With no explanation, chose the best option from "A", "B", "C" or "D". Ms. Manbeck actually spoke Vietnamese, or needed to, for purposes of this litigation. Thus, Ms. Manbeck’s ability to speak Vietnamese, even fluently, is irrelevant to the litigation and cannot serve as grounds to increase her fee. As to the claim that Ms. Manbeck has specialized expertise in refugee culture and historical background, the Court finds this wholly unsubstantiated. Ms. Manbeck fails to allege, much less demonstrate, that she possesses distinctive knowledge and skills in Plaintiffs Iraqi culture and historical background. Even if she had, Ms. Manbeck fails to demonstrate how this expertise was necessary to this litigation, other than the obvious fact that Plaintiff himself hails from Iraq. See Pierce v. Underwood, 487 U.S. 552, 572, 108 S.Ct. 2541, 101 L.Ed.2d 490 (1988) (<HOLDING>). Finally, Ms. Manbeck claims distinctive

A: holding that the governments litigation position which allegedly prolonged the litigation cannot be a special factor warranting an increase above the statutorily allowed 75 per hour under the eaja
B: holding that to qualify for a special factor increase the attorney must have some distinctive knowledge or specialized skill needful for the litigation in question  
C: holding that no specialized skill or distinctive knowledge was needed to represent an alien at asylum and withholding of deportation hearings
D: holding negligence on the part of the attorney does not qualify for such relief
B.