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               DEPARTMENT OF DEFENSE 
     DEFENSE OFFICE OF HEARINGS AND APPEALS 
 
 
 
 
In the matter of:  ) 
 ) 
  REDACTED  )   ISCR Case No. 16-01165 
   ) 
Applicant for Security Clearance  ) 
 
 
Appearances 
 
For Government: Aubrey M. DeAngelis, Esq., Department Counsel 
For Applicant: Pro se 
 
 
______________ 
 
Decision 
______________ 
 
 
MATCHINSKI, Elizabeth M., Administrative Judge: 
 
Applicant defaulted on his federal student loans obtained for $47,508. While the 
loans were rehabilitated and in forbearance until mid-January 2017, there is no evidence of 
any payments on his student loans since their rehabilitation or of any payments on $7,783 
in delinquent credit card debt. Low income caused him to default on his financial 
obligations, but he has yet to show a track record of debt repayment despite now having 
the income to make payments. Clearance is denied. 
 
Statement of the Case 
 
 On October 3, 2016, 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 (EO) 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 for 
 
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Determining Eligibility for Access to Classified Information (AG) effective within the DOD on 
September 1, 2006. 
 
On November 3, 2016, Applicant answered the SOR allegations and requested a 
decision on the written record by an administrative judge from the Defense Office of 
Hearings and Appeals (DOHA). The Government submitted a File of Relevant Material 
(FORM), consisting of eight exhibits (Items 1 through 8). DOHA forwarded a copy of the 
FORM to Applicant on December 22, 2016, and instructed him to respond within 30 days 
of receipt. Applicant received the FORM on January 19, 2017. He submitted his response 
on February 19, 2017, consisting of his statement (AE A), two paystubs for him (AEs B-C), 
a household budget (AE D), two paystubs for his spouse (AEs E-F), and his parents’ joint 
federal and state income tax returns for tax year 2011 (AE G). On February 26, 2017, 
Department Counsel indicated that the Government had no objection to Applicant’s 
exhibits.  
 
On October 1, 2017, I was assigned the case to determine whether it is clearly 
consistent with national security to grant or continue a security clearance for Applicant. On 
review of the case file, I accepted in evidence AEs A-G. 
 
While this case was pending a decision, Security Executive Agent Directive 4 was 
issued establishing National Security Adjudicative Guidelines (AG) applicable to all covered 
individuals who require initial or continued eligibility for access to classified information or 
eligibility to hold a sensitive position. The AG supersede the adjudicative guidelines 
implemented in September 2006 and are effective for any adjudication made on or after 
June 8, 2017. Accordingly, I have adjudicated Applicant’s security clearance eligibility 
under the new AG.1 
 
Evidentiary Ruling 
 
 Department Counsel submitted as Item 8 a summary of an unsworn enhanced 
subject interview of Applicant conducted on January 8, 2016. This document was part of 
the DOD Report of Investigation (ROI) in Applicant’s case. Under ¶ E3.1.20 of the 
Directive, a DOD personnel background report of investigation may be received in 
evidence and considered with an authenticating witness, provided it is otherwise admissible 
under the Federal Rules of Evidence. The interview summary did not bear the 
authentication required for admissibility under ¶ E3.1.20. 
 
 In ISCR Case No. 15-01807 decided on April 19, 2017, the Appeal Board held that it 
was not error for an administrative judge to admit and consider a summary of personal 
subject interview in the absence of any objection to it or any indication that it contained 
inaccurate information. The applicant in that case had objected on appeal to the accuracy 
of some of the information in a FORM, but had not objected to the interview summary or 
indicated that it was inaccurate in any aspects when she responded to the FORM. 
 
                                                 
1 Application of the AGs that were in effect as of the issuance of the SOR would not change my decision in this 
case. 
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 Like the applicant in ISCR Case No. 15-01807, Applicant was provided a copy of the 
FORM and advised of his opportunity to submit objections or material that he wanted the 
administrative judge to consider. In a footnote, the FORM advised Applicant of the 
following: 
 
IMPORTANT NOTICE TO APPLICANT: The attached summary of your 
Personal Subject Interview is being provided to the Administrative Judge for 
consideration as part of the record evidence in this case. In your response to 
this File of Relevant Material (FORM), you can comment on whether [the] 
PSI summary accurately reflects the information you provided to the 
authorized OPM investigator(s) and you can make any corrections, additions, 
deletions, and updates necessary to make the summary clear and accurate. 
Alternatively, you can object on the ground that the report is unauthenticated 
by a Government witness. If no objections are raised in your response to the 
FORM, or if you do not respond to the FORM, the Administrative Judge may 
determine that you have waived any objections to the admissibility of the 
summary and may consider the summary as evidence in your case. 
 
Concerning whether Applicant understood the meaning of authentication or the legal 
consequences of waiver, Applicant’s pro se status does not confer any due process rights 
or protections beyond those afforded him if he was represented by legal counsel. He was 
advised in ¶ E3.1.4 of the Directive that he may request a hearing. In ¶ E3.1.15, he was 
advised that he is responsible for presenting evidence to rebut, explain, or mitigate facts 
admitted by him or proven by Department Counsel and that he has the ultimate burden of 
persuasion as to obtaining a favorable clearance decision. While the Directive does not 
specifically provide for a waiver of the authentication requirement, Applicant was placed on 
sufficient notice of his opportunity to object to the admissibility of the interview summary, to 
comment on the interview summary, and to make any corrections, deletions, or updates to 
the information in the report. He was advised that if he did not respond, the interview 
summary may be considered as evidence in his case. Applicant did not state any concerns 
or objections to the information in the PSI when he responded to the FORM. I cannot 
presume without any evidence that Applicant failed to understand his due process rights or 
obligations under the Directive or that he did not want the summary of his interview 
considered in his case. It is reasonable to conclude that he read the FORM footnote and 
waived any objection to the interview summary. Accordingly, I accepted Item 8 in the 
record, subject to issues of relevance and materiality in light of the entire record, including 
Applicant’s admissions to some of the delinquent debts alleged in the SOR. 
 
Findings of Fact 
 
 The SOR alleges under Guideline F that, as of October 3, 2016, Applicant was in 
default on $38,944 in student loan debt (SOR ¶¶ 1.a-1.e) and delinquent on five other 
accounts totaling $7,822 (SOR ¶¶ 1.f-1.j). When he answered the SOR (Item 3), Applicant 
denied that he was indebted on his federal student loans as alleged. He explained that he 
had completed a nine-month loan rehabilitation program. He admitted owing the delinquent 
debts in SOR ¶¶ 1.f-1.g and 1.i-1.j, but indicated that he now had the income to make 
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payments on the four past-due accounts. Applicant denied the $39 utility service debt 
alleged in SOR ¶ 1.h because it had been paid in full as of January 20, 2016. 
 
 After considering the FORM, which includes Applicant’s response to the allegations 
as Item 3, and AEs A-G, I make the following findings of fact. 
 
 Applicant is 34 years old, married, and has a two-year-old daughter. Born abroad, 
he immigrated to the United States as an infant in 1983. He became a U.S. naturalized 
citizen in June 2003 on his own application. He has a bachelor’s degree conferred in June 
2012 from a polytechnic university. He has worked as a research engineer for his defense-
contractor employer since June 2015. (Item 4.) 
 
 Applicant paid for his undergraduate education in part through federal student loans. 
Between March 2008 and September 2011, he obtained ten federal student loans totaling 
approximately $47,508. (Items 3, 5.) His parents could not afford to pay for his college. His 
father was a maintenance worker who held three part-time jobs, including at a golf course, 
and his mother was unemployed. His parents’ federal adjusted gross income for 2011 was 
only $21,648. (AE G.) 
 
 Applicant and his spouse married in July 2012. Applicant was unemployed that 
summer. From September 2012 to June 2015, he worked as a manufacturing engineer for 
an aerospace company. There is no evidence that he needed a security clearance for that 
employment. (Items 4, 8.) Applicant’s income was insufficient to cover all of his financial 
obligations, and he defaulted on his federal student loans as well as on some credit cards. 
(Items 5-8.) 
 
 On May 30, 2015, Applicant entered into an agreement to rehabilitate his ten federal 
student loans, which included the loans in SOR ¶¶ 1.a-1.e. Based on his reported income, 
he was obligated to pay only $5 per month for nine months to remove his loans from 
default. (Item 3.) 
 
 In June 2015, Applicant began his defense-contractor employment. On June 9, 
2015, he completed and certified to the accuracy of a Questionnaire for National Security 
Positions (SF 86). In response to inquiries concerning any delinquency involving routine 
accounts, Applicant disclosed that he owed approximately $58,693 in defaulted federal 
student loan debt. He attributed his delinquency to a period of unemployment and being 
the sole financial provider for his household with two dependents (spouse and daughter). 
Although his student loans were in default, he had established a rehabilitation program, 
and he submitted the first of his monthly installment payments toward rehabilitating his 
loans. He disclosed no other past-due debts. (Item 4.) 
 
 A check of Applicant’s credit on June 25, 2015, revealed that he also owed charged-
off credit card debts of $1,681 from February 2010 (SOR ¶ 1.i) and $416 from September 
2012 (SOR ¶ 1.g) and credit card collection debts of $4,920 from April 2009 (SOR ¶ 1.j) 
and $766 from July 2009 (SOR ¶ 1.f). In May 2015, Applicant had obtained a car loan for 
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$19,980, to be repaid at $344 per month. He was making timely payments of $192 per 
month on another car loan obtained for $11,484 in April 2014. (Item 5.)  
 
 On January 8, 2016, Applicant was interviewed by an authorized investigator for the 
Office of Personnel Management (OPM). About his delinquent student loans, Applicant 
indicated that he had not been able to make any payments because of low-paying jobs. He 
was uncertain about the amount due on his student loans and provided only an estimate 
on his SF 86. He expressed an intention to apply for forbearance of his student loans and 
to work on a future payment plan for the loans. He denied recall of any other financial 
delinquencies. At the conclusion of his interview, he was informed about the negative credit 
card accounts on his record. He acknowledged three credit card debts (the credit card debt 
in SOR ¶ 1.f under the name of the original creditor, the debt in SOR ¶ 1.i, and a retail 
charged-off debt not alleged), which he incurred in college for miscellaneous purchases. 
He indicated that he would contact his creditors to arrange repayment plans. He did not 
recognize the debt in SOR ¶ 1.j. (Item 8.) 
 
 As of March 2016, Equifax was reporting that Applicant had five student loans in 
forbearance for $54,908. (Item 6.) A more recent credit report of December 2016 showed 
that his federal student loans were in deferment for $64,025. (Item 7.) Available loan 
rehabilitation documents show that Applicant’s loans would no longer be in forbearance on 
January 20, 2017. (Item 3.) The file does not shed any light on the amount of his scheduled 
payments for his student loans when they came out of deferment. 
 
 Also as of March 2016, the $766 credit card collection debt (SOR ¶ 1.f), the $416 
charged-off credit card debt (SOR ¶ 1.g), and a $39 collection debt (SOR ¶ 1.h) were 
reported as past due. Available documentation shows that the $39 debt was paid in 2016. 
(Item 3.) Although the consumer credit debts in SOR ¶¶ 1.i and 1.j were no longer on his 
credit record (Item 6), Applicant had made no payments on them or on the debts in SOR 
¶¶ 1.f and 1.g as of late October 2016. (Item 3.) 
 
 Applicant and his spouse purchased their home in June 2016. They obtained a joint 
30-year conventional mortgage loan for $324,022. As of November 2016, the loan was 
being repaid on time at $2,205 per month. In August 2016, they opened a joint credit card 
account with a $2,000 credit limit. As of November 2016, the account had a $1,296 
balance and was rated as current. In October 2016, Applicant opened a credit-card 
account which had a current balance of $716.  He was also repaying his May 2015 car loan 
according to terms. The car loan obtained in April 2014 was paid off in October 2015. (Item 
7.) 
 
 In response to the SOR, Applicant admitted on October 28, 2016, that he had made 
no payments on the delinquent accounts in SOR ¶¶ 1.f, 1.g, 1.i, and 1.j. However, he 
indicated that his household income has almost doubled with his spouse obtaining 
employment, that he is now able to pay off the debts, and that he is in the process of 
establishing repayment plans for the four debts. (Item 3.) 
 
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 Applicant received the FORM on January 19, 2017, and he learned that the 
Government was concerned about his willingness to repay his student loans, given that he 
had made payments totaling only $45 on the loans, and that the Government had issues 
with the lack of evidence concerning efforts to resolve his credit card delinquencies. 
Applicant indicated in response on February 19, 2017,2 that he had become more 
financially responsible since graduating from college and becoming employed. (AE A.)  
 
 As of February 2017, Applicant’s take-home pay was approximately $1,800 every 
two weeks. (AEs B-C.) His spouse’s take-home pay was $1,906 for 80 hours. (AEs E-F.) 
Their household budget showed $3,502 in discretionary income based on gross earnings. 
Their monthly household bills include $2,205 for the mortgage loan, $700 for child care, 
$118 for mobile phones, $433 in utility costs (water, trash, electricity, and gas), $344 for his 
car payment, and $560 toward their two new credit cards. Their budget did not account for 
grocery costs, clothing, or for personal care expenses for himself, his spouse, or his 
daughter. (AE D.) It also did not reflect any payments toward his old credit-card 
delinquencies or student loans. They were paying $3,880 every trimester to a different 
university than Applicant attended, although it is unclear whether it was for tuition or 
student loans. 
  
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(a), 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. 
 
The protection of the national security is the paramount consideration. AG ¶ 2(b) 
requires that “[a]ny doubt concerning personnel being considered for national security 
eligibility will be resolved in favor of the national security.” In reaching this decision, I have 
drawn only those conclusions that are reasonable, logical, and based on the evidence 
contained in the record. 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 
                                                 
2 The date of his statement, “19 February, 2012,” is an obvious error, given Applicant referenced his home 
loan, which he obtained in June 2016. 
 
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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 EO 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 articulated in AG ¶ 18: 
 
Failure 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 or 
sensitive information. Financial distress can also be caused or exacerbated 
by, and thus can be a possible indicator of, other issues of personnel security 
concern such as excessive gambling, mental health conditions, substance 
misuse, or alcohol abuse or dependence. An individual who is financially 
overextended is at greater risk of having to engage in illegal or otherwise 
questionable acts to generate funds. Affluence that cannot be explained by 
known sources of income is also a security concern insofar as it may result 
from criminal activity, including espionage. 
 
 The Government met its burden of establishing a prima facie case for 
disqualification because Applicant defaulted on his student loans obtained between March 
2008 and September 2011 for approximately $47,508. Four credit card debts totaling 
$7,783 were placed for collection or charged off. Three disqualifying conditions under AG ¶ 
19 are implicated: AG ¶ 19(a), “inability to satisfy debts;” AG ¶ 19(b), “unwillingness to 
satisfy debts regardless of the ability to do so,” 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 
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reasonably apply. His student loans were in default status until early 2016. His failure to 
make any effort to address his old credit card delinquencies, despite having the income to 
make some payments, constitutes a persistent pattern of questionable financial judgment. 
 
 Applicant’s delinquencies were caused largely by insufficient income, which is a 
circumstance contemplated within AG ¶ 20(b). There has been no activity on the account in 
SOR ¶ 1.f since July 2009 when the creditor placed Applicant’s account for collection for 
$766. Likewise, the $4,920 debt in SOR ¶ 1.j and the $1,681 debt in SOR ¶ 1.i became 
delinquent when Applicant was in college. Applicant was unemployed during the summer 
before his account in SOR ¶ 1.g was charged off. Absent a hardship deferment, he would 
have been required to start repaying his student loans in 2013. He was employed as a 
manufacturing engineer at that time, but there is no evidence that his spouse was 
contributing to the household income. AG ¶ 20(b) has some applicability. It provides: 
 
(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, a death, divorce or separation, clear 
victimization by predatory lending practices, or identity theft), and the 
individual acted responsibly under the circumstances. 
 
 AG ¶ 20(b) also requires that an individual act responsibly under the circumstances. 
Applicant began the process of rehabilitating his student loans before he applied for a 
security clearance. Shortly thereafter, he started his present employment. The file contains 
no information about his starting wage or his expenses at the time. During his January 
2016 subject interview, Applicant was reminded of some credit card delinquencies, 
including the undisputed debts in SOR ¶¶ 1.f and 1.i. He indicated at that time that he 
would contact the creditors and arrange repayment terms. By late October 2016, 
Applicant’s and his spouse’s household income had doubled because his spouse had 
become employed. He indicated that he was in position to make the payments necessary 
to remove his old credit card debts from collection status. He also explained that he was in 
the process of communicating with his creditors. There is no proof that he had any 
repayment plans in place for those debts as of February 2017 despite a claimed 
discretionary monthly household income exceeding $3,000. His household budget did not 
include any payments for his student loans or his credit card delinquencies. Applicant has 
not acted fully responsibly with regard to addressing these legitimate debts. 
 
 Applicant’s rehabilitation of his student loans is considered a good-faith effort to 
address his default of his student loans. AG ¶ 20(d), ‘the individual initiated and is adhering 
to a good-faith effort to repay overdue creditors or otherwise resolve debts,” has some 
applicability. However, the evidence falls considerably short of establishing AG ¶ 20(c), “the 
person has received or is receiving counseling for the problem from a legitimate and 
credible source, such as a non-profit credit counseling service, and there are clear 
indications that the problem is being resolved or is under control.” Applicant has no track 
record of payments toward his considerable student loan balances ($64,025 as of October 
2016) beyond $45 paid over nine months to rehabilitate them. Neither AG ¶ 20(c) nor AG ¶ 
20(d) apply in mitigation of his ongoing disregard of his old credit card debts. 
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 Applicant’s financial situation has improved. He and his spouse obtained a $324,002 
mortgage loan in June 2016, and he has made his car payments on time since he obtained 
a loan for $19,980 in May 2015. I cannot ignore Appeal Board precedent, which requires 
that “a person acts in a way that shows reasonableness, prudence, honesty, and 
adherence to duty or obligation.”3 To improve his credit score, Applicant opened two new 
credit cards (one jointly and one individually) since August 2016 on which he owed 
balances of $1,296 and $712 as of late November 2016 while his old credit card debts 
remain unresolved. Even though his old credit card debt totals only $7,783, concerns 
persist about his financial judgment, given he has given priority to reestablishing his own 
credit over repaying his old credit card debts. More documented progress is also needed 
toward paying his student loans. 
 
Whole-Person Concept 
 
In assessing the whole person, 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(d).4 The analysis under Guideline F is incorporated in my whole-
person analysis. Some of the factors in AG ¶ 2(d) were addressed under that guideline, but 
some warrant additional comment. 
 
 Applicant has the burden of presenting evidence of relevant facts and 
circumstances to show why he should be granted security clearance eligibility 
notwithstanding the delinquent debt information on his credit record. He chose to rely on 
the written record. It is not enough in mitigation to assert an intention to resolve his old 
credit card delinquencies. In response to the FORM, he provided documentation showing 
that he has the income to make payments on his student loans and his old credit-card 
delinquencies but no evidence of any payments. 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 
                                                 
3 The DOHA Appeal Board stated in ISCR Case No. 07-06482, decided on May 21, 2008, in part: 
 
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.” See, e.g., ISCR Case No. 05-01920 at 5 (App. Bd. Mar. 1, 2007). 
However, an applicant is not required, as a matter of law, to establish that he has paid off 
each and every debt listed in the SOR. See, e.g., ISCR Case No. 02-25499 at 2 (App. Bd. 
Jun. 5, 2006). All that is required is that an applicant demonstrate[s] that he has “. . . 
established a plan to resolve his financial problems and taken significant actions to 
implement that plan.” See, e.g., ISCR Case No. 04-09684 at 2 (App. Bd. Jul. 6, 2006). 
 
4 The factors under AG ¶ 2(d) 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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1399, 1401 (9th Cir. 1990). Applicant’s candor on his SF 86 about his student-loan default 
weighs in his favor. Yet, based on the evidence before me, I am unable to conclude that it 
is clearly consistent with the national interest to grant security clearance eligibility for 
Applicant. 
 
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, Financial Considerations:  Against Applicant 
 
 Subparagraphs 1.a-1.j:   Against Applicant 
 
Conclusion 
 
In light of all of the circumstances, 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. 
 
 
_____________________ 
Elizabeth M. Matchinski 
Administrative Judge