instruction:
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.
question:
options,” including by streamlining communication between the distressed borrower and foreclosing party. See Assemb. B. 278, 2011-2012 Leg., Reg. Sess. (Cal. 2012); S.B. 900, 2011-2012 Leg., Reg. Sess. (Cal. 2012). There has been a wave of litigation in state and federal courts challenging various aspects of the MERS System. Almost all of the relevant law is state rather than federal. The results under state law have been inconsistent. See Weber, supra, at 246-56 (cataloguing the “schizophrenic position of state courts” on issues relating to the MERS System). Some state supreme courts have upheld the MERS System on issues ranging from foreclosure authority to recording requirements. See, e.g., Renshaw v. Mortg. Elec. Registration Sys., Inc., 155 Idaho 656, 315 P.3d 844, 846-47 (2013) (<HOLDING>); Jackson v. Mortg. Elec. Registration Sys., 
 Holding statements: (A) holding that mers lacked standing to foreclose as the lenders nominee (B) holding that because mers receives no payments on the debt it is not the beneficiary even though it is so designated in the deed of trust (C) holding that mers is an ineligible beneficiary within the terms of the washington deed of trust act if it never held the promissory note or other debt instrument secured by the deed of trust and that characterizing mers as the beneficiary has the capacity to deceive and may give rise to an action under the consumer protection act (D) holding that mers may be a beneficiary as nominee for the lender that assignments of the deed of trust between mers members need not be recorded that mers was not liable to the borrower in negligence and that the idaho consumer protection act did not provide a cause of action to the borrower (E) holding that mers was not the beneficiary of a deed of trust under the oregon trust deed act absent conveyance to mers of the beneficial right to repayment and that mers could not hold or transfer legal title to the deed as the lenders nominee
answer:
holding that mers lacked standing to foreclose as the lenders nominee


question:
of common law fraud, it is considered a fraudulent act and is protected by 9(b)). We conclude that 9(b) applies to FCA fraud claims because not only is such a conclusion in accord with other courts and our more recent decisions, but also because its applicability is consistent with the purposes of Rule 9: (1) to inhibit claims that are filed as a pretext to uncover unknown wrongs; (2) to protect defendants from the harm that results from charges of serious wrongdoing; and (3) to give defendants notice of the complained-of conduct, enabling defendants to prepare a defense. Coronet Insurance Co. v. Seyfarth, 665 F.Supp. 661, 666 (N.D.Ill.1987). See also U.S. ex rel. Stinson, Lyons, Gerlin & Bustamante v. Blue Cross Blue Shield of Georgia, Inc., 755 F.Supp. 1055, 1058 (S.D.Ga.1990) (<HOLDING>); U.S. ex rel. Stinson, Lyons, Gerlin & 
 Holding statements: (A) holding a broad claim with no factual support was insufficient to satisfy rule 9b (B) holding that rule 9b applies to fca (C) holding that californias ucl claims are subject to rule 9b pleading standards (D) holding that charge of money laundering need not satisfy rule 9b (E) holding plaintiffs speculations did not satisfy rule 9b requirements
answer:
holding a broad claim with no factual support was insufficient to satisfy rule 9b


question:
Apr. 14, 2011). Accord Wright v. Goord, 554 F.3d 255, 274 (2d Cir.2009) (dismissing a retaliation claim whose only causal basis was a letter that plaintiff wrote many weeks before the allegedly retaliatory acts, implicating officers other than named defendants). See also Def. Mem. at 11 ("[A] claim that one defendant took action against the plaintiff in retaliation for a complaint made against a different [officer] [should be] viewed with particular skepticism."). 40 . Def, Mem. at 17. 41 . See id. (citing exclusively to Eighth Amendment cases). 42 .Id. 43 . See Wright, 554 F.3d at 274. 44 . Def. Mem. at 18. 45 . Def. Mem. at 19. 46 . Davis, 320 F.3d at 353. 47 . Dawes, 239 F.3d at 493. 48 . Compare Hofelich v. Ercole, No. 06 Civ. 1369, 2010 WL 1459740, at *2 (S.D.N.Y. Apr. 10, 2010) (<HOLDING>), with Rembert v. Cheverko, No. 12 Civ. 9196, 
 Holding statements: (A) holding that the plaintiffs placement on paid administrative leave constituted an adverse action for purposes of a first amendment retaliation claim (B) holding that a verbal threat of being fired is not an adverse employment action for purposes of title vii (C) holding that verbal threats if they are specific can constitute adverse action for retaliation purposes (D) holding that a suspension with pay may constitute materially adverse action for the purposes of retaliation claims depending on the facts of the case (E) holding that a transfer of job duties can constitute an adverse employment action
answer:

holding that the plaintiffs placement on paid administrative leave constituted an adverse action for purposes of a first amendment retaliation claim