Amilu S. Rothhammer, formerly Amilu S. Martin - Page 10

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               We conclude that respondent’s position that the petition was           
          valid as to Martin was substantially justified.                             
               To reflect the foregoing,                                              


                                                       An appropriate order           
                                                  will be issued denying              
                                                  Martin’s motion for an              
                                                  award of litigation                 
                                                  costs.                              
























               6(...continued)                                                        
          costs were reasonable in light of our conclusion that                       
          respondent’s position was substantially justified.                          

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