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:
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
answer:
holding that the automatic stay barred a suit for injunctive relief to prevent postpetition antitrust violations


question:
of record rather than the alien. The Federal Rules of Civil Procedure also favor notice of counsel of record rather than actual notice of the client. See Fed.R.Civ.P. 5(b) (stating that “whenever service under these rules is required or permitted to be made upon a party represented by an attorney the service shall be made upon the attorney unless service upon the party is ordered by the court”). Case precedent also indicates that actual notice of an alien is not required under the INA. See Sewak v. INS, 900 F.2d 667, 669 n. 6 (3d Cir.1990) (noting in dicta that notice to attorney comprised actual notice to alien); Reyes-Arias v. INS, 866 F.2d 500, 502-3 (D.C.Cir.1989) (finding actual knowledge of attorney constitutes reasonable notice); Newton v. INS, 622 F.2d 1193, 1194 (3d Cir.1980) (<HOLDING>). Anin received notice as required by the INA. 
 Holding statements: (A) holding that notice to supervisor is notice to city (B) holding that notice to the attorney of record constitutes notice to the petitioner (C) holding that actual notice fulfills a notice requirement that an applicable federal regulation be conspicuously posted because actual notice is the best notice (D) holding that a defendant is not entitled to relief from default judgment because notice to an attorney of filing of motions and orders is constructive notice to the client even when the client did not have actual notice (E) holding that notice to original attorney not formally withdrawn comprised proper notice
answer:
holding that notice to supervisor is notice to city


question:
requires that the convict must have been sentenced to separate terms of at least one year for each of his two prior felonies. Id. However, Section 99-19-83 provides that any person convicted of a felony that has two previous felony convictions, one of those being a conviction of a violent crime, that person will be sentenced to life imprisonment without the possibility of parole or probation. Miss. Code Ann. § 99-19-83 (Rev.2000) (emphasis added). ¶ 12. This issue has been examined before. The Mississippi Supreme Court determined that “[i]t [is] not necessary for the State to specify in the indictment which section of the habitual criminal statute they were proceeding under.” Ellis v. State, 469 So.2d 1256, 1258 (Miss.1985) (citing Osborne v. State, 404 So.2d 545, 548 (Miss.1981)) (<HOLDING>). ¶ 13. Assuming, for the sake of the argument, 
 Holding statements: (A) recognizing that the two statutes are nearly identical (B) holding that in the conviction and sentencing for criminal offenses committed in the course of one criminal episode it is the intent of the legislature that there be a separate conviction and sentence for each criminal offense unless one of the offenses is a degree of the other a necessarily included lesser offense subsumed in the other or both offenses are identical (C) holding these two statutes are not criminal offenses and only affect sentencing (D) holding that claims under  1983 1985 and 1986 are barred for the further reason that these statutes create rights solely against persons and a state is not considered a person under these statutes (E) holding that when two underlying offenses are charged in an indictment for capital murder the state need only prove one of the two offenses to support the conviction
answer:

recognizing that the two statutes are nearly identical