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.

first time a party must specify the statute authorizing attorney’s fees is in the Rule 54 motion (unless otherwise provided by statute or court order). In Missouri, attorney’s fees are not recoverable from another party, except when a contract or statute allows it. Essex Contracting, Inc. v. Jefferson County, 277 S.W.3d 647, 657 (Mo. banc 2009). The second sentence of the Missouri commissions statute is such an exception to the general Missouri rule. Kraft v. Edwards, 946 S.W.2d 775, 776 (Mo.App.1997). The district judge’s ruling that there was no statutory basis for an award of attorney’s fees is erroneous as a matter of law. On remand, the district court should consider whether to award attorney’s fees. See Chem-Trend, Inc. v. Newport Indus., Inc., 279 F.3d 625, 631 (8th Cir.2002) (<HOLDING>). Because this case as tried addressed only 
 Holding statements: (A) recognizing discretion of district court in determining a fee award (B) holding that the most critical factor in determining the reasonableness of a fee award is the degree of success obtained (C) recognizing district courts discretion to consider pending state charge in determining sentence (D) recognizing court discretion in determining reasonable fee under rule 11 (E) holding that attorneys fee award in a common fund case must be  reasonable under the circumstances
holding that the most critical factor in determining the reasonableness of a fee award is the degree of success obtained

court is without power to extend that authority beyond the scope granted by the statute, and no District of Columbia court has ever found service upon such an unauthorized official to be valid against a foreign corporation. Accordingly, we conclude that service upon the Director was ineffective to bring Am-eritrade within the jurisdiction of the district court. Finally, Gorman urges that it would be unfair if a foreign corporation, lawfully subject to the jurisdiction of the District of Columbia because it does business here, could evade that jurisdiction by keeping its agents out of the District and hence beyond the range of effective service of process. If such a loophole does exist, the legislature can, of course, remove it by amending § 13-384 to provide an alternative method 1) (<HOLDING>); Oriental Trading Co. v. Firetti, 236 F.3d 
 Holding statements: (A) holding that making phone calls and sending facsimiles into the forum may be sufficient to confer specific jurisdiction (B) holding that purposeful availment may exist when a defendant makes phone calls and sends facsimiles into the forum state and such communications form the bases for the action of an intentional tort (C) holding that the defendant companys action in sending a representative to ohio to negotiate a resolution of a prior dispute did not confer personal jurisdiction (D) holding that foreseeability of causing injury in forum state is not sufficient for specific personal jurisdiction (E) holding that phone and facsimile communications to the forum purchase orders and payments sent to the forum a choice of law clause within the contract regarding the forum state and delivery of the product within the forum state were not enough to satisfy minimum contacts
holding that purposeful availment may exist when a defendant makes phone calls and sends facsimiles into the forum state and such communications form the bases for the action of an intentional tort

the period allowed for redemption the creditor file for record notice of intention to redeem with the county recorder or registrar of titles of each county where the mortgage is recorded. Minn.Stat. § 580.24 (1990). 13 . The City concedes that it forfeited its interest in the property under the mortgage by not redeeming under the Bank's foreclosure sale. 14 . The debtor's redemption period expired on December 2, 1988, and the City's redemption period expired five days later. 15 .The City would have no interest in the escrow fund under its assignment of rents even if it had redeemed under the Bank’s foreclosure sale because it obtained full satisfaction of the underlying mortgage debt through foreclosure. Compare Cross Cos. v. Citizens Mortgage Inv., 305 Minn. 111, 232 N.W.2d 114 (1975) (<HOLDING>) with G.G.C. Co. v. First Nat'l Bank of St. 
 Holding statements: (A) holding that the assignment of rents clause contained in the mortgage was enforceable during the period of redemption for the purpose of securing the 300000 deficiency existing after foreclosure of the mortgage (B) holding that the mortgagee had no right to rents under its assignment of rents during the redemption period because it purchased the property for the full amount of the mortgage debt at its foreclosure sale (C) holding that in a case in which an omitted junior mortgagee foreclosed its mortgage the junior mortgagee had the absolute right to redeem from the senior mortgagee who had purchased the property at a sale following foreclosure of the senior mortgage (D) holding that a mortgagee could enforce mortgage covenants requiring the mortgagors to keep the property free of encumbrances even after it foreclosed by advertisement and purchased the property for the full amount of the mortgage debt because the mortgage covenants concerned title to the mortgaged property rather than repayment of the debt (E) holding that an assignment of rents clause in a mortgage is enforceable after foreclosure during the redemption period to secure any deficiency and to pay any expenses associated with maintaining the property

holding that the assignment of rents clause contained in the mortgage was enforceable during the period of redemption for the purpose of securing the 300000 deficiency existing after foreclosure of the mortgage