ISCR Case No. 25-01592

______________ ______________ DEFENSE LEGAL SERVICES AGENCY DEFENSE OFFICE OF HEARINGS AND APPEALS In the matter of: Applicant for Security Clearance ) ) ) ) ) ISCR Case No. 25-01592 Appearances For Government: Tovah A. Minster, Esq., Department Counsel For Applicant: Pro Se 09/29/2026 Decision HOGAN, Erin C., Administrative Judge: This case involves security concerns raised under Guideline F, Financial Considerations, and Guideline E, Personal Conduct. Eligibility for access to classified information is denied. Statement of the Case Applicant submitted a security clearance application (SCA) on March 19, 2025. (Government Exhibit (GE) 1). On March 17, 2026, the Defense Counterintelligence and Security Agency (DCSA) sent him a Statement of Reasons (SOR) alleging security concerns under Guidelines F and E. The DCSA acted under Executive Order (EO) 10865, Safeguarding Classified Information within Industry (February 20, 1960), as amended; Department of Defense (DOD) Directive 5220.6, Defense Industrial Personnel Security Clearance Review Program (January 2, 1992), as amended (Directive); and the adjudicative guidelines (AG) implemented by the DOD on June 8, 2017. On May 1, 2026, Applicant timely answered the SOR and requested a hearing before an administrative judge. Department Counsel forwarded the case to the DOHA Hearing Office on May 26, 2026. The case was assigned to me on June 2, 2026. On June 5, 2026, a notice was issued scheduling the hearing on July 21, 2026, via video- teleconference. The hearing was held on that date. The Government offered ten exhibits, which were admitted in evidence as Government Exhibits (GE) 1-10 without objection.

Applicant testified. The record was held open until August 1, 2026, to allow Applicant to submit additional exhibits. He timely submitted a 16-page exhibit which was marked and admitted as Applicant Exhibit (AE) A without objection. The transcript (Tr.) was received on July 30, 2026. Some details in the decision were excluded to protect Applicant’s right to privacy. Specific information is available in the cited exhibits. Findings of Fact Applicant, age 39, has been an employee of a government contractor since October 2023 and is seeking a security clearance. This is his first time applying for a security clearance. He has no military service. He has a bachelor’s degree. He has been married since 2014 and has an eight-year-old son. (Tr. 15, 19-21; GE 1) Guideline F – Financial Considerations Under Guideline F, Financial Considerations, the SOR alleged Applicant had five delinquent accounts. Applicant admits all the allegations under Guideline F. The SOR allegations include: SOR ¶ 1.a: a $36,237 delinquent credit card account that was placed for collection. (GE 2 at 4; GE 4 at 12: GE 5 at 3; GE 6 at 2); SOR ¶ 1.b: a $20,199 delinquent credit card account that was placed for collection. (GE 2 at 5; GE 4 at 12; GE 5 at 3; GE 6 at 2); SOR ¶ 1.c: a $8,342 delinquent credit card account that was placed for collection. (GE 2 at 4; GE 3; GE 4 at 12; GE 5 at 4; GE 6 at 2); SOR ¶ 1.d: a $3,066 delinquent credit card account that was placed for collection. (GE 2 at 5; GE 3; GE 4 at 12; GE 5 at 4; GE 6 at 2); and SOR ¶ 1.e: a $1,017 delinquent credit card account that was placed for collection. (GE 2 at 5; GE 3; GE 4 at 12; GE 5 at 4; GE 6 at 2). The total balance of delinquent debt is approximately $68,861. In his response to the SOR, Applicant indicated that all of these debts became delinquent in 2019. During that time, his wife handled the household finances. He was not involved in managing these accounts. He only used a debit card. He was not aware that these accounts became delinquent until the investigator conducting his security clearance background investigation confronted him about these delinquent debts during his June 13, 2025, interview. Once Applicant learned of these accounts, he assumed the role of managing the household finances. All current obligations are paid on time. He has had no new delinquent accounts since 2019. He is the sole income earner in his household. (Response to SOR) 2

In 2023, Applicant and his family moved to another state where his current job is located. He and his wife own a home in the previous state where they lived. They did not put the house up for sale when they moved to their current location. They were debating whether to rent it or to sell it. His wife was reluctant to sell the house. They recently put the house up for sale. Applicant claims the value is between $400,000 to $430,000. His current mortgage balance is approximately $100,000. He anticipates he will receive approximately $300,000 in proceeds after the sale of the house. Putting the house on the market took longer than expected because repairs needed to be done on the property before it was put up for sale. Once the house sells, Applicant testified that he will be able to pay off all the delinquent debts with money made from the sale. (Tr.13-18, 29; Response to SOR; AE A at 1-11, 13) However, at the close of record, none of the debts alleged in the SOR, have been paid, either in part or in full. In response to DOHA Interrogatories, dated October 2, 2025, Applicant provided a monthly budget. His net monthly income was approximately $5,543. His total monthly expenses to include the mortgage on his previous home was approximately $5,106. He has a net remainder each month of $437. (GE 2 at 9) Personal Conduct Under the Personal Conduct concern, the SOR alleged three arrests and two falsification allegations. The arrests include: SOR ¶ 2.a: In approximately August 2002, Applicant was charged with multiple counts of Felony Burglary, Felony Criminal Damage to Property, and Felony Theft by Taking. He was convicted of five counts of felony burglary and three counts of felony theft by taking. (GE 4 at 7-8; Ge 7 at 8-14); SOR ¶ 2.b: In approximately September 2013, Applicant was charged with Leaving the Scene of an Accident. Obstruction of Officers, and Reckless Driving. He was convicted of Reckless Driving. (GE 4 at 10-11; GE 7 at 16-17; GE 8); and SOR ¶ 2.c: In approximately February 2018, he was charged with Felony Attempt or Conspire to Commit Offense Involving Explosives, Destructive Device, etc. He was convicted of three counts of misdemeanor Reckless Conduct and sentenced to three years’ probation. (GE 4 at 4-7; GE 7 at 17-21; GE 9). Regarding the offense alleged in SOR ¶ 2.a, Applicant was 15 years old at the time of his 2002 arrest. He explained that he had permission to go fishing at a private club where his grandparents were members. He would invite a friend who was two years older to come fishing with him. He claims that his friend would sometimes wander around while he was fishing. Applicant was unaware that his friend was stealing items from the clubhouse. His friend was caught after he stole a small boat. Applicant told his friend to return the boat, which he did. Applicant claims that he was implicated because he was present and his friend was his guest. Applicant appeared in juvenile court with his parents. He was sentenced to probation and ordered to pay restitution. He served the terms of his 3

sentence. He does not associate with anyone engaged in criminal activity since this arrest, which occurred over 24 years ago. (Tr. 38-45; Response to SOR; GE 4 at 7-8; GE 7 at 8-14) In September 2013, Applicant was at a gas station filling his car with gas. When he backed out, he thought he hit one of the metal posts that protect the fuel pumps. He drove away. He later determined that he had not hit a metal pump but hit a car. The driver of the other car called police and informed them that his car was hit by another driver who then drove away. The police were able to locate Applicant’s home address based on his credit card receipt for his purchases at the gas station. The police went to his home, and he was arrested and charged with Leaving the Scene of an Accident, Obstruction of Officers, and Reckless Driving. He was convicted of Reckless Driving, a misdemeanor. The charge was nolle prossed. Applicant paid a fine and completed a defensive driving course. Applicant stated that this occurred over 13 years ago and did not involve alcohol, firearms, explosives, or domestic violence. He has not had similar incidents since that date. (Tr. 45-48; Response to SOR; GE 4 at 10-11; GE 10 at 171) When Applicant was a child, his grandfather, who worked in the space program, got him interested in model rockets. In February 2018, Applicant and a friend were testing model rockets in his driveway between 10 and 10:30 pm. He made a measurement error which caused the rockets to generate more noise and debris than intended. A neighbor called police. He said the model rockets he was testing did not constitute legal explosives under the state law where he was residing. He was charged with Felony Attempt to Conspire to Commit Offense Involving Explosives, Destructive Device. He was convicted of three counts of misdemeanor Reckless Conduct and sentenced to three years’ probation. He successfully completed the terms of his probation. (Tr. 48-60; Response to SOR; GE 4 at 4-7) In his response to the SOR, Applicant indicated that the matter was resolved under his state’s First Offender Act. Under this act, the disposition of the offense is not considered a conviction. The offense would also be sealed by operation of law from non- criminal justice use. He accepted the plea because he had a newborn child and his family’s stability was more important to him than prolonged litigation. During the hearing, he admitted that he was reckless and did not show consideration to his neighbors. Applicant injured his left leg during the explosion and went to the hospital the night of the incident. After the date of the incident, he gave up his model rocketry hobby and disposed of all of his related equipment. (Tr. 51-62; Response to SOR; GE 4 at 4-7; GE 10 at 18) The falsification allegations include: SOR ¶ 2.d: Applicant falsified material facts on an Electronic Questionnaire for Investigations Processing (e-QIP), certified by him on March 19, 2025, in response to “Section 22-Police Record. (EVER) – Have you EVER been changed with any felony offense?” Applicant answered, “No.” He deliberately failed to disclose his felony arrests which were alleged in SOR ¶¶ 2.a and 2.c, above. (GE 1 at 25) 4

SOR ¶ 2.e: Applicant falsified material facts on an e-QIP certified by him on March 19, 2025, in response to “Section 26-Financial Record – In the last seven (7) years, [have] you had any account or credit card suspended, charged off, or cancelled for failing to pay as agreed?” He answered “No” and deliberately failed to disclose the information alleged in SOR ¶¶ 1.a and 1.c.(GE 1 at 28) Applicant denied both falsification allegations. With regard to SOR ¶ 2.d, he thought that he did not have to list the August 2022 arrest (SOR ¶ 2.a) because he was a juvenile and the case was adjudicated in juvenile court. He did not believe that his juvenile record was considered an adult felony and his juvenile records were sealed when he became an adult. He did not list the February 2018 arrest (SOR ¶ 2.c) because he was advised by his lawyer that he did not have to list this offense because the First Offender Act disposition resulted in no legal conviction and the record was sealed by law from non-criminal justice use. While he may have interpreted it incorrectly, he relied on this legal advice in good-faith when completing the e-QIP. (Tr. 42-44, 60-61; Response to SOR) During his personal subject interview on June 13, 2025, when the investigator brought up these two felony arrests, Applicant cooperated. He explained why he did not list these offenses and cooperated with the investigator about each offense. (Response to SOR; GE 4) SOR ¶ 2.e alleged Applicant deliberately falsified material facts on his March 2025 e-QIP application in response to Section 26 - Financial Record by deliberately failing to list his delinquent accounts within the past seven years that were turned over to a collection agency or were charged off. The SOR allegation alleges he deliberately failed to list the debts alleged in SOR ¶¶ 1.a and 1.c. Applicant was unaware of these delinquent accounts at the time he completed his March 2025 e-QIP. His wife handled the finances at the time. When confronted by the investigator conducting his background investigation, Applicant told the investigator that he had no idea that these accounts were past due. He could not provide any details on the debts because he not aware of them until the investigator disclosed them during his background investigation interview (Tr. 23, 36-38; Response to SOR; GE 4 at 12) Whole-Person Factors Ms. R.M., Applicant’s manager, provided a statement on his behalf. She notes that she has consistently observed him demonstrate “exceptional integrity, professionalism and dedication to his work.” He takes ownership of his responsibilities and has a strong work ethic. He delivers high-quality results, is supportive of his colleagues, and represents the organization well. His performance reviews have consistently reflected his strong contributions, and the recognition and awards he received are well deserved. She has no reservations recommending him for a security clearance because he is a trustworthy, hard-working professional who brings commitment and sound character to every role. (AE A at 12) In March 2025, Applicant received a Mission Excellence Award from his current employer. (AE A at 14) 5

Policies “[N]o one has a ‘right’ to a security clearance.” (Department of the Navy v. Egan, 484 U.S. 518, 528 (1988)). As Commander in Chief, the President has the authority to “control access to information bearing on national security and to determine whether an individual is sufficiently trustworthy to have access to such information.” (Egan at 527). The President has authorized the Secretary of Defense or his designee to grant applicants eligibility for access to classified information “only upon a finding that it is clearly consistent with the national interest to do so.” (EO 10865 § 2) Eligibility for a security clearance is predicated upon the applicant meeting the criteria contained in the AG. These guidelines are not inflexible rules of law. Instead, recognizing the complexities of human behavior, an administrative judge applies these guidelines in conjunction with an evaluation of the whole person. An administrative judge’s overarching adjudicative goal is a fair, impartial, and commonsense decision. An administrative judge must consider all available and reliable information about the person, past and present, favorable and unfavorable. The Government reposes a high degree of trust and confidence in persons with access to classified information. This relationship transcends normal duty hours and endures throughout off-duty hours. Decisions include, by necessity, consideration of the possible risk that the applicant may deliberately or inadvertently fail to safeguard classified information. Such decisions entail a certain degree of legally permissible extrapolation about potential, rather than actual, risk of compromise of classified information. Clearance decisions must be made “in terms of the national interest and shall in no sense be a determination as to the loyalty of the applicant concerned.” (EO 10865 § 7). Thus, a decision to deny a security clearance is merely an indication the applicant has not met the strict guidelines the President and the Secretary of Defense have established for issuing a clearance. Initially, the Government must establish, by substantial evidence, conditions in the personal or professional history of the applicant that may disqualify the applicant from being eligible for access to classified information. The Government has the burden of establishing controverted facts alleged in the SOR. (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. (ISCR Case No. 15-01253 at 3 (App. Bd. Apr. 20, 2016)). Once the Government establishes a disqualifying condition by substantial evidence, the burden shifts to the applicant to rebut, explain, extenuate, or mitigate the facts. (Directive ¶ E3.1.15). An applicant has the burden of proving a mitigating condition, and the burden of disproving it never shifts to the Government. (ISCR Case No. 02-31154 at 5 (App. Bd. Sep. 22, 2005)) 6

An applicant “has the ultimate burden of demonstrating that it is clearly consistent with the national interest to grant or continue his security clearance.” (ISCR Case No. 01- 20700 at 3 (App. Bd. Dec. 19, 2002)). “[S]ecurity clearance determinations should err, if they must, on the side of denials.” (Egan, 484 U.S. at 531; AG ¶ 2(b)) Analysis Guideline F: Financial Considerations The concern under this guideline is set out in AG ¶ 19: 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, 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. This concern is broader than the possibility that a person might knowingly compromise classified information to raise money. It encompasses concerns about a person’s self-control, judgment, and other qualities essential to protecting classified information. A person who is financially irresponsible may also be irresponsible, unconcerned, or negligent in handling and safeguarding classified information. (ISCR Case No. 11-05365 at 3 (App. Bd. May 1, 2012)). AG ¶ 19 notes several disqualifying conditions that could raise security concerns. The disqualifying conditions that are relevant to Applicant’s case are: (a) inability to satisfy debts; and (c) a history of not meeting financial obligations. AG ¶¶ 19(a) and 19(c) apply with regard to Applicant’s delinquent debts which were alleged in SOR ¶¶ 1.a – 1.e. The total approximate amount of the debt is $68,861. These delinquent debts show an inability to satisfy debts and a history of not meeting financial obligations. The Appeal Board in ISCR Case No. 10-04641 at 4 (App. Bd. Sept. 24, 2013) explained an applicant’s responsibility for proving the applicability of mitigating conditions is as follows: 7

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). AG ¶ 20 describes conditions that could mitigate security concerns. The following are potentially applicable in this case: (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, a death, divorce, or separation, clear victimization by predatory lending practices, or identity theft), and the individual acted responsibly under the circumstances; (c) the individual has received or is receiving financial 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 under control; and (d) the individual initiated and is adhering to a good-faith effort to repay overdue creditors or otherwise resolve debts. AG ¶ 20(a) does not apply because Applicant’s financial issues were ongoing at the close of the record. AG ¶ 20(b) applies, at least in part, because Applicant’s wife opened the credit card accounts alleged in the SOR without Applicant’s knowledge. This was a circumstance beyond Applicant’s control. Upon discovering the additional credit cards his wife opened, Applicant took control over the household finances. While this was the most responsible thing to do, he should have been more proactive reviewing the family finances to prevent these delinquent credit card accounts from happening. He could have attempted to settle some of the debts with lower balances as well. For this reason, this mitigating condition is given less weight. 8

AG ¶ 20(c) does not apply. Applicant has not taken financial counseling and there were no clear indications that the problem was being resolved or under control at the close of the record. AG ¶ 20(d) partially applies because Applicant intends to pay off all the delinquent debts with the money received from the sale of his home. However, he had just put the house on the market, and it is not clear when the house will sell. A promise to pay in the future does not mitigate the concerns under financial considerations. While Applicant has a reasonable plan to pay off all the delinquent accounts once his house is sold, one cannot predict when the house will sell and for what price. There is insufficient evidence to mitigate the concerns raised under Financial Considerations. 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 or sensitive information. Of special interest is any failure to cooperate or provide truthful and candid answers during national security investigative or adjudicative processes. The following disqualifying conditions under AG ¶ 16 potentially apply to Applicant’s case: AG ¶ 16(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 national security eligibility or trustworthiness, or award fiduciary responsibilities; AG ¶ 16(c) credible adverse information in several adjudicative issue areas that is not sufficient for an adverse determination under any other single guideline, but which, when considered as a whole, supports a whole-person assessment of questionable judgment, untrustworthiness, unreliability, lack of candor, unwillingness to comply with rules and regulations or other characteristics indicating the individual may not properly safeguard classified or sensitive information; and AG ¶ 16(e) personal conduct, or concealment of information about one’s conduct that creates a vulnerability to exploitation, manipulation, or duress by a foreign intelligence entity or other individual or group. Such conduct includes: (1) engaging in activities which, if known, could affect the person’s personal, professional, or community standing. 9

AG ¶ 16(a) applies with regard to SOR ¶¶ 2.d and 2.e. Applicant deliberately failed to list the extent of his felony arrests in 2002 and 2018 in response to the Section 22- Police Record on his March 19, 2025, e-QIP application. He also deliberately failed to list his delinquent accounts that were placed for collection in response to Section 26 – Financial Record on his March 19, 2025, e-QIP application. AG ¶¶ 16(c) and 16(e) apply towards the offenses alleged in SOR ¶¶ 2.a - 2.c. When Applicant was younger, he engaged in conduct that led to three arrests and charges against him. His actions might therefore have also been alleged under Guideline J (Criminal Conduct). This raises concerns about his judgment, trustworthiness and reliability and raised questions about his ability to properly safeguard classified information. His past conduct as alleged in SOR ¶¶ 2.a - 2.c made Applicant vulnerable to exploitation, manipulation or duress because it could potentially adversely affect his professional standing. Under Guideline E, the following mitigating conditions apply in Applicant’s case: AG ¶ 17(b) the refusal or failure to cooperate, omission, or concealment was caused or significantly contributed to by advice of legal counsel or of a person with professional responsibilities for advising or instructing the individual specifically concerning security processes. Upon being made aware of the requirement to cooperate or provide the information, the individual cooperated fully and truthfully; AG ¶ 17(c) the offense is so minor, or so much time has passed, or the behavior is so infrequent, or it happened under such unique circumstances that it is unlikely to recur and does not cast doubt on the individual’s reliability, trustworthiness, or good judgment; and AG ¶ 17(e) the individual has taken positive steps to reduce or eliminate vulnerability to exploitation, manipulation, or duress. AG ¶ 17(b) applies to the alleged falsifications in SOR ¶ 2.d for failing to list that he was charged with a felony offense. Applicant did not think he was required to list the 2002 offense alleged in SOR ¶ 2.a because it happened when he was juvenile, the case was adjudicated in juvenile court, and the records were sealed when he reached adulthood. He testified that he was advised by his attorney that he was not required to list his February 2018 arrest and charge alleged in SOR ¶ 2.b because he was tried under his state’s First-Time Offenders Act and that it was not considered a conviction. In both instances, Applicant was provided legal advice about these past offenses which led him to believe that he did not need to list them. Upon being advised by the investigator conducting his background investigation that he needed to disclose and discuss these offenses, he fully cooperated with the investigation. This mitigating condition applies. AG ¶ 17(c) applies with Applicant’s past offenses alleged in SOR ¶¶ 2.a – 2.c. The offense in 2002 happened more than 24 years ago. The offense in 2013 occurred more 10

than 13 years ago, and his most recent offense occurred in February 2018 more than eight years ago. He completed all the terms of his sentences to include probation. There is no evidence of additional offenses since that time. While Applicant had problems in the past as a teenager and as a young man, he has matured and turned his life around. He has a favorable employment record with his current employer. AG ¶ 17(e) applies because Applicant cooperated fully during his background investigation. He fully disclosed his past arrest history and has not committed an offense for over eight years. Once the investigator informed him of the delinquent accounts, he fully cooperated and took over the handling of the finances from his wife. He is no longer vulnerable to exploitation, manipulation, or duress. Considering all of the evidence, the security concerns under Personal Conduct are mitigated. Whole-Person Concept Under AG ¶ 2(c), the ultimate determination of whether the granting or continuing of national security eligibility is clearly consistent with the interests of national security must be an overall commonsense judgment based upon careful consideration of the adjudicative guidelines, each of which is to be evaluated in the context of the whole person. An administrative judge should consider the nine adjudicative process factors listed at AG ¶ 2(d): (1) the nature, extent, and seriousness of the conduct; (2) the circumstances surrounding the conduct, to include knowledgeable participation; (3) the frequency and recency of the conduct; (4) the individual’s age and maturity at the time of the conduct; (5) the extent to which participation is voluntary; (6) the presence or absence of rehabilitation and other permanent behavioral changes; (7) the motivation for the conduct; (8) the potential for pressure, coercion, exploitation, or duress; and (9) the likelihood of continuation or recurrence. I have incorporated my comments under Guideline F in my whole-person analysis, and I have considered the factors in AG ¶ 2(d). After weighing the disqualifying and mitigating conditions under Guideline F and evaluating all the evidence in the context of the whole person, I conclude that Applicant mitigated the security concerns raised under personal conduct, but it is too soon to conclude that he mitigated the security concerns raised under financial considerations. This decision should not be construed as a determination that Applicant cannot or will not attain the state of reform necessary for award of a security clearance in the future. With continued efforts to resolve his delinquent debts and maintain his financial responsibility, he may well be able to demonstrate persuasive evidence of his security clearance worthiness. 11

Formal Findings Formal findings 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 Subparagraphs 1.a – 1.e: Against Applicant Paragraph 2, Guideline E: FOR APPLICANT Subparagraphs 2.a – 2.e: For Applicant Conclusion I conclude that it is not clearly consistent with the interests of national security to grant Applicant eligibility for access to classified information. Clearance is denied. Erin C. Hogan Administrative Judge 12