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]: (1986) (relying on section 45(1) and comment a). 24 . See e.g., United States R.R. Ret. Bd. v. Fritz, 449 U.S. 166, 174 (1980) (“railroad [retirement] benefits are not contractual and may be altered or even eliminated at any time”); Devlin v. Transportation Communications Int’l Union, 173 F.3d 94, 103 (2nd Cir. 1999) (a claim to vested welfare benefits is contradicted by the ... unambiguous reservation in the plan documents of its right to amend the plan”); International Union, United Auto., Aerospace and Agric. Implement Workers of Amer. v. BVR Liquidating Inc., 190 F.3d 768, 773 (6th Cir. 1999) (“the inclusion of a ‘reservation of rights’ provision establishes that there was no intent for benefits to vest”); McGrath v. Rhode Island Retirement Bd., 88 F.3d 12, 17-18 (1st Cir. 1998) (<HOLDING>); In re Unisys Corp. Retiree Medical Benefit 
 Holding statements: (A) holding that performance of employment services constituted acceptance of the offer of participation in bonus plan and a binding unilateral contract was thereby formed (B) recognizing that generally    with supposed unilateral contracts  if the offeror expressly reserves the power to revoke the offer until the offerees performance is complete then the offer is illusory and cannot give rise to a unilateral contract but noting exceptions (C) holding that the offerors signature on the offerees conditional acceptance bound the offeror to all the terms therein (D) holding that an offer to donate cannot be an offer to sell (E) holding that a written offer accepted by parol may constitute a sufficient memorandum of the contract provided the person making the offer is the party to be charged
[EX A]: holding that performance of employment services constituted acceptance of the offer of participation in bonus plan and a binding unilateral contract was thereby formed

[EX Q]: seeking to invoke the exception must establish that they agreed to engage in a joint effort and to keep the shared information confidential from outsiders. See, e.g., United States v. Schwimmer, 892 F.2d 237, 243-44 (2d Cir.1989) (finding valid joint defense privilege where information was “imparted in confidence” between parties “who had agreed upon and undertaken a joint strategy”); United States v. Sawyer, 878 F.Supp. 295, 297 (D.Mass.1995) (despite similar interests between employer and employee, insufficient evidence that communications were made during the course of a joint defense effort; proponent could neither establish time frame of agreement nor acts creating and/or terminating the agreement); United States v. United Tech. Corp., 979 F.Supp. 108, 110, 112 (D.Conn.1997) (<HOLDING>); Libbey Glass, Inc. v. Oneida, Ltd., 197 
 Holding statements: (A) holding common interest doctrine shielded information consortium members shared pursuant to collaboration agreement (B) recognizing doctrine (C) recognizing that tribes and states understood that they shared the right to manage the exercise of in common hunting and fishing rights (D) recognizing a subset of the common interest privilege as parents and schools have a corresponding interest in the free flow of information about administrators and faculty members (E) holding that there was no waiver of the work product protection because the business and public relations firm specializing in litigationrelated crisis management shared a common interest
[EX A]: recognizing doctrine

[EX Q]: bar, Carlock and Reid were engaged in a “minor confrontation” about ten to twenty feet away from him. (J.A. 54-55.) 7 Given the context in which the police report was used to cross-examine Decatur, we assume thatit was used under the past recollection recorded exception. See Fed. R. Evid. 803(5). The police report was not admitted into evidence. We do note, however, that the prosecution did not object to the use of the police report and the trial court judge did not explicitly rule on the use of the police report during cross-examination. 8 “[Credibility] determinations are the sole province of the jury.” Gov’t of the Virgin Islands v. Henry, 232 Fed. Appx. 170, 174 (3d Cir. 2007); see also U.S. v. Jannotti, 673 F.2d 578, 598 (3d Cir. 1982) (en banc), cert. denied, 457 U.S. 1106 (1982) (<HOLDING>). The Third Circuit has held that the testimony 
 Holding statements: (A) holding that the credibility determinations by the board are virtually unreviewable (B) holding that the credibility determinations of hearing officers are afforded special deference (C) holding that credibility determinations are reviewed only for substantial evidence (D) holding that credibility determinations are for the jury (E) holding that we review adverse credibility determinations for substantial evidence
[EX A]:
holding that the credibility determinations by the board are virtually unreviewable