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.

Q: 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

A: holding that the automatic stay barred a suit for injunctive relief to prevent postpetition antitrust violations
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Q: the effect that the code-fendant’s confession must be disregarded in determining the defendant’s guilt or innocence is ineffective and cannot overcome the prejudicial effect of the incriminating statement on the jury. Id. at 124, 88 S.Ct. 1620. As such, the trial court’s curative instruction in the instant case was insufficient to cure the erroneous admission of Hertz’s statement to Hathcock. Nonetheless, this Court has also recognized that a Bruton violation does not automatically require reversal of an otherwise valid conviction but, rather, is subject to a harmless error analysis. See Farina v. State, 679 So.2d 1151, 1155 (Fla.1996) (citing Harrington v. California, 395 U.S. 250, 254, 89 S.Ct. 1726, 23 L.Ed.2d 284, (1969)); see also Franqui v. State, 699 So.2d 1312, 1322 (Fla.1997) (<HOLDING>); Smith v. State, 699 So.2d 629, 644-45 
 Holding statements: (A) holding that confrontation clause violation was not harmless beyond a reasonable doubt in part because it concerned the limitation of crossexamination of the prosecutions key witness (B) holding that the sixth amendment confrontation clause violation in that case was harmless beyond a reasonable doubt and therefore did not require the conviction to be overturned (C) holding that a confrontation clause violation constituted harmless error (D) holding confrontation clause violation was harmless beyond a reasonable doubt and thus upholding firstdegree murder conviction (E) holding that testimony at trial in violation of defendants constitutional confrontation right was harmless beyond a reasonable doubt because the testimony was cumulative

A: holding that confrontation clause violation was not harmless beyond a reasonable doubt in part because it concerned the limitation of crossexamination of the prosecutions key witness
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Q: amendment is not futile. Moreover, “the statute of limitations under the New York State Labor Law is six years, posing no hurdle to amendment here.” Hosking v. New World Mortg., Inc., 602 F.Supp.2d 441, 446 (E.D.N.Y.2009). However, with respect to plaintiff Vanderheydt, the Court finds that it lacks sufficient information to determine whether the proposed amendment would be futile because the Proposed Second Amended Complaint fails to provide the time period in which Vanderheydt contends he was denied minimum wage and overtime compensation in violation of the FLSA. Generally, the absence of such information from a complaint is grounds for dismissal pursuant to Fed.R.Civ.P. 12(b)(6). See DeSilva v. North Shore-Long Island Jewish Health Sys., Inc., 770 F.Supp.2d 497, 509 (E.D.N.Y.2011) (<HOLDING>). On the other hand, “the statute of 
 Holding statements: (A) holding that flsa which provides an exemption from the acts wage and overtime provisions for fishermen preempts claims under alaskas minimumwage and overtime statute (B) holding that a plan administrators decision to deny benefits was arbitrary and capricious even though an attending physician had submitted a form stating the plaintiff could sit for six hours stand for two hours and walk for two hours (C) holding that to state a claim for wage violations under the flsa plaintiffs must provide at least some approximation of the overtime hours that defendants required them to work and a time frame for when those hours were worked (D) holding that the flsa does not prohibit changes in wage rates it prohibits the payment of overtime at less than one and onehalf times the regular wage rate (E) holding illinois wage law only applied where at least some work was performed within the state

A:
holding that flsa which provides an exemption from the acts wage and overtime provisions for fishermen preempts claims under alaskas minimumwage and overtime statute
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