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]: commencing an action will be assumed to have waived its right to arbitration when its use of the judicial process is clearly inconsistent with seeking arbitration at a later date.” Id. (internal quotation marks and citation omitted). Applying this law, Judge Weinstein' concluded that choosing to file a claim in court rather than arbitrate constitutes a waiver of the right to arbitrate. Id. (citing Digitronics Inventioneering Corp. v. Jameson, 52 A.D.3d 1099, 860 N.Y.S.2d 303 (3d Dep’t 2008)). I agree with Judge Weinstein’s well-reasoned decision that, if New York law applies, the decision to litigate disputes over unpaid claims in state court precludes Defendants from now seeking to compel arbitration with respect to those same claims. But see Grand Med. Supply, 2012 WL 2577577, at *2 (<HOLDING>). Moreover, I would reach the same result even 
 Holding statements: (A) holding that mandatory arbitration agreements in the employment context fall under the faa (B) holding that the framework for determining any disputed issues concerning arbitration must be determined in the context of the faa (C) holding that the faa requires arbitration of age discrimination claims when a valid arbitration agreement exists (D) holding that faa was inapplicable where parties involved in action are not parties to an arbitration agreement under which issues are referable to arbitration (E) holding that the faa mandates courts to direct parties to arbitration on issues to which a valid arbitration agreement has been signed
[EX A]: holding that mandatory arbitration agreements in the employment context fall under the faa

[EX Q]: re Haddad), 68 B.R. 944, 948 (Bankr.D.Mass.1987); Williams v. Clark (In re Clark), 91 B.R. 324, 332-34 (Bankr.E.D.Pa.1988). And, although § 105 “does not authorize the bankruptcy courts to create substantive rights that are otherwise unavailable under applicable law,” Pertuso, 233 F.3d at 423, n. 1; “[b]ankruptcy courts ... enjoy inherent power to sanction parties for improper conduct.” Mapother & Mapother v. Cooper (In re Downs), 103 F.3d 472, 477 (6th Cir.1996). This inherent power authorizes federal courts “to protect their proceedings and judgments in the course of discharging their traditional responsibilities.” Degen v. United States, 517 U.S. 820, 823, 116 S.Ct. 1777, 135 L.Ed.2d 102 (1996). See also Chambers v. NASCO, Inc., 501 U.S. 32, 50, 111 S.Ct. 2123, 115 L.Ed.2d 27 (1991)(<HOLDING>); Jones v. Bank of Santa Fe (In re Courtesy 
 Holding statements: (A) recognizing that court has inherent power to control the judicial business before it (B) recognizing inherent power of courts of appeals (C) recognizing district courts inherent authority to dismiss with prejudice for abuse of judicial process (D) recognizing inherent power of federal district court to sanction conduct abusive of judicial process (E) recognizing courts inherent power to impose sanctions including attorneys fees for conduct that abuses the judicial process
[EX A]: recognizing that court has inherent power to control the judicial business before it

[EX Q]: Id. (citations omitted). To be sure, in making its analysis under Rule 19(a)(1), a court should consider the interests of “the public in avoiding repeated lawsuits on the same essential subject matter.” Fed.R.Civ.P. 19 advisory committee’s notes. Rule 19(a)(1), however, similarly “stresses the desirability of joining those persons in whose absence the court would be obliged to grant partial or ‘hollow’ rather than complete relief to the parties before the court.” Id. In this case, considering Pennsylvania’s joint and several liability rules which supply the governing substantive law, GRC’s failure to name the absent insurers to its suit plainly will not result in it obtaining “partial” or “hollow” relief if it is successful in its suit. See Janney Montgomery Scott, 11 F.3d at 406 (<HOLDING>). To this end, the advisory committee’s notes 
 Holding statements: (A) recognizing that where liability is joint and several among multiple parties complete relief may be granted with respect to any one of them (B) holding that one agreement cannot be taken to be several agreements and therefore several conspiracies because the agreement envisages the violation of several statutes rather than one (C) holding that the surety of a joint and several bond has direct liability and may be sued individually or collectively (D) recognizing forfeiture liability among criminal confederates to be joint and several (E) holding that all partners are not indispensible parties defendant where state law provides for partners joint and several liability
[EX A]:
holding that one agreement cannot be taken to be several agreements and therefore several conspiracies because the agreement envisages the violation of several statutes rather than one