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 DEPARTMENT OF DEFENSE 
 DEFENSE OFFICE OF HEARINGS AND APPEALS 
  
  
 
In the matter of: ) 
 ) 
   )  ISCR Case No. 15-03019 
  ) 
Applicant for Security Clearance  ) 
 
 
Appearances 
 
For Government: Ray T. Blank, Esq., Department Counsel 
For Applicant: Pro se 
 
 
 
 
___________ 
 
Decision 
___________ 
 
HEINY, Claude, Administrative Judge: 
 
 Applicant’s federal income tax returns were not timely filed for several years, a 
tax lien was filed against her in 2007, and she had several delinquent obligations. The 
financial considerations security concerns have been mitigated. Access to classified 
information is granted.  
  
History of the Case 
  
On November 12, 2015, the Department of Defense (DoD) Consolidated 
Adjudication Facility (CAF) issued a Statement of Reasons (SOR) to Applicant pursuant 
to Executive Order (Exec. Or.) 10865, Safeguarding Classified Information within 
Industry, February 20, 1960; DOD Directive 5220.6, Defense Industrial Personnel 
Security Clearance Review Program (Directive), January 2, 1992; and the adjudicative 
guidelines (AG), which became effective on September 1, 2006. 
 
The SOR detailed reasons why the DOD CAF did not find under the Directive that 
it is clearly consistent with the national interest to grant or continue a security clearance 
for Applicant, and recommended referral to an administrative judge to determine 
whether a clearance should be granted, continued, denied, or revoked. Specifically, the 
SOR set forth security concerns arising under the financial considerations guidelines. 
 
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On December 17, 2015, Applicant responded to the SOR, and she requested a 
hearing. On February 17, 2016, the Defense Office of Hearings and Appeals (DOHA) 
issued a notice of hearing, setting the hearing for February 25, 2016. The hearing was 
held as scheduled.  
  
Department Counsel offered five exhibits (Ex.) 1-5, and Applicant offered three 
exhibits, Ex. A-C. There were no objections to the proffered exhibits and all were 
admitted. On March 28, 2016, Applicant provided post-hearing exhibits, which were 
admitted without objection. (Ex. D, E, F, G) On March 4, 2016, DOHA received a copy 
of the transcript (Tr.) of the hearing.  
 
Findings of Fact 
 
In Applicant’s SOR response, she was unsure about a $16 debt (SOR 1.a) and 
admitted the remaining SOR allegations. Applicant’s admissions are incorporated as 
facts. After a thorough review of the pleadings, exhibits, and submissions, I make the 
following additional findings of fact. 
 
Applicant is 55 years old, and has been employed by a defense contractor as a 
systems analyst since July 2012. (Ex. 1, Tr. 25, 48) Her annual salary is approximately 
$80,000. (Tr. 49) She has been separated from her husband since 2003. Her children, 
three of which are in college and one has graduated, no longer live in her home. She 
received sporadic child support from her spouse in the amount of $300 to $400 monthly. 
(Tr. 57) They no longer live in her home. (Tr. 33) Following her separation, Applicant 
moved in with her sister to save expenses. (Tr. 34) For ten years starting in 1994, she 
worked for a major airline. In 2004, she went to work for a video rental store chain, but 
was terminated in May 2007 for inappropriate conduct with another employee. She 
described the conduct as “horseplay.” (Ex. 5) She then had sporadic employment, with 
periods of unemployment in 2009 and 2011. At times, she had two full-time jobs in order 
to provide for her family. (Tr. 32)  
 
The SOR alleges an $8,200 tax lien, a $5,000 debt following a vehicle 
repossession, seven additional debts totaling $1,146, and $40,000 in unpaid taxes. 
Other than her tax debt, her total indebtedness listed in the SOR is $14,328. Applicant 
acknowledged she had been financially irresponsible in the past. In September 2012, 
Applicant had a personal subject interview (PSI) and made an unsworn statement. (Ex. 
5) Following her PSI, she hired a credit firm to help her address her credit issues. (Ex. 
5) She paid the company $600 and received very little assistance. (Tr. 37, 69)  
 
On Applicant’s July 2012 Electronic Questionnaires for Investigations Processing 
(e-QIP) she listed her failure to file her tax returns and pay the tax due. (Ex. 1) In her 
PSI, she indicated she had not filed her federal income tax returns for tax years 2006 
through 2011. Her husband had previously decided not to have taxes withheld from his 
pay. They separated in 2003, and she failed to file her returns. As sole provider for 
herself and her children, she made the decision to retain as much income during the 
year to help her pay living expenses and support her three boys and one girl. (Tr. 17, 
20) She had money withheld from her pay, but the amount withheld was insufficient to 
 
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pay her federal taxes when they were due. (Ex. 1, Tr. 38) Her state does not have 
personal income tax. She chose not to apply for food stamps or other forms of welfare. 
(Tr. 20) 
 
Applicant contacted the Internal Revenue Service (IRS) on her own to determine 
what she owed. (Tr. 61) She asked what years were unfiled and what she had to do to 
become compliant. She did not know the full extent until she talked with the IRS. (Tr. 
60) Her reason for filing was “[t]hat’s my duty as a citizen.” (Tr. 61) Following her 
separation from her husband, she failed to file her tax returns for year 2006, which was 
due in April 2007, onward.  
 
 In September 2010, three and a half years since she should have filed her tax 
year 2006 return, she hired a tax professional to file her past-due returns. He failed to 
get the returns filed and is no longer in business. (Ex. 5) He informed Applicant that he 
attempted to file her returns but they were rejected by the IRS because someone else 
had already filed. (Tr. 36, 38) An unauthorized person had received her $3,000 tax 
refund. (Tr. 51) She questioned the IRS as to why a refund check had been issued 
when she was still indebted to the IRS. (Tr. 52) No satisfactory response was received. 
She hired a tax firm that frequently advertises tax assistance on late night television. 
(Tr. 39) She paid for their services and, again, received little of value.  
 
In 2012, Applicant contacted another tax company to assist her in the filing of her 
returns. She paid them $2,500 and the company contacted the Internal Revenue 
Service (IRS) on her behalf. The company filed her 2006 through 2011 tax returns in 
August 2012, a month after starting her job with her current employer. (Tr. 39, 64) She 
made an arrangement with the IRS by which she would pay $800 monthly on her 
delinquent tax debt. (Tr. 53, 54) During her PSI, she stated she was unaware an $8,208 
tax lien (SOR 1.g) had been filed against her in 2007 for tax years 2002 and 2003.(Ex. 
5) In December 2015, she paid the federal tax lien and it was released. (Ex. A) At one 
time, she was paying the IRS $800 per month to address the debt.  
 
In February 2016, Applicant entered into another installment agreement with the 
IRS, which automatically debits $500 monthly from her account to pay her past-due 
taxes including tax years 2012, 2013, and 2014.1 (Ex. E, Tr. 40, 53) This will address 
the approximate $35,0002 she owes in taxes. (Tr. 54) Her taxes for tax year 2015 were 
timely filed and paid. (Tr. 39) 
On Applicant’s e-QIP and during her interview she indicated her vehicle had 
been repossessed when she lost her job at the video rental store. (Ex. 1, 5) This is the 
first car she ever purchased. (Tr. 34) The day she lost her job, she called the credit 
union and had them pick up the vehicle. (Tr. 34) She had purchased the vehicle in 
October 2004. (Ex. 2) She owes approximately $5,000 (SOR 1.h) on the loan. As of 
March 28, 2016, she had not reached an agreement with the credit union as to a 
repayment plan. (Ex. G) When she contacted the credit union, the lender informed her 
                                            
1 The IRS informed Applicant she owed $72 for tax year 2014. (Tr. 55) 
 
2 The $40,000 listed in SOR 1.j included the $8,208 owed for tax years 2002 and 2003. (Tr. 54) 
 
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that the debt was no longer enforceable. (Tr. 43) She was informed by an employee of 
the credit reporting agency not to restart payment on the debt because a payment could 
re-establish the debt and take it out of the protection of the statute of limitations. (Tr. 44) 
Knowing these facts, Applicant is still attempting to reach some sort of repayment 
arrangement concerning the debt. She has recently made a $1,000 offer to settle the 
matter. (Ex. G) 
In addition to the repossession, Applicant’s April 2012 credit report lists five 
additional accounts with the same credit union that were all paid as agreed. (Ex.2) Her 
December 2014 credit report lists no derogatory information and her February 2016 
credit report lists no repossessions or charged-off accounts. (Ex.3, 4) Her December 
2015 credit reports do not list any derogatory account with the credit union listed in SOR 
1.h. (Ex. B, C) 
 
During Applicant’s interview, she did not recognize a $234 charged-off account 
(SOR 1.e) with the same credit union. (Ex. 5) During her interview, she had no 
knowledge about the following debts: SOR 1.a, $57; SOR 1.c, $42; SOR 1.d, $180, and 
SOR 1.i, $16. (Ex. 5) She acknowledged the $207 (SOR 1.b) medical debt. (Ex. 5) The 
creditor offered to settle the $207 debt for $124, which she accepted and paid. (SOR 
Answer, Tr. 45) She is disputing the $410 (SOR 1.e) charged-off account. She 
contacted the creditor and was informed the creditor was no longer reporting the debt to 
the credit reporting firms.  
 
Two of Applicant’s delinquent debts involve insufficient funds checks (SOR 1.d, 
$180 and SOR 1.i, $16). The state in which she lives has a very aggressive stance on 
insufficient fund checks. She received a letter from the district attorney’s (DA) office 
concerning her bad checks. She went to the DA’s office where she was photographed 
and fingerprinted, but not arrested. (Ex. 5) State law requires her to immediately redeem 
such checks or face criminal prosecution. (Tr. 46) She made good on the checks.  
 
Applicant contacted every SOR creditor. (Tr. 21) The creditor in SOR 1.a ($57) 
had no information concerning any delinquent obligation owed by her. (Tr. 21, 45) 
Applicant does not have credit cards and drives a 21-year-old car she purchased from 
her sister. (Tr. 33, 48) She asserts she lives simply and wants to address her delinquent 
debts. (Tr. 49) She is not receiving any calls or correspondence concerning delinquent 
accounts. (Tr. 50) There has been fraud on her accounts resulting in her having to open 
and later close five checking accounts. (Tr. 50) The last fraud occurred in January 2016 
when someone spent $300 from her account. (Tr. 51) She met with a financial advisor 
weekly for a couple of months learning about saving, budgets, not incurring new debt, 
and meeting her financial obligations. (Tr. 86)  
 
Policies 
 
The U.S. Supreme Court has recognized the substantial discretion of the 
Executive Branch in regulating access to information pertaining to national security 
emphasizing, “no 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 
 
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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 
applicant’s eligibility for access to classified information “only upon a finding that it is 
clearly consistent with the national interest to do so.” Exec. Or. 10865, Safeguarding 
Classified Information within Industry § 2 (Feb. 20, 1960), as amended.  
 
Eligibility for a security clearance is predicated upon the applicant meeting the 
criteria contained in the adjudicative guidelines. These guidelines are not inflexible rules 
of law. Instead, recognizing the complexities of human behavior, these guidelines are 
applied 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, 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 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 “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, nothing should be construed to suggest that I have based this decision, in whole 
or in part, on any express or implied determination about applicant’s allegiance, loyalty, 
or patriotism. It 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. 95-0611 
at 2 (App. Bd. May 2, 1996). 
 
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 ultimate burden of demonstrating that it 
is clearly consistent with the national interest to grant or continue his or her security 
clearance.” ISCR Case No. 01-20700 at 3 (App. Bd. Dec. 19, 2002). The burden of 
disproving a mitigating condition never shifts to the Government. See ISCR Case No. 
02-31154 at 5 (App. Bd. Sep. 22, 2005). “[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 
 
Financial Considerations 
 
AG ¶ 18 articulates the security concern relating to financial problems:  
 
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.  
 
AG ¶ 19 provides three disqualifying conditions that could raise a security 
concern and may be disqualifying in this case: “(a) inability or unwillingness to satisfy 
debts;” “(c) a history of not meeting financial obligations;” and “(g) failure to file annual 
Federal, state, or local income tax returns as required . . . .” She admitted that she failed 
to timely file her federal tax returns, that she had a vehicle repossessed in 2007, and 
had other delinquent debt totaling approximately $1,100.  
 
  In ISCR Case No. 08-12184 at 7 (App. Bd. Jan. 7, 2010), the Appeal Board 
explained: 
 
It is well-settled that adverse information from a credit report can normally 
meet the substantial evidence standard and the government’s obligations 
under [Directive] ¶ E3.1.14 for pertinent allegations. At that point, the 
burden shifts to applicant to establish either that [he or] she is not 
responsible for the debt or that matters in mitigation apply. 
 
The Government established the disqualifying conditions in AG ¶¶ 19(a), 19(c), 
and 19(g) requiring additional inquiry about the possible applicability of mitigating 
conditions.  
 
Five mitigating conditions under AG ¶ 20 are potentially applicable: 
  
(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; 
  
 
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(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;3 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. 
 
The Appeal Board concisely explained an applicant’s responsibility for proving 
the applicability of mitigating conditions as follows:  
 
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. See Dorfmont v. Brown, 913 F. 2d 1399, 1401 (9th 
Cir. 1990), cert. denied, 499 U.S. 905 (1991). After the Government 
presents evidence raising security concerns, the burden shifts to the 
applicant to rebut or mitigate those concerns. See Directive ¶ E3.1.15. The 
standard applicable in security clearance decisions is that articulated in 
Egan, supra. “Any doubt concerning personnel being considered for 
access to classified information will be resolved in favor of the national 
security.” Directive, Enclosure 2 ¶ 2(b).  
 
ISCR Case No. 10-04641 at 4 (App. Bd. Sept. 24, 2013).  
 
Applicant failed to withhold sufficient funds from her salary to pay her share of 
her federal income taxes and she failed to timely file her federal tax returns for several 
years. She did so in order to provide for her four children. She contacted the IRS about 
her failure to file because, as she acknowledged, it was her duty as a citizen to file tax 
returns and pay taxes. The DOHA Appeal Board has commented about tax filing issues: 
 
                                            
3The Appeal Board has previously explained what constitutes a “good faith” effort to repay 
overdue creditors or otherwise resolve debts:  
 
In order to qualify for application of [the “good faith” mitigating condition], an applicant 
must present evidence showing either a good-faith effort to repay overdue creditors or 
some other good-faith action aimed at resolving the applicant’s debts. The Directive does 
not define the term “good-faith.” However, the Board has indicated that the concept of 
good-faith “requires a showing that a person acts in a way that shows reasonableness, 
prudence, honesty, and adherence to duty or obligation.” Accordingly, an applicant must 
do more than merely show that he or she relied on a legally available option (such as 
bankruptcy) in order to claim the benefit of [the “good faith” mitigating condition]. 
 
(internal citation and footnote omitted) ISCR Case No. 02-30304 at 3 (App. Bd. Apr. 20, 2004) (quoting 
ISCR Case No. 99-9020 at 5-6 (App. Bd. June 4, 2001)).  
 
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Failure to file tax returns suggests that an applicant has a problem with 
complying with well-established governmental rules and systems. 
Voluntary compliance with such rules and systems is essential for 
protecting classified information. ISCR Case No. 01-05340 at 3 (App. Bd. 
Dec. 20, 2002). As we have noted in the past, a clearance adjudication is 
not directed at collecting debts. See, e.g., ISCR Case No. 07-08049 at 5 
(App. Bd. Jul. 22, 2008). By the same token, neither is it directed toward 
inducing an applicant to file tax returns. Rather, it is a proceeding aimed at 
evaluating an applicant’s judgment and reliability. Id. A person who fails 
repeatedly to fulfill his or her legal obligations does not demonstrate the 
high degree of good judgment and reliability required of those granted 
access to classified information. See, e.g., ISCR Case No. 14-01894 at 5 
(App. Bd. Aug. 18, 2015). See Cafeteria & Restaurant Workers Union 
Local 473 v. McElroy, 284 F.2d 173, 183 (D.C. Cir. 1960), aff’d, 367 U.S. 
886 (1961). 
 
ISCR Case No. 14-04437 at 3 (App. Bd. Apr. 15, 2016). See ISCR Case No. 14-05476 
at 5 (App. Bd. Mar. 25, 2016) (citing ISCR Case No. 01-05340 at 3 (App. Bd. Dec. 20, 
2002)); ISCR Case No. 14-01894 at 4-5 (App. Bd. Aug. 18, 2015).  
 
The Appeal Board clarified that even in instances where an “[a]pplicant has 
purportedly corrected [the applicant’s] federal tax problem, and the fact that [applicant] 
is now motivated to prevent such problems in the future, does not preclude careful 
consideration of [a]pplicant’s security worthiness in light of [applicant’s] longstanding 
prior behavior evidencing irresponsibility” including a failure to timely file federal income 
tax returns. See ISCR Case No. 15-01031 at 3 and note 3 (App. Bd. June 15, 2016) 
(characterizing “no harm, no foul” approach to an applicant’s course of conduct and 
employed an “all’s well that ends well” analysis as inadequate to support approval of 
access to classified information with focus on timing of filing of tax returns after receipt 
of the SOR).  
 
 Applicant has initiated a good-faith effort to repay her delinquent taxes. In 
December 2015, she paid an $8,200 tax lien (SOR 1.g) and it was withdrawn. The lien 
was for tax years 2002 and 2003. In February 2016, she entered into an installment 
agreement with the IRS to pay her remaining taxes (SOR 1.j) of approximately $35,000. 
The agreement requires $500 to be automatically debited from her account monthly. AG 
¶ 20 (d) applies to her taxes.  
 
AG ¶ 20 (d) also applies to SOR 1.b, and to the insufficient fund checks listed in 
SOR 1.a, 1.d, and 1.i. Had she not redeemed the checks she would have faced 
prosecution. She contacted all of her creditors. The creditor claiming a $57 collection 
debt (SOR 1.a) informed Applicant that the creditor has no documentation showing a 
delinquent obligation. She is disputing the $234 charged-off account (SOR 1.e) and 
$410 charged-off account (SOR 1.f), which no longer appear on her credit report. The 
debts no longer appear on her credit reports. These two debts which total $644 are not 
large enough to be of security significance. 
 
 
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The remaining debt results from the repossession of Applicant’s vehicle in 2007. 
She acted responsibly when she lost her job at the video rental store by immediately 
calling the credit union to inform them she would not be able to continue her payments 
and they should come and get the vehicle. The repossession was over nine years ago 
and was due to losing her job. AG ¶ 20 (a) applies. Additionally, the creditor informed 
Applicant that the debt was no longer enforceable. An employee of a credit reporting 
agency informed her that to make payment might reinstate the debt. Even with this 
knowledge, Applicant has continued to pursue some type of settlement with the lender. 
She has not yet reached agreement, but has continued her attempt to reach an 
agreement. Financial considerations concerns are mitigated.  
 
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 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. I have incorporated my 
comments under Guideline F in my whole-person analysis. Some of the factors in AG ¶ 
2(a) were addressed under Guideline F, but some warrant additional comment.  
 
In 2007, Applicant lost her job which resulted in the repossession of her vehicle. 
Even with the debt being unenforceable, Applicant is voluntarily attempting to reach 
some type of agreeable payment on the debt. She paid an $8,200 tax lien and has an 
arrangement to repay her other past-due taxes. I believe that someone who pay a tax 
lien and enters into a repayment agreement is likely to meet that obligation. The tax 
debt is large and will take some time to satisfy, but the monthly amount is automatically 
deducted from her account. She received weekly financial counseling for a few months. 
She is not living beyond her means. She drives a vehicle more than twenty years old. 
She has no credit cards and is receiving no demand from creditors for payment. She 
indicates she lives simply and wants to address her past financial problems. 
 
The issue is not simply whether all her debts are paid—it is whether her financial 
circumstances raise concerns about her fitness to hold a security clearance. (See AG & 
2(a)(1).) Overall, the record evidence leaves me without questions or doubts as to 
 
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Applicant’s eligibility and suitability for a security clearance. For all these reasons, I 
conclude Applicant mitigated the security concerns arising from her financial 
considerations.  
 
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:    FOR APPLICANT  
 
Subparagraphs 1.a through 1.j:   For Applicant 
 
Conclusion 
 
In light of all of the circumstances presented by the record in this case, it is 
clearly consistent with the national interest to grant or continue Applicant’s eligibility for 
a security clearance. Eligibility for access to classified information is granted. 
 
 
 
_________________________ 
Claude R. Heiny 
Administrative Judge