PER CURIAM:
The Equal Access to Justice Act, 5 U.S.C. § 504, provides that "[a]n agency that conducts an adversary adjudication shall award, to a prevailing party ..., fees ... incurred by that party in connection with that proceeding, unless ... the position of the agency as a party to the proceeding was substantially justified or ... special circumstances make an award unjust." 5
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