In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision.  Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

[EX Q]: before section 362(b)(3) can come into play. An act that both creates and perfects a lien postpetition cannot so qualify. See, e.g., Louisville & Jefferson County Metro. Sewer Dist. v. Excel Eng’g, Inc. (In re Excel Eng’g, Inc.), 224 B.R. 582, 589-90 (Bankr.W.D.Ky.1998) (refusing to recognize validity of postpetition creation and perfection of mechanic’s hen because creditor had no lien at the time debtor filed for bankruptcy); Water-vliet Paper Co. v. City of Watervliet (In re Shoreham Paper Co.), 117 B.R. 274, 281-83 (Bankr.W.D.Mich.1990) (finding postpe-tition creation and perfection of property tax lien barred by automatic stay because no prepetition interest existed); Equitable Life Assur. Soc’y v. Ballentine Bros. (In re Ballentine Bros.), 86 B.R. 198, 201 (Bankr. D.Neb.1988) (<HOLDING>); North Side Lumber Co. v. Indus. Indem. Co. 
 Holding statements: (A) holding that the automatic stay barred a suit for injunctive relief to prevent postpetition antitrust violations (B) holding that the automatic stay would be modified so that a credit union could seek payment of postpetition interest from the codebtor (C) holding judgment in violation of automatic stay void (D) holding that creditors failure to voluntarily turn over property lawfully seized prepetition constituted violation of automatic stay (E) holding that creation of a postpetition tax levy based on a prepetition assessment was barred by the automatic stay
[EX A]: holding that the automatic stay barred a suit for injunctive relief to prevent postpetition antitrust violations

[EX Q]: while the parties informally agreed to extend the discovery deadline in order to allow further expert depositions, we do not regard this arrangement as a waiver by plaintiffs of their right to receive documents of such volume and complexity in a sufficiently timely manner to allow an effective response. We recognize, of course, the normal tendency for preparations to intensify as trial approaches and, thus, suggest no general bar to material produced seasonably and in good faith. See Fusco v. General Motors Corp., 11 F.3d 259, 266 (1st Cir.1993). In this case, however, we believe that, if Ford intended to rely on this evidence at trial, it should have made more diligent efforts at its timely production. Cf. Glover v. Grace Pac. Corp., 86 Hawai'i 154, 164, 948 P.2d 575, 585 (App.1997) (<HOLDING>). The trial court, nevertheless, distinguished 
 Holding statements: (A) holding that a request for admission is a tool of discovery subject to discovery cutoff dates (B) holding the record which included the opinion of several physicians was sufficient for the alj to arrive at a decision (C) holding that the trial court properly excluded an expert who failed to arrive at his final opinion before the discovery cutoff date (D) holding that plaintiff need not have submitted requests for admissions by the august 15 discovery motion cutoff date or by the discovery cutoff date of september 15 because requests for admissions are distinct from other general discovery devices and are not subject to discovery cutoff dates (E) holding that requests for admissions are subject to discovery cutoff dates
[EX A]: holding that a request for admission is a tool of discovery subject to discovery cutoff dates

[EX Q]: debtor "cannot be viewed as 'the debtor' as that reference appears for the second time in the second sentence in subsection 554.9402(7) (Iowa stats.]." Id. at 27. This reasoning assumes two debtors though factually there is only one. The reasoning is therefore fundamentally flawed. 6 First Agri does not contend that it was actually misled by the debtors' change of name. It cites several ninth circuit cases for the proposition that a conclusion that a financing statement is "seriously misleading" does not require a finding that a creditor had actually been misled. In Re Thomas, Inc., 466 F.2d 51 (9th Cir. 1972); In Re Pacific Trencher & Equipment, Inc., 735 F.2d 362 (9th Cir. 1984). Respondents suggest that this is not a ease of a name change, but is rather a change in iden 1970) (<HOLDING>); In Re McCauley's Reprographics, Inc., 638 
 Holding statements: (A) holding that motor vehicle to be retained by chapter 13 debtor should be valued at the price the debtor could get for it in a free and open market ie its fair market value (B) recognizing implied duty to market (C) holding brawns super market an insufficient listing where the debtor was wendall p brawn (D) holding that a contract for an exclusive agency to market a product contains an implied promise to use all reasonable efforts to market the product (E) holding that oral listing agreement did not preclude recovery of a commission
[EX A]:
holding that motor vehicle to be retained by chapter 13 debtor should be valued at the price the debtor could get for it in a free and open market ie its fair market value