Security Clearance Lawyer for DOHA ISCR Cases – Responding to a Statement of Reasons (SOR)

Contractors holding or seeking a Department of Defense (DoD) security clearance face one of the most critical steps in the clearance adjudication process when they receive a Statement of Reasons (SOR) from the Defense Office of Hearings and Appeals (DOHA). This document outlines the government’s preliminary concerns under the Adjudicative Guidelines and requires the Applicant to admit or deny each allegation.

How you respond to these allegations—especially whether you admit or deny them—can determine whether your clearance is granted, denied, or revoked. The SOR response is the foundation of your defense, and mistakes made here often become fatal at the hearing.

Korody Law, P.A. represents defense contractors nationwide before DOHA in ISCR (Industrial Security Clearance Review) cases. We ensure that your SOR response is accurate, strategically prepared, and consistent with the evidence and your testimony at a future hearing.

Understanding the DOHA Statement of Reasons (SOR)

The SOR identifies security concerns under the Adjudicative Guidelines (A–M), including:

• Guideline F – Financial Considerations
• Guideline E – Personal Conduct
• Guideline J – Criminal Conduct
• Guideline G – Alcohol Consumption
• Guideline H – Drug Involvement and Substances
• Guideline B – Foreign Influence
• Other applicable guidelines

For each allegation, the Applicant must by writing:

• “Admit”
• “Deny”
• Or “Admit in part / Deny in part” with an explanation (though DCSA has been pushing back partial admissions/denials)

What many Applicants do not realize is that admissions become binding and can be used against them at the DOHA hearing. If you deny the allegation, the Department has to prove it by evidence. However, if you deny an allegation without a good faith basis, you could jeopardize your case.

Why You Must Be Extremely Careful Making Admissions in a DOHA SOR

DOHA Administrative Judges treat an admission as conclusive evidence that the allegation is true. Even if the Applicant misunderstood the question or meant only to admit part of it, a full admission can:

• Eliminate arguments that the underlying facts are inaccurate
• Prevent challenges to evidence at the hearing
• Be used by Department Counsel to discredit your testimony
• Be treated as a credibility issue if you later try to correct or explain your answer

Example:

If the SOR says “You failed to timely file federal taxes for tax years 2018–2022” and you only actually filed late in 2020, but you check “Admit”, the judge will treat the entire allegation as true—even if the government cannot prove it.

Once admitted, the allegation is no longer in dispute.

This is why many Applicants unknowingly damage their defense before the hearing even begins.

Problems With “Partial” or “Conditional” Admissions

Many Applicants believe they can “explain away” an allegation after admitting it. DOHA does not work that way. A partial admission must be drafted with precision:

• Admissions that are too broad can close off important defenses.
• Explanations that contradict the admission undermine credibility.
• Admitting conduct that did not occur may be treated as dishonesty later.

Department Counsel often uses sloppy admissions to impeach Applicants on credibility—one of the most important factors in any security clearance decision.

Denying an Allegation Is Not a Bad Thing

Many Applicants are afraid to deny allegations because they worry it may appear uncooperative. In reality:

A proper denial simply preserves your right to contest the allegation and force the government to prove its case.

DOHA places the burden of proof on the government to establish disqualifying conditions. If you deny the allegation:

• Department Counsel must present evidence
• If they cannot, the allegation may be resolved in your favor
• It preserves your credibility if the allegation is inaccurate or overstated

You should never admit something that is not entirely true just to appear cooperative. Cooperation is shown through timely responses, documentation, and clear explanations—not admitting incorrect allegations.

Common DOHA SOR Response Mistakes

• Admitting allegations that are only partially true
• Denying allegations without explanation when an explanation is needed
• Using emotional or inconsistent wording
• Copy-pasting explanations from the past SF-86 or incident reports
• Writing contradictory statements
• Confessing to things not alleged in the SOR

Remember: your SOR response becomes part of the official DOHA record and will be used at the hearing.

Your SOR Response Sets Up Your DOHA Hearing Strategy

The SOR response is the foundation of your case. It must be consistent with:

• Your testimony at the hearing
• Exhibits you plan to introduce
• Rehabilitation or corrective steps
• Character evidence and whole-person analysis
• Prior disclosures on the SF-86

A poorly drafted SOR response often leads to inconsistent testimony—one of the biggest reasons DOHA judges deny clearances. Department Counsel will scrutinize every word you wrote.

How Korody Law Helps With DOHA SOR Responses

Our representation includes:

• Reviewing the SOR and identifying factual inaccuracies
• Drafting precise, strategic admissions or denials
• Developing a strategy for mitigation evidence at the hearing
• Ensuring no admissions undermine future hearing arguments
• Preparing you for the DOHA hearing and government cross-examination

We represent contractors nationwide in DOHA ISCR cases and understand how Department Counsel and Administrative Judges evaluate evidence, testimony, and credibility.

Contact a DOHA SOR Response & Security Clearance Lawyer

If you received a Statement of Reasons, the clock is running. Your response must be complete, accurate, and strategically framed to support a favorable outcome at the hearing.

Call or text Korody Law at (904) 383-7261 for immediate assistance.

Korody Law, P.A. – National Security Clearance Defense