ISCR Case No. 26-00013

______________ ______________ DEFENSE LEGAL SERVICES AGENCY DEFENSE OFFICE OF HEARINGS AND APPEALS _____________________________________

In the matter of: )

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) ISCR Case No. 26-00013

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) Applicant for Security Clearance ) _____________________________________ Appearances For Government: Daniel P. O’Reilley, Esq., Department Counsel For Applicant: Pro Se 09/29/2026 Decision CEFOLA, Richard A. Administrative Judge: Applicant mitigated the security concerns under Guideline E (Personal Conduct), and Guideline G (Alcohol Consumption). Applicant did not mitigate the security concerns under Guideline H (Drug Involvement and Substance Misuse) and Guideline J (Criminal Conduct). Eligibility for access to classified information is denied. Statement of the Case Applicant submitted a Questionnaire for National Security Positions on September 25, 2024 (Questionnaire). On February 11, 2026, the Defense Counterintelligence and Security Agency (DCSA) issued a Statement of Reasons (SOR) to Applicant detailing security concerns under Guideline E (Personal Conduct), Guideline G (Alcohol Consumption), Guideline H (Drug Involvement and Substance Misuse), and Guideline J (Criminal Conduct). The action was taken under Executive Order 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) effective within DoD after June 8, 2017. On March 27, 2026, Applicant responded to the SOR in writing (Answer) and requested that the case be decided on the written record in lieu of a hearing. In his Answer, Applicant admitted to all of the SOR allegations. On August 3, 2026, Department Counsel submitted the Government’s written case in a File of Relevant Material (FORM). A complete copy of the FORM, consisting of Government Exhibits (GE) 1 to 5, and the Government’s arguments in support of the SOR, was received by the Applicant on August 11, 2026. He was afforded 30 days to file objections and submit material to refute, extenuate, or mitigate the security concerns, but did not respond. The case was assigned to me on September 23, 2026, and all exhibits were admitted without objection. Findings of Fact Applicant is 30 years old, has never married, and has no children. He completed high school and some college work. Applicant has been employed by a defense contractor since August 2024 as a software engineer and applied for a security clearance in connection with this employment. (GE 3 at 5, 11-13, 23) SOR Paragraph 1 (Guideline H: Drug Involvement and Substance Misuse) The Government alleged that Applicant is ineligible for a security clearance due to his use of several illegal drugs. The following facts pertain: 1.a. Use of marijuana from November 2014 – November 2025: Applicant admitted to this allegation i n his Answer, but also acknowledged marijuana use through at least March 2026. In his Questionnaire response to the topic in September 2024, Applicant revealed both legal and illegal possession – as well as use – of marijuana over the years, explaining that he had ingested tetrahydrocannabinol (THC) products via all manner of consumption, including “vaporizer, water pipe, rolling paper, edibles, and THC capsules.” He also discussed previously selling and growing marijuana. As of July 31, 2024, however, he declared himself to be “clean of all illegal drugs and controlled substances,” noting, “I quit THC in July before starting at [Defense Contractor] because of the nature of defense work, my health, and my financial stability. I understand that American lives are at state. If I make a mistake while coding good people could die, there is no margin for error.” “[Defense Contractor] is the best thing to ever happen to me. I ABSOLUTELY WILL NOT jeopardize [Defense Contractor’s] or the U.S. government’s reputation or business by using or purchasing any illegal substance or drug…. I do not want it in my life moving forward.” He also noted being “aware of the prohibition of any drug use while holding a national security position” and related that he “plans to abide by that prohibition.” In his November 2025 responses to interrogatories, Applicant revisited his stance on the use of marijuana while employed by a defense contractor. He noted therein that 2

he ingests approximately one half gram of THC extract per week and will continue doing so in the future. “I intend to use THC. I enjoy the effects of consuming it through smoking, vaping, and edibles. I intend to only use in my personal time, never prior to or during work.” (Answer; GE 3 at 36, 39-40; GE 4 at 5-9; GE 5 at 1-3) 1.b. Purchase and use of cocaine from November 2014 – August 2023: Applicant purchased cocaine from fellow college students and used it monthly at social gatherings from approximately 2014 to 2016. He stopped taking the drug when he left school in 2016 but resumed use in 2022 “only 3 or 4 times” until mid-2023. He does not intend to use this substance again in the future because “it is very unhealthy.” Additionally, he no longer associates with the individual he used the drug with from 2022 to 2023 because “he got creepy and I cut all ties.” Applicant was aware this conduct was illegal. (GE 3 at 37, 41; GE 5 at 1-2) 1.c. Purchase and use of various stimulants from November 2014 – March 2017: Applicant purchased Adderall and Vyvanse from fellow college students and used the drugs during mid-terms or final exams from approximately December 2014 to April 2017. Applicant also obtained and used Ritalin during this timeframe “to study, do homework, or at work...sometimes for a party. I estimate 10-20 times.” Applicant further volunteered having taken Ecstasy “at parties, concerts, and music festivals. I used Ecstasy once every couple months…maybe 6-10 times.” Applicant was aware this conduct was illegal. (GE 3 at 37, 41; GE 5 at 1-2) 1.d. Purchase and use of Xanax from June 2015 – May 2018: Applicant initially purchased Xanax from fellow college students until he left school in 2016, after which time he purchased the drug on the dark web using Bitcoin. Applicant used the drug “hundreds of times” for anxiety, but also sometimes at parties, mixing it with alcohol. Applicant was aware this conduct was illegal. In the spring of 2018, he overdosed on Xanax, combined with lysergic acid diethylamide (LSD). He ultimately had a seizure, was hospitalized, and then given anti-psychotic medication. See also SOR ¶ 1.f below. Following the overdose, Applicant saw a psychiatrist, Dr. SN, in May 2018, who prescribed Gabapentin. After Applicant began abusing that drug as well, Applicant’s mother took it away from Applicant. Angered by this, Applicant reacted by flying to Asia without telling his family. He smuggled Xanax into Hong Kong with him, then became heavily intoxicated on the drug. Applicant’s family ultimately tracked him down, incapacitated on the city streets, after which time he was involuntarily admitted into a mental health facility for detox. He received care from May to June 2018. Upon returning to the United States, Applicant began seeing a psychologist, Dr. BL, for drug treatment once every two weeks. He continued with Dr. BL until March 2020, when in-person care was curtailed due to COVD-19 restrictions. Applicant did not pursue virtual care or resume in-person care when the restrictions ended. He does not intend to use Xanax in the future. (GE 3 at 33-34, 38, 42, 44; GE 5 at 1-2) 1.e. Use of “mushrooms” from December 2014 – October 2022: Applicant admitted to this allegation in his Answer but also acknowledged mushroom use through 3

at least March 2026. In college, he used hallucinogenic mushrooms three to five times from 2015 to 2017. He would either eat a “mushroom cap” or make tea from it. He used the hallucinogenic substance once again in 2022 in a gummy edible form. Though he insisted in his Questionnaire that he does not intend to use mushrooms in the future, per his Answer he has apparently revisited his stance on the matter. (Answer; GE 3 at 39) 1.f. Purchase and use of LSD from December 2014 – May 2018: Applicant initially purchased LSD from fellow college students until he left school in 2016, after which time he purchased the drug on the dark web using Bitcoin. He acknowledged extensive use of LSD during this time frame, estimating “probably 40-100 times.” He used the drug at concerts, during study, in class, on hikes, “or often just at home, sometimes while coding.” His last use in the spring of 2018 was in conjunction with Xanax, after which he overdosed and had a seizure, resulting in hospitalization and anti-psychotic medication (see SOR ¶ 1.d above). He does not intend to use LSD in the future. (GE 3 at 39, 43) 1.g. Intent to continue use of marijuana in the future: Applicant uses THC now and intends to continue doing so in the future. See SOR ¶ 1.a above. SOR Paragraph 2 (Guideline J: Criminal Conduct) The Government alleged that Applicant is ineligible for a security clearance due to certain criminal activity. The following findings of fact pertain: 2.a. Cross-allegation with SOR ¶¶ 1.b through 1.f: As drafted, SOR ¶ 2.a reads: “Information as set forth under subparagraph 2.b through 2.f. above.” The SOR, as drafted, does not contain subparagraphs 2.b through 2.f; but given the reference to “above,” the wording of the allegation appears to be a scrivener’s error and will be treated as such. Referring instead to “information as set forth under subparagraph 1.b through 1.f. above” for findings of fact, see SOR ¶¶ 1.b through 1.f above. SOR Paragraph 3 (Guideline E: Personal Conduct) The Government alleged that Applicant is ineligible for a security clearance because he had engaged in conduct that involved questionable judgment, lack of candor, dishonesty, or unwillingness to comply with rules and regulations. The following findings of fact pertain: 3.a. Drug abuse and involuntary mental facility admission (May 2018): See SOR ¶ 1.d above. SOR Paragraph 4 (Guideline G: Alcohol Consumption) 4.a. Weekly intoxication from alcohol consumption: In his Questionnaire response to the topic in September 2024, Applicant explained, “I do not enjoy the effects of consuming alcohol, it is a depressant so I tend to steer clear.” In his November 2025 responses to interrogatories, Applicant revisited his stance on the use of alcohol, 4

explaining that now he drinks seven to eight beers per week and seven or eight glasses of wine per month. He gets “a craving for intoxication” about once a month. There is no evidence in the record to support the statement that he drinks alcohol to the point of intoxication weekly, as alleged in the SOR. He averred that he becomes intoxicated after two beers and noted having experienced intoxication to the level of blackout on November 1, 2025. He has not had any alcohol-related incidents. (GE 3 at 47; GE 4 at 12-13) Whole Person and Mitigating Evidence Applicant submitted no comments or explanations in his Answer as whole person evidence in mitigation of the security concerns alleged in the SOR. The comments and explanations Applicant included in his Questionnaire, interrogatories, and response to the defense investigator, however, were reviewed in their entirety. Specifically of note, Applicant expressed to the defense investigator that he “considers himself a drug free person and a law abiding citizen.” He “did not disclose his drug use, drug treatment or illegal drug activities” to his present employer but would if so required. (GE 5 at 3) Policies When evaluating an applicant’s suitability for national security eligibility, the administrative judge must consider the adjudicative guidelines. In addition to brief introductory explanations for each guideline, the adjudicative guidelines (AG) list potentially disqualifying conditions and mitigating conditions, which are to be used in evaluating an applicant’s national security eligibility. 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 AG ¶ 2 describing 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 applicable guidelines in the context 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 national security is the paramount consideration. AG ¶ 2(b) requires, “Any 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. I have not drawn inferences based on mere speculation or conjecture. Directive ¶ E3.1.14, requires the Government to present evidence to establish controverted facts alleged in the SOR. Under Directive ¶ E3.1.15, “The applicant is responsible for presenting witnesses and other evidence to rebut, explain, extenuate, or mitigate facts admitted by the applicant or proven by Department Counsel, and has the ultimate burden of persuasion as to obtaining a favorable clearance decision.” A person who seeks access to classified information enters into a fiduciary relationship with the 5

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 national security eligibility. Decisions include, by necessity, consideration of the possible risk the applicant may deliberately or inadvertently fail to protect or safeguard classified information. Such decisions entail a certain degree of legally permissible extrapolation as to potential, rather than actual, risk of compromise of classified or sensitive information. Finally, as emphasized in Section 7 of Executive Order 10865, “Any determination under this order adverse to an applicant shall be a determination in terms of the national interest and shall in no sense be a determination as to the loyalty of the applicant concerned.” See also Executive Order 12968, Section 3.1(b) (listing multiple prerequisites for access to classified or sensitive information.) Analysis SOR Paragraph 1 (Guideline H: Drug Involvement and Substance Misuse) The security concerns relating to the guideline for drug involvement and substance misuse are set out in AG ¶ 24, which reads as follows: The illegal use of controlled substances, to include the misuse of prescription and non-prescription drugs, and the use of other substances that cause physical or mental impairment or are used in a manner inconsistent with their intended purpose can raise questions about an individual’s reliability and trustworthiness, both because such behavior may lead to physical or psychological impairment and because it raises questions about a person’s ability or willingness to comply with laws, rules, and regulations. Controlled substance means any “controlled substance” as defined in 21 U.S.C. 802. Substance misuse is the generic term adopted in this guideline to describe any of the behaviors listed above. The facts of this case establish the following potentially disqualifying conditions set forth in AG ¶ 25 to the allegations under Guideline H: (a) any substance misuse (see above definition); (c) illegal possession of a controlled substance, including cultivation, processing, manufacture, purchase, sale, or distribution; or possession of drug paraphernalia; and (g) expressed intent to continue drug involvement and substance misuse, or failure to clearly and convincingly commit to discontinue such misuse. 6

The burden therefore shifts to Applicant to mitigate security concerns under Guideline H. The guideline includes the following conditions in AG ¶ 26 that could potentially mitigate security concerns arising from Applicant’s drug use: (a) the behavior happened so long ago, was so infrequent, or happened under such circumstances that it is unlikely to recur or does not cast doubt on the individual’s current reliability, trustworthiness, or good judgment; and (b) the individual acknowledges his or her drug involvement and substance misuse, provides evidence of actions taken to overcome the problem, and has established a pattern of abstinence, including, but not limited to: (1) disassociation from drug-using associates and contacts; (2) changing or avoiding the environment where drugs were used; (3) providing a signed statement of intent to abstain from all drug involvement and substance misuse, acknowledging that any future involvement or misuse is grounds for revocation of national security eligibility; (d) satisfactory completion of a prescribed drug treatment program, including, but not limited to, rehabilitation and aftercare requirements, without recurrence of abuse, and a favorable prognosis by a duly qualified medical professional. Applicant’s long history of both legal and illegal marijuana purchase and use precludes the application of any AG ¶ 26 mitigating factors to SOR ¶¶ 1.a and 1.g – particularly given his decision to start using the drug again after pledging not to do so in the future. He also decided to resume use of marijuana after completing the Questionnaire. The Appeal Board has specifically noted that use of the drug after being placed on notice is incompatible with security clearance eligibility standards and raises substantial questions about an applicant’s judgment, reliability, and willingness to comply with laws, rules, and regulations. ISCR 20-02974 at 6 (App. Bd. Feb. 1, 2022). See also ISCR 07- 00852 at 3 (App. Bd. May 27, 2008) (Use of marijuana after having submitted a security clearance application undercuts an applicant’s promise to avoid such conduct in the future). And though he avers to having attending drug counseling for two years, he provided no certificate from a successfully completed program or statement from his treating physician explaining Applicant’s current and/or future propensity for continued drug abuse. SOR ¶¶ 1.a and 1.g are found against Applicant. Regarding SOR ¶ 1.b and 1.e, Applicant’s college use of cocaine and mushrooms could typically be mitigated by AG ¶ 26(a), given how long ago it occurred. But his 7

decision to use cocaine again as recently as 2023 – and “mushrooms” in March 2026 – is of great concern. Though he explained he no longer associated with the friend with whom he used cocaine, his multiple uses in 2022 and 2023 were after two hospitalizations for drug abuse and after the above-referenced two years of drug counseling with Dr. BL. This recent and repeated decision-making process casts doubt on Applicant’s present commit to discontinue such misuse and challenges his current reliability, trustworthiness, and good judgment. Consequently, none of the AG ¶ 26 mitigators apply and SOR ¶¶ 1.b and 1.e are found against Applicant. Conversely, Applicant ceased his use of stimulants, Xanax, and LSD shortly after leaving college and he did not relapse again into misuse. AG ¶ 26(a) does apply to these issues and, as such, SOR ¶¶ 1.c, 1.d, and 1.f are found for Applicant. Paragraph 1 is found against Applicant. SOR Paragraph 2 (Guideline J: Criminal Conduct) The security concern for criminal conduct is set out in AG ¶ 30: Criminal activity creates doubt about a person’s judgment, reliability, and trustworthiness. By its very nature, it calls into question a person’s ability or willingness to comply with laws, rules and regulations. The facts of this case establish the following potentially disqualifying conditions set forth in AG ¶ 31 to the allegations under Guideline J: (a) a pattern of minor offenses, any one of which on its own would be unlikely to affect a national security eligibility decision, but which in combination cast doubt on the individual’s judgment, reliability, or trustworthiness; and (b) evidence (including, but not limited to, a credible allegation, an admission, and matters of official record) of criminal conduct, regardless of whether the individual was formally charged, prosecuted, or convicted. The burden therefore shifts to Applicant to mitigate security concerns under Guideline J. The guideline includes the following conditions in AG ¶ 32 that could potentially mitigate security concerns arising from Applicant’s criminal conduct: (a) so much time has elapsed since the criminal behavior happened, or it happened under such unusual circumstances, that it is unlikely to recur and does not cast doubt on the individual’s reliability, trustworthiness, or good judgment; and (d) there is evidence of successful rehabilitation; including, but not limited to, the passage of time without recurrence of criminal activity, restitution, 8

compliance with the terms of parole or probation, job training or higher education, good employment record, or constructive community involvement. Once again, the criminal nature of Applicant’s college drug use might otherwise have been mitigated by AG ¶ 32(a), given how long ago it occurred. But he resumed the use of “mushrooms” after completing the Questionnaire and despite being “aware of the prohibition of any drug use while holding a national security position” while relating that he “plans to abide by that prohibition.” He also used cocaine in 2023. The analyses discussed in SOR ¶¶ 1.b and 1.e above pertain and the recency of Applicant’s uses render both mitigating conditions inapplicable. The recent criminal behavior also undercuts whatever mitigation may have otherwise applied to SOR ¶¶ 1.c, 1.d, and 1.f as well. SOR ¶ 2.a is found against Applicant. Paragraph 2 is found against Applicant. SOR Paragraph 3 (Guideline E: Personal Conduct) The security concerns relating to the guideline for personal conduct are set out in AG ¶ 15, which states: 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 facts of this case establish the following potentially disqualifying condition set forth in AG ¶ 16 to the allegations under Guideline E: (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 that the individual may not properly safeguard classified or sensitive information; The burden, therefore, shifts to Applicant to mitigate security concerns under Guideline E. The guideline includes the following condition in AG ¶ 17 that could potentially mitigate security concerns arising from Applicant’s drug abuse and involuntary mental facility admission: (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; 9

(d) the individual has acknowledged the behavior and obtained counseling to change the behavior or taken other positive steps to alleviate the stressors, circumstances, or factors that contributed to untrustworthy, unreliable, or other inappropriate behavior, and such behavior is unlikely to recur; and (e) the individual has taken positive steps to reduce or eliminate vulnerability to exploitation, manipulation, or duress. Applicant’s profound and dangerous struggle with Xanax in 2018 was followed by inpatient treatment and two years of drug counseling and/or therapy. During the ensuing six years, there is no evidence he abused Xanax – or even took the drug. As such, AG ¶ 17(c) and (d) apply. Paragraph 3 is found for Applicant. SOR Paragraph 4 (Guideline G: Alcohol Consumption) The security concerns relating to the guideline for alcohol consumption are set out in AG ¶ 21, which reads as follows: Excessive alcohol consumption often leads to the exercise of questionable judgment or the failure to control impulses and can raise questions about an individual’s reliability and trustworthiness. The facts of this case ostensibly establish the following potentially disqualifying condition set forth in AG ¶ 22 to the allegations under Guideline G: (c) habitual or binge consumption of alcohol to the point of impaired judgment, regardless of whether the individual is diagnosed with alcohol use disorder. The minimal evidence in the record on this issue reveals that Applicant drinks to the point of intoxication “about once a month” – not once a week as alleged. To that end, he revealed that he drinks seven or eight beers per week – not per sitting. Also, he was asked in interrogatories the date of his last black-out, which he answered (November 1, 2025). Applicant was not asked if he had ever consumed alcohol to the point of black-out prior to that date (and if so, how frequently it happens). But to the extent that intoxication once per month is arguably “habitual,” the burden shifts to Applicant to mitigate security concerns under Guideline G. The guideline includes the following conditions in AG ¶ 23 that could potentially mitigate security concerns arising from Applicant’s alcohol consumption: (a) so much time has passed, or the behavior was so infrequent, or it happened under such unusual circumstances that it is unlikely to recur or does not cast doubt on the individual’s current reliability, trustworthiness, or judgment; and 10

(b) the individual acknowledges his or her pattern of maladaptive alcohol use, provides evidence of actions taken to overcome this problem, and has demonstrated a clear and established pattern of modified consumption or abstinence in accordance with treatment recommendations. Drinking beer or wine to the point of intoxication about once per month – perhaps 12 times per year – is arguably not a healthy choice for a healthy lifestyle. But to aver it rises to the level of habitual or binge drinking contemplated by the security concerns discussed in AG ¶ 21 and AG ¶ 22(c), without more, requires speculation beyond the evidentiary record. To the extent AG ¶ 22(c) may be triggered by monthly intoxication and no alcohol-related incidents, I find this behavior is so infrequent that it is unlikely to recur or does not cast doubt on the individual’s current reliability, trustworthiness, or judgment. AG ¶ 23(a) applies and Paragraph 4 is found for Applicant. Whole-Person Concept Applying the whole-person concept, the administrative judge must evaluate an applicant’s eligibility for national security eligibility by considering the totality of the applicant’s conduct and all relevant circumstances. The 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. Under AG ¶ 2(c), the ultimate determination of whether to grant national security eligibility for a security clearance must be an overall commonsense judgment based upon careful consideration of the guidelines and the whole-person concept. I considered the above whole-person factors and the potentially disqualifying and mitigating conditions in light of all pertinent facts and circumstances surrounding this case. I have given the appropriate weight to Applicant’s statements included in his responses to interrogatories and his Answer. Overall, however, the Guideline H and J issues in the record evidence leave me with questions and doubts as to Applicant’s suitability for national security eligibility and a security clearance. Formal Findings Formal findings for or against Applicant on the allegations set forth in the SOR, as required by ¶ E3.1.25 of Enclosure 3 of the Directive, are: Paragraph 1, Guideline H: AGAINST APPLICANT 11

Subparagraphs 1.a – 1.b: Against Applicant Subparagraphs 1.c – 1.d: For Applicant Subparagraph 1.e: Against Applicant Subparagraph 1.f: For Applicant Subparagraph 1.g: Against Applicant Paragraph 2, Guideline J: AGAINST APPLICANT Subparagraph 2.a: Against Applicant Paragraph 3, Guideline E: FOR APPLICANT Subparagraph 3.a: For Applicant Paragraph 4, Guideline G: FOR APPLICANT Subparagraph 4.a: For Applicant Conclusion In light of all of the circumstances presented by the record in this case, I conclude that it is not clearly consistent with the interests of national security to grant Applicant’s eligibility for a security clearance. Eligibility for access to classified information is denied. RICHARD A. CEFOLA Administrative Judge 12