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   DEPARTMENT OF DEFENSE 
       DEFENSE OFFICE OF HEARINGS AND APPEALS 
           
             
 
 
 
In the matter of: ) 
 ) 
 ---  )  ISCR Case No. 15-01735 
  ) 
Applicant for Security Clearance ) 
  
 
Appearances 
 
For Government: Julie R. Mendez, Esquire, Department Counsel 
For Applicant: Pro se 
 
 
 
______________ 
 
Decision 
______________ 
 
 
GALES, Robert Robinson, Administrative Judge: 
 
Applicant failed to mitigate the security concerns regarding financial considerations 
and personal conduct. Eligibility for access to classified information is denied. 
 
Statement of the Case 
 
On June 3, 2014, Applicant applied for a security clearance and submitted an 
Electronic Questionnaire for Investigations Processing (e-QIP) version of a Security 
Clearance Application.1 On September 15, 2015, the Department of Defense (DOD) 
Consolidated Adjudications Facility (CAF) issued an SOR to him, under Executive Order 
10865, Safeguarding Classified Information within Industry (February 20, 1960), as 
amended and modified; DOD Directive 5220.6, Defense Industrial Personnel Security 
Clearance Review Program (January 2, 1992), as amended and modified (Directive); and 
the Adjudicative Guidelines for Determining Eligibility For Access to Classified Information 
(December 29, 2005) (AG) applicable to all adjudications and other determinations made 
under the Directive, effective September 1, 2006. The SOR alleged security concerns 
under Guideline F (Financial Considerations) and Guideline E (Personal Conduct), and 
                                                          
1 Item 3 (e-QIP, dated June 3, 2014). 
 
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detailed reasons why the DOD adjudicators were unable to find that it is clearly consistent 
with the national interest to grant or continue a security clearance for Applicant. The SOR 
recommended referral to an administrative judge to determine whether a clearance 
should be granted, continued, denied, or revoked.  
 
 It is unclear as to when Applicant received the SOR as there is no receipt in the 
case file. In a sworn statement, dated October 2, 2015, Applicant responded to the SOR 
and elected to have his case decided on the written record in lieu of a hearing. Applicant’s 
response was considered incomplete, as he had failed to admit or deny the allegations in 
the SOR. On April 11, 2016, he submitted his Revised Answer to the SOR. A complete 
copy of the Government’s file of relevant material (FORM) was mailed to Applicant by the 
Defense Office of Hearings and Appeals (DOHA) on May 2, 2016, and he was afforded 
an opportunity, within a period of 30 days after receipt of the FORM, to file objections and 
submit material in refutation, extenuation, or mitigation. In addition to the FORM, 
Applicant was furnished a copy of the Directive as well as the Guidelines applicable to his 
case. Applicant received the FORM on May 5, 2016. Applicant’s response was due on 
June 4, 2016, but to date, no response has been received. The case was assigned to me 
on April 6, 2017.  
 
Findings of Fact 
 In his Revised Answer to the SOR, Applicant admitted, without any comments, all 
of the factual allegations pertaining to financial considerations (¶¶ 1.a. through 1.o.) of 
the SOR. He denied the sole allegation pertaining to personal conduct (¶ 2.a.). Applicant’s 
admissions are incorporated herein as findings of fact. After a complete and thorough 
review of the evidence in the record, and upon due consideration of same, I make the 
following additional findings of fact: 
 
Applicant is a 53-year-old employee of a defense contractor. He has been a ground 
support equipment (GSE) mechanic with the company since March 2000. He is a June 
1982 high school graduate. Applicant has never served with the U.S. military. He was 
granted a secret security clearance on an unspecified date, and it is unclear if he still has 
that clearance. Applicant was married in September 1992. Although Applicant did not list 
any children in his 2014 e-QIP, there is evidence in the case file that he has one college-
age daughter.  
 
Financial Considerations2 
It is unclear what Applicant’s finances were like before they deteriorated. His June 
2014 credit report reveals a substantial number of delinquent accounts, including 
judgments filed as far back as 2009. Applicant failed to attribute his financial difficulties to 
any specific events that could be construed as being largely beyond Applicant’s control. 
                                                          
2 General source information pertaining to the financial accounts discussed below can be found in the following 
exhibits: Item 3, supra note 1; Item 7 (Combined Experian, TransUnion, and Equifax Credit Report, dated June 25, 
2014); Item 6 (Equifax Credit Report, dated January 30, 2015); Item 5 (Equifax Credit Report, dated August 31, 2015); 
Item 4 (Voluntary Petition, Chapter 13 Bankruptcy, dated June 5, 2015).  
 
 
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He neglected to describe any efforts he may have taken to contact his creditors to work 
out settlements or repayment arrangements; or any efforts to reflect that payments were 
ever made to his creditors or collection agents.  
The SOR identified 14 purportedly delinquent debts that had been placed for 
collection, charged off, or filed as judgments, as generally reflected by his June 2014 
credit report, his January 2015 credit report, or his August 2015 credit report. Applicant’s 
2015 Chapter 13 bankruptcy petition reflected liabilities totaling $221,740.75. Based on 
the evidence listed in his bankruptcy petition and the credit reports, the current status of 
the debts alleged in the SOR are described below. 
Those delinquent accounts, for which there is no evidence of resolution, pending 
resolution, or dispute, are as follows: delinquent federal taxes for the tax year 2011 in the 
amount of $827.49 (SOR ¶ 1.b.); delinquent state taxes for the tax year 2013 in the 
amount of $914.36 (SOR ¶ 1.c.); a judgment for $3,445 filed in 2014 (SOR ¶ 1.d.); a 
judgment on a repossessed automobile for $3,000 filed in 2009 (SOR ¶ 1.e.); a judgment 
for $368 filed in 2010 (SOR ¶ 1.f.); a home mortgage loan that was past due in the amount 
of $12,175 (SOR ¶ 1.g.); an automobile account that was past due $864 (SOR ¶ 1.h.); 
three medical accounts with unpaid balances of $229 (SOR ¶ 1.i.), $100 (SOR ¶ 1.j.), and 
$100 (SOR ¶ 1.k.); a cellular phone account with an unpaid balance of $71 (SOR ¶ 1.l.); 
an insurance account with an unpaid balance of $955 (SOR ¶ 1.m.); a cash advance 
account with an unpaid balance of $526 (SOR ¶ 1.n.); and a telephone account with an 
unpaid balance of $110 (SOR ¶ 1.o.). 
At the time Applicant filed for bankruptcy in June 2015, he reported total assets of 
$159,646 (including four automobiles) and total liabilities of $221,740.75 (SOR ¶ 1.a.). 
He listed $58,099.67 owed creditors holding secured claims (a home mortgage and an 
automobile loan); $1,741.85 owed to creditors holding unsecured priority claims (state 
and federal taxes); and $14,222.88 owed to 13 creditors holding unsecured nonpriority 
claims. His combined net family income was listed as $5,000, with monthly expenses of 
$4,565, leaving a monthly remainder of $435 available for saving or spending. He also 
reported a $10 expense for credit counseling related to his bankruptcy. There is no 
indication that a Chapter 13 payment plan had been approved by the Bankruptcy Court 
or that a Trustee had been assigned to the action. There is no evidence of any payments 
having been made during the period June 2015, when the petition was filed, and June 
2016, when Applicant’s response to the FORM was due. In the absence of pre-bankruptcy 
resolution efforts and a bankruptcy payment plan, it appears that Applicant’s debts have 
not been resolved and his finances are not yet under control. 
Personal Conduct 
 
 When Applicant completed his e-QIP on June 3, 2014, he responded to a series 
of questions in Section 26 – Financial Record which asked if he was currently delinquent 
on any Federal debt; or in the past seven years, he had: a judgment entered against him; 
defaulted on any type of loan; had bills or debts turned over to a collection agency; had 
any account or credit card suspended, charged off, or cancelled for failing to pay as 
agreed; been over 120 days delinquent on any debt not previously entered, and if he was 
 
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currently over 120 days delinquent on any debt. Applicant answered “no” to all of those 
questions. He certified that the responses were “true, complete, and correct” to the best 
of his knowledge and belief, but the responses to those questions were, in fact, false for 
Applicant had multiple accounts that came within the parameters of the questions. In his 
Revised Answer to the SOR, he admitted having the accounts in collection, but he denied 
that he had intentionally falsified the fact, claiming that he “did not have a clear 
understanding or misread the question.”  
  
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.”3 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. The President has authorized the Secretary of Defense or his designee to 
grant an applicant eligibility for access to classified information “only upon a finding that 
it is clearly consistent with the national interest to do so.”4   
 
When evaluating an applicant’s suitability for a security clearance, the 
administrative judge must consider the AG. In addition to brief introductory explanations 
for each guideline, the AG list potentially disqualifying conditions and mitigating 
conditions, which are used in evaluating an applicant’s eligibility for access to classified 
information. 
 
An administrative judge need not view the guidelines as inflexible, ironclad rules 
of law. Instead, acknowledging the complexities of human behavior, these guidelines are 
applied in conjunction with the factors listed in the adjudicative process. The 
administrative judge’s overarching adjudicative goal is a fair, impartial, and commonsense 
decision. 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 meaningful decision. 
 
In the decision-making process, facts must be established by “substantial 
evidence.”5 The Government initially has the burden of producing evidence to establish a 
potentially disqualifying condition under the Directive, and has the burden of establishing 
controverted facts alleged in the SOR. Once the Government has produced substantial 
evidence of a disqualifying condition, under Directive ¶ E3.1.15, the applicant has the 
                                                          
3 Department of the Navy v. Egan, 484 U.S. 518, 528 (1988). 
 
4 Exec. Or. 10865, Safeguarding Classified Information within Industry § 2 (Feb. 20, 1960), as amended and 
modified.    
 
5 “Substantial evidence [is] such relevant evidence as a reasonable mind might accept as adequate to support 
a conclusion in light of all contrary evidence in the record.”  ISCR Case No. 04-11463 at 2 (App. Bd. Aug. 4, 2006) 
(citing Directive ¶ E3.1.32.1).  “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). 
 
 
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burden of persuasion to present evidence in refutation, explanation, extenuation or 
mitigation, sufficient to overcome the doubts raised by the Government’s case. The 
burden of disproving a mitigating condition never shifts to the Government.6  
 
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 as well. It is 
because of this special relationship that the Government must be able to repose a high 
degree of trust and confidence in those 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 safeguard classified information. Such 
decisions entail a certain degree of legally permissible extrapolation as to potential, rather 
than actual, risk of compromise of classified information.  Furthermore, “security 
clearance determinations should err, if they must, on the side of denials.”7  
 
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.”8 Thus, nothing in this 
decision should be construed to suggest that I have based this decision, in whole or in 
part, on any express or implied determination as to Applicant’s allegiance, loyalty, or 
patriotism. It is merely an indication the Applicant has or has not met the strict guidelines 
the President and the Secretary of Defense have established for issuing a clearance.  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. 
 
Analysis 
 
Guideline F, Financial Considerations 
 
The security concern relating to the guideline for Financial Considerations is set 
out 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. . . . 
The guideline notes several conditions that could raise security concerns. Under 
AG ¶ 19(a), an “inability or unwillingness to satisfy debts” is potentially disqualifying.  
                                                          
6 See ISCR Case No. 02-31154 at 5 (App. Bd. Sep. 22, 2005). 
 
7 Egan, 484 U.S. at 531. 
 
8 See Exec. Or. 10865 § 7. 
 
 
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Similarly, under AG ¶ 19(c), “a history of not meeting financial obligations” may raise 
security concerns. Applicant’s financial problems initially arose some time prior to 2009, 
when a judgment was filed against him, and continued thereafter. Accounts became 
delinquent. Some accounts were charged off. Federal and state taxes were not paid. A 
vehicle was repossessed. AG ¶¶ 19(a) and 19(c) apply.  
The guideline also includes examples of conditions that could mitigate security 
concerns arising from financial difficulties. Under AG ¶ 20(a), the disqualifying condition 
may be mitigated where “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.” Also, under AG ¶ 
20(b), financial security concerns may be mitigated where “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.” Evidence that “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” is potentially mitigating under AG 
¶ 20(c). Similarly, AG ¶ 20(d) applies where the evidence shows “the individual initiated 
a good-faith effort to repay overdue creditors or otherwise resolve debts.”9 In addition, AG 
¶ 20(e) may apply if “the individual has a reasonable basis to dispute the legitimacy of the 
past-due debt which is the basis of the dispute or provides evidence of actions to resolve 
the issue.” 
AG ¶¶ 20(a), 20(b), 20(d), and 20(e) do not apply. AG ¶ 20(c) minimally applies. 
Applicant failed to attribute his financial difficulties to any specific events that could be 
construed as being largely beyond Applicant’s control. He neglected to describe any 
efforts he may have taken to contact his creditors to work out settlements or repayment 
arrangements; or any efforts to reflect that payments were ever made to his creditors or 
collection agents. Other than the incomplete filing of his Chapter 13 Bankruptcy Petition, 
there is no evidence of any efforts, much less “good-faith” efforts to address his debts 
over a multi-year period. 
Clearance decisions are aimed at evaluating an applicant’s judgment, reliability, 
and trustworthiness. They are not a debt-collection procedure. The adjudicative 
guidelines do not require an applicant to establish resolution of each and every debt 
                                                          
9 The 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 [or statute of limitations]) 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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alleged in the SOR. An applicant need only establish a plan to resolve financial problems 
and take significant actions to implement the plan. There is no requirement that an 
applicant immediately resolve or make payments on all delinquent debts simultaneously, 
nor is there a requirement that the debts alleged in an SOR be paid first. Rather, a 
reasonable plan and concomitant conduct may provide for the payment of such debts one 
at a time.  
 
In this instance, there is no evidence of any pre-bankruptcy resolution actions or 
an approved Chapter 13 payment plan. Applicant offered no documentary evidence of a 
good-faith effort to resolve or dispute any of his accounts. Applicant had two years since 
the filing of his bankruptcy petition in June 2015, and approximately one and one-half 
years following receipt of the SOR, to resolve, or at least start to resolve, his delinquent 
accounts, but, to date, by his inaction, he has failed to do so. Applicant appears to have 
acted imprudently and irresponsibly.10 Applicant’s actions, or inactions, under the 
circumstances confronting him, continue to cast doubt on his current reliability, 
trustworthiness, and good judgment.11 
 
Other than a brief mention that Applicant completed financial counseling in relation 
to the filing of his bankruptcy, there is no evidence to indicate that Applicant ever received 
substantial financial counseling with emphasis on credit management, budgeting, or debt 
consolidation. Based on the two-year-old information furnished in the Bankruptcy Petition, 
it is unclear if Applicant currently has any meaningful funds remaining at the end of each 
month for discretionary use or savings. There is no evidence to reflect that Applicant’s 
financial problems are under control. To the contrary, the overwhelming evidence leads 
to the conclusion that Applicant’s financial problems are not under control.  
 
Guideline E, Personal Conduct 
 
The security concern relating to the guideline for Personal Conduct is set out in 
AG & 15:       
 
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.  
 
                                                          
10 “Even if Applicant’s financial difficulties initially arose, in whole or in part, due to circumstances outside his 
[or her] control, the Judge could still consider whether Applicant has since acted in a reasonable manner when dealing 
with those financial difficulties.” ISCR Case No. 05-11366 at 4 n.9 (App. Bd. Jan. 12, 2007) (citing ISCR Case No. 99-
0462 at 4 (App. Bd. May 25, 2000); ISCR Case No. 99-0012 at 4 (App. Bd. Dec. 1, 1999); ISCR Case No. 03-13096 at 
4 (App. Bd. Nov. 29, 2005)). A component is whether he or she maintained contact with creditors and attempted to 
negotiate partial payments to keep debts current. 
 
11 See ISCR Case No. 09-08533 at 3-4 (App. Bd. Oct. 6, 2010). 
 
 
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 The guideline notes several conditions that could raise security concerns. Under 
AG ¶ 16(a), it is potentially disqualifying if there is 
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. 
 On June 3, 2014, when Applicant completed his e-QIP, he falsely responded to a 
series of questions in Section 26 – Financial Record that asked about past and current 
delinquencies. He certified that the responses were “true, complete, and correct” to the 
best of his knowledge and belief, but the responses to those questions were, in fact, false 
for Applicant had concealed multiple accounts that came within the parameters of the 
questions. In his Revised Answer to the SOR, he admitted having the accounts in 
collection, but he denied that he had intentionally falsified the fact, claiming that he “did 
not have a clear understanding or misread the question.” That explanation, without more, 
is simply too simplistic. His position is unreasonable and not credible. AG ¶ 16(a) has 
been established.  
 
The guideline also includes examples of conditions that could mitigate security 
concerns arising from personal conduct, but none of those mitigating conditions apply. 
His conduct shows a lack of honesty and integrity.  
 
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. Moreover, I have 
evaluated the various aspects of this case in light of the totality of the record evidence 
and have not merely performed a piecemeal analysis.12       
                                                          
12 See U.S. v. Bottone, 365 F.2d 389, 392 (2d Cir. 1966); See also ISCR Case No. 03-22861 at 2-3 (App. Bd. 
Jun. 2, 2006). 
 
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There is some evidence in favor of mitigating Applicant’s conduct. Applicant has 
been employed by the same defense contractor since March 2000. He was granted a 
secret security clearance on an unspecified date.  
The disqualifying evidence under the whole-person concept is simply more 
substantial. As noted above, Applicant’s financial problems commenced some time 
before 2009 and they continue to the present. Applicant offered no explanations as to 
how or why his accounts became delinquent. The SOR identified 14 purportedly 
delinquent debts that had been placed for collection, charged off, or filed as judgments. 
Applicant’s 2015 bankruptcy petition reflected liabilities totaling $221,740.75. There is no 
indication that a Chapter 13 payment plan had been approved by the Bankruptcy Court 
or that a Trustee had been assigned to the action. There is no evidence of any payments 
having been made during the period June 2015, when the petition was filed, and June 
2016, when Applicant’s response to the FORM was due. In the absence of pre-bankruptcy 
resolution efforts and a bankruptcy payment plan, it appears that Applicant’s debts have 
not been resolved and his finances are not yet under control. In addition, although he 
owed delinquent federal and state taxes, had lost a vehicle to repossession, and had a 
substantial number of accounts in collection or charged off, Applicant falsely denied 
having any financial difficulties when he completed his e-QIP. 
The Appeal Board has addressed a key element in the whole-person analysis in 
financial cases stating: 
In evaluating Guideline F cases, the Board has previously noted that the 
concept of “‘meaningful track record’ necessarily includes evidence of 
actual debt reduction through payment of debts.” However, an applicant is 
not required, as a matter of law, to establish that he [or she] has paid off 
each and every debt listed in the SOR. All that is required is that an applicant 
demonstrate that he [or she] has “. . . established a plan to resolve his [or 
her] financial problems and taken significant actions to implement that plan.” 
The Judge can reasonably consider the entirety of an applicant’s financial 
situation and his [or her] actions in evaluating the extent to which that 
applicant’s plan for the reduction of his outstanding indebtedness is credible 
and realistic. See Directive ¶ E2.2(a) (“Available, reliable information about 
the person, past and present, favorable and unfavorable, should be 
considered in reaching a determination.”) There is no requirement that a 
plan provide for payments on all outstanding debts simultaneously. Rather, 
a reasonable plan (and concomitant conduct) may provide for the payment 
of such debts one at a time. Likewise, there is no requirement that the first 
debts actually paid in furtherance of a reasonable debt plan be the ones 
listed in the SOR. 13 
 
Applicant has demonstrated a poor track record of debt reduction and elimination 
efforts. He offered no evidence of pre-bankruptcy resolution efforts, and only an 
                                                          
 
13 ISCR Case No. 07-06482 at 2-3 (App. Bd. May 21, 2008) (internal citations omitted). 
 
 
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incomplete bankruptcy filing, without an established or approved payment plan. His 
delinquent debts seemed to have been ignored over a multi-year period. Overall, the 
evidence leaves me with substantial questions and doubts as to Applicant’s security 
worthiness. For all of these reasons, I conclude Applicant has failed to mitigate the 
security concerns arising from his financial considerations and personal conduct. See AG 
¶ 2(a)(1) through AG ¶ 2(a)(9). 
 
Formal Findings 
 
 Formal findings for or against Applicant on the allegations set forth in the SOR, as 
amended, as required by section E3.1.25 of Enclosure 3 of the Directive, are: 
 
 Paragraph 1, Guideline F:   AGAINST APPLICANT 
 
  Subparagraphs 1.a. through 1.o:  Against Applicant 
  
Paragraph 2, Guideline E:   AGAINST APPLICANT  
 
Subparagraph 2.a:    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. 
 
                                          
            
________________________ 
ROBERT ROBINSON GALES 
Administrative Judge