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]: potentially to have lost contact with family, friends, or each other. But that consequence is not “serious harm” — and warning of such a consequence is not a “threat” — under the Trafficking Victims Protection Act. In applying the Act, we must distinguish between “Dimproper threats or coercion and permissible warnings of adverse but legitimate consequences.” United States v. Bradley, 390 F.3d 145, 151 (1st Cir.2004), judgment vacated on other grounds, 545 U.S. 1101, 125 S.Ct. 2543, 162 L.Ed.2d 271 (2005); cf. Dann, 652 F.3d at 1170 (Act aims at serious trafficking and threats of dire consequences). This case involves the latter. A church is entitled to stop associating with someone who abandons it. Paul v. Watchtower Bible & Tract Soc’y of N.Y., Inc., 819 F.2d 875, 883 (9th Cir.1987) (<HOLDING>). A church may also warn that it will stop 
 Holding statements: (A) holding fourth amendment protects right to be free from arrest without probable cause (B) holding that the free exercise clause protects the practice of shunning explaining that when the members of a cjhurch no longer want to associate with someone who has abandoned them those members are free under the first amendment to make that choice (C) holding that shortterm and sporadic interference with free exercise rights does not violate the first amendment (D) holding that possession of marijuana is not protected by the free exercise clause of the first amendment (E) recognizing serious harm results when members of the legal profession engage in criminal acts which give rise to a lack of confidence by members of the public in those who are officers of the court
[EX A]: holding fourth amendment protects right to be free from arrest without probable cause

[EX Q]: of the debtor. This distinction appears immaterial under the language of sec. 409.402(7), Stats. 7 In other contexts, a security interest properly perfected at one time may later become unperfected through creditor inaction. See, e.g. sec. 409.103(l)(d)l, (2)(b), (3)(e), Stats, (four month grace periods preserving perfection in collateral removed from jurisdic tion); sec. 409.403(2) (lapse of financing statements after 5 years unless continued). 8 Interestingly, the Ansley court held that a filing under "the name Ansley Farms instead of the debtor's true name — Emory Ansley — is seriously misleading, making [the]. . . security interest unperfected.. . ." Id,., 467 F.Supp. at 55. Other cases reaching similar results are In Re Wishart, 10 U.C.C. Rep. Serv. 1296 (Bankr.W.D. Mich. 1972) (<HOLDING>); In Re Brawn, 7 U.C.C. Rep. Serv. 565 (D.C. 
 Holding statements: (A) holding that the filing of notice without motion is insufficient (B) holding a filing under mccauleys reprographics and mapping insufficient to perfect a security interest in the assets of the debtor corporation (C) holding that the reservation of a claim need not name a defendant but only identify the type of claim the debtor seeks to retain (D) holding a filing under wishart equipment co insufficient to identify the debtor horace wishart (E) holding a filing under john and mayella lintz insufficient to identify the debtor corporation
[EX A]: holding that the filing of notice without motion is insufficient

[EX Q]: standard. Fed. R. Crv. P. 9(b) (“In all averments of fraud or mistake, the circumstances constituting fraud or mistake shall be stated with particularity.”). Thus, Toombs extended the Rule 9(b) exception to cases with no fraud allegations. Importantly, Toombs provided no reason whatsoever for extending Rule 9(b), and the Court cannot determine that the Ninth Circuit even considered its holding’s impact on notice pleading. The Court must reject those cases which require plaintiffs to plead facts showing compliance with the statute of limitations in every suit brought pursuant to § 111. Rule 8(a) does not require plaintiffs to plead every element that they must ultimately prove simply because plaintiffs carry the burden of proof. Woodfield v. Bowman, 193 F.3d 354, 362 (5th Cir.1999) (<HOLDING>); Bennett v. Schmidt, 153 F.3d 516, 518 (7th 
 Holding statements: (A) holding that group pleading did not render complaint infirm where complaint provided fair notice of claims (B) holding that a pleading may give proper fair notice even where only the title of the theory is pled (C) holding the employees complaints must give adequate notice to the employer that the employee is complaining of conduct prohibited by title vii (D) holding that the application of the fair use doctrine at the pleading stage is appropriate (E) holding that courts look to substance of plea for relief to determine nature of pleading not merely title of pleading
[EX A]:
holding that group pleading did not render complaint infirm where complaint provided fair notice of claims