed in April 2014 (SOR ¶ 1.d). When he 
answered the SOR, Applicant admitted the debts and bankruptcy filing. He explained that 
his home loan had been foreclosed and he planned to refile for bankruptcy to address the 
credit card debts. 
 
Findings of Fact 
 
 After considering the pleadings, exhibits, and transcript, I make the following 
findings of fact. 
 
Applicant is a 53-year-old high school graduate who served in the military from June 
1982 until October 2003, when he retired with an honorable discharge. (GE 1; Tr. 18.) His 
monthly military retirement income is $900. (Tr. 19.) Applicant has worked for a defense 
contractor since November 2003, and he has held a secret security clearance throughout 
his employment. (GEs 1, 4; Tr. 19, 21.) He is paid an hourly rate of approximately $30. (Tr. 
20.) 
 
Applicant and his ex-wife married in September 1998. (GE 1; Tr. 22.) In November 
2004, Applicant and his ex-wife bought a home. He took on a 30-year mortgage, to be 
repaid at $1,820 per month. (GE 3.) His ex-wife paid the bills during their marriage (Tr. 30), 
and available credit records show that his debts were paid on time through 2012. (GE 3.) 
 
In October 2012, Applicant’s ex-wife filed for divorce. (AE B.) Applicant and his ex-
wife formally separated in November 2012, although they continued to cohabitate until their 
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divorce was final in July 2013. (GE 1; Tr. 22.) Applicant was required to pay his ex-wife, 
who was unemployed, $200 a week after they separated. (Tr. 23, 25.) They maintained 
their joint bank account pending their divorce into which Applicant’s pay was deposited. 
According to Applicant, his ex-wife depleted the funds in their account, leaving him with 
little to pay their bills. After paying utilities and other household expenses, he could not pay 
his mortgage or some credit card debts. (Tr. 28.)  
 
On May 14, 2013, Applicant completed and certified to the accuracy of a 
Questionnaire for National Security Positions (SF 86) to renew his security clearance 
eligibility. In response to inquiries into any delinquencies involving routine accounts, 
Applicant listed four credit card debts of $1,573 (SOR ¶ 1.b), $1,446 (SOR ¶ 1.e), $7,146 
(not alleged in the SOR), and $280 (not alleged in the SOR). He explained that he was 
going through a divorce and his finances were very tight. (GE 1.) 
 
As of May 2013, Applicant was reportedly $10,921 past due on his mortgage loan 
(SOR ¶ 1.a). His credit card identified in SOR ¶ 1.b was $1,304 past due. His credit card 
account in SOR ¶ 1.e had been closed by the credit grantor for nonpayment since 
December 2012. The account was past due $1,764 with a reported balance of $18,427. 
(GE 3.) Some of the debt on that account was for his ex-wife’s divorce attorney. (Tr. 67.) 
His credit record also included a past-due retail charge account with a balance of $11,455 
(not alleged in the SOR), which was $1,043 past due. Timely payments were being made 
on a credit card balance of $8,942 (SOR ¶ 1.c), on which Applicant was an authorized 
user; on a joint auto loan; and on two revolving charge accounts. (GE 3.) 
 
On June 4, 2013, Applicant was interviewed by an authorized investigator for the 
Office of Personnel Management (OPM) about his finances. Applicant attributed the past-
due balances listed on his SF 86 to his ex-wife’s spending all their money after they 
separated. He added that he was in the process of establishing repayment plans for the 
debts. When asked about unreported delinquencies that were on his credit record, 
Applicant acknowledged that he was past due on his mortgage loan and on a retail charge 
account with an $11,455 balance. He had contacted a debt resolution firm and was 
currently reviewing his options for resolving his financial issues. (GE 4.) 
 
Applicant and his ex-wife were granted a divorce in July 2013. Under their divorce 
settlement Applicant is required to pay $600 in alimony per week for the next seven years 
to his ex-wife. Applicant has grounds to modify the alimony agreement if his ex-wife, who 
has no income, earns more than $400 per week. His alimony obligation will terminate in 
seven years unless either Applicant or his ex-wife die in the interim or she cohabits with a 
male not related to her. Applicant retained possession of his automobile and of the marital 
home. Applicant was solely responsible for the mortgage, taxes, insurance, and 
maintenance of the property.1 His ex-wife was awarded half of his 401(k) and also his 
pension benefit as valued at the time of their divorce. Applicant retained his military 
pension free of any claim by his ex-wife. In addition to the mortgage (SOR ¶ 1.a), Applicant 
                                                 
1 Applicant’s ex-wife vacated the marital home around September 2013. Applicant covered $300 of her moving 
expenses. (Tr. 70.) 
 
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assumed sole liability for repaying the debts in SOR ¶ 1.b (reported at $8,000), SOR ¶ 1.e 
(reported at $10,000), and four debts not alleged in the SOR with balances of $781, 
$11,577, $7,000, and $374. His spouse was financially liable for the credit card debt 
(reported at $8,486) in SOR ¶ 1.c as well as two other credit card debts.2 (AE B.) 
 
Applicant made no payments on the debt with a claimed $781 balance, and in June 
2013, the account was sold. As of September 2015, the past-due balance was $2,810. In 
September 2013, the debt in SOR ¶ 1.b was placed for collection for $12,875. He stopped 
paying on the debt in SOR ¶ 1.e in February 2014. (GE 5.) 
 
Sometime in 2013, Applicant borrowed $25,000 from his 401(k). Some of the loan 
went toward past-due debts. His ex-wife took half of the 401(k) funds immediately because 
she had been awarded half of the balance of his 401(k) in their divorce. (Tr. 56.) 
 
On February 17, 2014, Applicant filed a Chapter 13 bankruptcy petition to address 
his delinquent credit card debt. (Tr. 32, 34.) He paid $400 to his bankruptcy attorney for the 
filing. (Tr. 31.) Because of issues involving Applicant’s mortgage, the bankruptcy was 
dismissed in April 2014 before any plan could be confirmed. (GEs 2, 5; Tr. 31, 34.) 
 
As of May 2014, Applicant was past due $3,696 on his mortgage. (GE 2.) In 
December 2014, his lender foreclosed on his home for nonpayment since November 2012. 
(GE 5; Tr. 24.) After losing his home, Applicant began paying a bankruptcy attorney $50 
per month toward a retainer fee of $3,000 with the intent of refiling for bankruptcy at some 
future date. (Tr. 32-33.) 
 
By September 2015, Applicant had made no progress toward resolving the credit 
card debts in SOR ¶ 1.b ($12,875 in collection) or SOR ¶ 1.e ($17,364 balance). When 
asked at his hearing to explain his lack of progress toward addressing his delinquencies, 
Applicant responded, “I was just maybe being careless.” (Tr. 55.) Applicant also reportedly 
owed past-due balances of $2,810 (from $781 on divorce papers) and $9,502 (from $7,000 
on divorce papers) on accounts not included in the SOR.3 A $1,057 credit card delinquency 
from March 2013 not covered in his divorce had been placed for collection in March 2014. 
(GE 5.) The account on which he was an authorized user and his ex-wife’s responsibility 
(SOR ¶ 1.c) was charged off for $9,818 in July 2014. The balance on his home loan was 
reportedly zero after the foreclosure. (GE 5.) Applicant has received no paperwork from the 
lender since the foreclosure. (Tr. 26, 64.)  
 
                                                 
2 The divorce settlement did not include the $7,146 debt listed on his SF 86. That account was reported as 
having a zero balance on his May 2013 credit report after the account was transferred. (GEs 2, 3, 5.) 
 
3 The $11,455 retail credit card debt included in his divorce paperwork was reported by Equifax as having a 
zero balance as of March 2014 after being included in a Chapter 13 bankruptcy. It does not appear on his 
September 2015 credit report, so the lender may have written off the debt. At his hearing, Applicant initially 
testified that he or his ex-wife “maybe paid that one off.” (Tr. 74.) After being shown his credit record, he 
indicated that the debt had not been satisfied. (Tr. 76-77.) Additionally, Applicant admitted that he had not paid 
the $7,000 credit card debt (not alleged in the SOR), which had accrued to $9,502. (Tr. 79.) 
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With the intent of rehabilitating his credit, Applicant applied for a $33,000 loan from 
his 401(k) on November 28, 2015. (Tr. 35.) Available records show a processing date of 
December 1, 2015. Repayment term is $137.56 per week from January 4, 2016, to 
December 21, 2020. (AE A.) Applicant is still repaying his 2013 loan from his 401(k) at 
about $60 a week. He has three more years of payments before that loan is satisfied. (Tr. 
60.) 
 
Applicant works about 50 hours a week when overtime is available. His take-home 
pay increases from $400 to $600 a week when he works overtime. (Tr. 45.) Over half of his 
paycheck is paid in alimony to his ex-wife. To Applicant’s knowledge, she is still 
unemployed. (Tr. 42-43.) Applicant estimated that he has about “a couple hundred” in 
discretionary funds available after he pays his recurring expenses. It does not include the 
$550 in repayment of the 401(k) loan that was yet to be disbursed as of his hearing. (Tr. 
61.) 
 
Applicant paid off his car loan in November 2013. (GE 5; Tr. 42, 66.) As of 
December 2015, Applicant had $800 on deposit in his checking account. (Tr. 42.) Applicant 
still owes his divorce attorney “roughly $2,000” of the attorney’s $3,000 fee. (Tr. 43.) 
Applicant had not had any financial counseling. He has not opened any new credit cards 
since 2013. (Tr. 93.) 
 
As of December 2015, Applicant had not yet filed his federal or state income tax 
returns for tax year 2014 because he could not find his W-2 for his military retirement 
income. He requested the missing W-2 information in August 2015 and was given an 
extension to file to October 2015. He does not know whether he owes taxes for 2014. He 
owes federal taxes of approximately $1,000 for tax year 2013. Occasionally he sends $10 
or $20 to the Internal Revenue Service (IRS) for his back taxes. He has sent no payment to 
the IRS since June or July 2015. (Tr. 47-49.) 
 
Policies 
 
The U.S. Supreme Court has recognized the substantial discretion the Executive 
Branch has in regulating access to information pertaining to national security,  emphasizing 
that “no one has a ‘right’ to a security clearance.” Department of the Navy v. Egan, 484 
U.S. 518, 528 (1988). When evaluating an applicant’s suitability for a security clearance, 
the administrative judge must consider the adjudicative guidelines. In addition to brief 
introductory explanations for each guideline, the adjudicative guidelines list potentially 
disqualifying conditions and mitigating conditions, which are required to be considered 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 the adjudicative 
process. The administrative judge’s overall adjudicative goal is a fair, impartial, and 
commonsense decision. According to AG ¶ 2(c), the entire process is a conscientious 
scrutiny 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. 
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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. Under Directive ¶ E3.1.14, the Government must present evidence 
to establish controverted facts alleged in the SOR. Under Directive ¶ E3.1.15, the 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 applicant 
has the ultimate burden of persuasion to obtain a favorable security decision. 
 
A person who seeks access to classified information enters 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 
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. 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.” See also EO 
12968, Section 3.1(b) (listing multiple prerequisites for access to classified or sensitive 
information). 
 
Analysis 
 
Guideline F, Financial Considerations 
 
 The security concerns about financial considerations are set forth in AG ¶ 18: 
 
Failure or inability to live within one’s means, satisfy debts, and meet  
financial obligations may indicate poor self-control, lack of judgment, or 
unwillingness to abide by rules and regulations, all of which can raise 
questions about an individual’s reliability, trustworthiness and ability to 
protect classified information. An individual who is financially overextended is 
at risk of having to engage in illegal acts to generate funds. 
 
 Applicant stopped paying his mortgage and some credit cards after he and his ex-
wife separated in November 2012. As of May 2013, Applicant was past due on his 
mortgage and on the credit cards in SOR ¶¶ 1.b and 1.e. The debt in SOR ¶ 1.c was 
charged off for $9,818 in July 2014, but Applicant was only an authorized user on the 
account. His ex-wife was solely legally liable for repayment of that debt after their divorce. 
Applicant is legally liable for repayment of debt balances beyond those alleged in the SOR. 
As of May 2013, his revolving charge account with a retailer was $1,043 past due on a 
balance of $11,455. Around June 2013, another retailer charged off a $2,810 balance. 
Another credit card debt of $1,057 was placed for collection in March 2014. Around 
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October 2013, he stopped paying on a credit card debt that has accrued to $9,502 as of 
August 2015. Applicant filed a Chapter 13 bankruptcy petition in February 2014 (SOR ¶ 
1.d) to address his delinquent credit card debt, but it was dismissed in April 2014 without a 
plan being filed. 
 
 Applicant reportedly owed nothing on the mortgage after the foreclosure of his home 
in December 2014. As of September 2015, the $11,455 revolving charge debt (not alleged 
in the SOR) was no longer on his credit record. However, Applicant admits that the debt 
has not been paid. Equifax was reporting past-due balances of $12,875 on SOR ¶ 1.b, 
$17,364 on SOR ¶ 1.e, and $13,369 on three past-due accounts not included in the SOR. 
The $13,369 in additional debt on his credit record and the unpaid $11,455 retail charge 
debt that has been dropped from his credit record cannot provide bases for disqualification 
because they were not alleged.4 Nevertheless, Applicant’s nonpayment of his mortgage 
loan and of the credit cards in SOR ¶¶ 1.b and 1.e sufficiently establish AG ¶ 19(a), 
“inability or unwillingness to satisfy debts,” and AG ¶ 19(c), “a history of not meeting 
financial obligations.” 
 
 Mitigating condition AG ¶ 20(a), “the behavior happened so long ago, was so 
infrequent, or occurred under such circumstances that it is unlikely to recur and does not 
cast doubt on the individual’s current reliability, trustworthiness, or good judgment,” cannot 
reasonably apply in this case. The accounts became delinquent within the last five years, 
and he has no record of recent payments. 
 
 AG ¶ 20(b), “the conditions that resulted in the financial problem were largely 
beyond the person’s control (e.g., loss of employment, a business downturn, unexpected 
medical emergency, or a death, divorce or separation), and the individual acted responsibly 
under the circumstances,” is implicated in that Applicant’s financial struggles largely began 
because of his divorce. Despite receiving $200 a week from Applicant during their 
separation, his ex-wife depleted their joint bank account, which he was required to maintain 
pending their divorce. Since their divorce in July 2013, he has had an alimony obligation of 
$600 per week, which has compromised his ability to address his delinquencies. He has 
had consistent income from his employment with a defense contractor and from his military 
retirement pay. Nonetheless, given his alimony obligation, he may not have been able to 
make other than small payments toward his debts. Under the circumstances, Applicant 
acted responsibly by filing a Chapter 13 bankruptcy under which his creditors would have 
received at least a percentage of what he owed. However, Applicant cannot be said to 
have acted fully responsibly toward his creditors when he made no attempts to arrange 
affordable repayment terms with his creditors after his bankruptcy was dismissed. When 
asked at his hearing to explain his lack of progress toward addressing his delinquencies, 
Applicant responded, “I was just maybe being careless.” (Tr. 55.) 
                                                 
4 The DOHA Appeal Board has long held that the administrative judge may consider non-alleged conduct to 
assess an applicant’s credibility; to evaluate an applicant’s evidence of extenuation, mitigation, or changed 
circumstances; to consider whether an applicant has demonstrated successful rehabilitation; to decide 
whether a particular provision of the Adjudicative Guidelines is applicable; or to provide evidence for a whole 
person analysis under Section 6.3 of the Directive. See, e.g., ISCR Case No. 03-20327 (App. Bd. Oct. 26, 
2006); ISCR Case No. 09-07219 (App. Bd. Sep. 27, 2012). The additional credit card delinquencies are 
relevant to assessing Applicant’s financial judgment generally. 
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 The foreclosure of Applicant’s home has apparently resolved his mortgage debt. To 
the extent that AG ¶ 20(c), “the person has received or is receiving counseling for the 
problem and/or there are clear indications that the problem is being resolved or is under 
control,” applies, it does not mitigate the credit card delinquencies that were yet to be 
addressed as of his security clearance hearing. In late November 2015, Applicant applied 
for a $33,000 loan from his 401(k), which he intended to use to reduce his delinquent debt. 
The record was open for additional documents until January 4, 2016, but Applicant 
forwarded no documents showing payments toward the debts in SOR ¶ 1.b or SOR ¶ 1.e, 
or the $13,369 in unalleged debt listed on his recent credit report. 
 
 Applicant’s application for the 401(k) loan could be considered a good-faith effort to 
address his credit card delinquencies. Yet, it would be premature to apply either AG ¶ 
20(d), “the individual initiated a good-faith effort to repay overdue creditors or otherwise 
resolve debts,” or AG ¶ 20(c) without evidence showing disbursement of monies to his 
creditors. Applicant has no track record of timely payments from which I could reasonably 
conclude that he will manage his finances responsibly. 
 
 AG ¶ 20(e) applies, but only to the debt in SOR ¶ 1.c. Available credit information 
shows that Applicant was only an authorized user of the account. His divorce paperwork 
(AE B) confirms that his ex-wife is solely liable for repayment. AG ¶ 20(e) provides: 
 
(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 admits that he incurred at least some of the debt on the credit cards that 
he is legally liable to repay, and as of the close of the evidentiary record, he had made no 
payments toward the debts. The financial considerations security concerns are not fully 
mitigated under the adjudicative guidelines. 
 
Whole-Person Concept 
 
Under the whole-person concept, the administrative judge must consider the totality 
of an applicant’s conduct and all relevant circumstances in light of the nine adjudicative 
process factors in AG ¶ 2(a).5 The analysis under Guideline F is incorporated in my whole-
                                                 
5 The factors under AG ¶ 2(a) are as follows: 
 
(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. 
 
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person analysis. Some of the factors in AG ¶ 2(a) were addressed under that guideline, but 
some warrant additional comment. 
 
 Applicant’s finances continue to be impacted by a significant alimony obligation that 
was assessed based on his income from his employment and military retirement income. 
Concerning Applicant’s financial situation as a whole, he has a significant financial burden 
even with the resolution of his mortgage. In addition to the credit card debts discussed 
above, he owes the IRS approximately $1,000 for tax year 2013. He has made only 
sporadic payments toward his delinquent taxes and none since June or July 2015. He also 
still owes his divorce attorney approximately $2,000. The DOHA Appeal Board has held 
that an applicant is not required to establish that he has paid each debt in the SOR, or 
even that the first debts paid be those in the SOR. However, an applicant needs to show 
that he has a plan to resolve his debts and that he has taken significant steps to implement 
his plan. See ISCR 07-06482 (App. Bd. May 21, 2008). Even if his loan from his 401(k) is 
processed as requested and he puts the entire $33,000 toward his delinquent debt, he will 
have $550 a month in loan payments for the next five years, and it is not clear that he can 
afford those payments. As of his hearing in December 2015, Applicant had not filed his 
federal or state income tax returns for tax year 2014. He was apparently missing his W-2 
for his military retirement pay, but he also did not request it until August 2015. It is unclear 
whether he owes any delinquent taxes for 2014. 
 
 It is well settled that once a concern arises regarding an applicant’s security 
clearance eligibility, there is a strong presumption against the grant or renewal of a security 
clearance. See Dorfmont v. Brown, 913 F.2d 1399, 1401 (9th Cir. 1990). A determination of 
an applicant’s eligibility for a security clearance should not be made as punishment for 
specific past conduct, but on a reasonable and careful evaluation of the evidence to 
determine if a nexus exists between established facts and a legitimate security concern. 
Applicant has not shown the good judgment that is demanded of persons with access to 
classified information. While his financial situation was not completely of his own making, 
he has not been proactive about resolving debts that he is legally liable to repay. After 
considering all the facts and circumstances, it is not clearly consistent with the national 
interest to continue his security clearance eligibility at this time. 
 
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 
 
Subparagraph 1.a:    For Applicant 
Subparagraph 1.b:   Against Applicant 
Subparagraph 1.c:   For Applicant 
Subparagraph 1.d:   Against Applicant 
Subparagraph 1.e:   Against Applicant 
 
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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 continue Applicant’s eligibility for a security 
clearance. Eligibility for access to classified information is denied. 
 
_____________________ 
Elizabeth M. Matchinski 
Administrative Judge