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]: 602 F.Supp. 859, 864 (D.N.J.1985); Tedesco v. U.S. Po esentation against the Government. 28 U.S.C. § 2680(h). Further, the FTCA requires, as a jurisdictional prerequisite to adjudication in a federal court, all claims to first be brought before the appropriate agency-here, the USPS’s Tort Claims Examiner. See 28 U.S.C. § 2675(a). It is undisputed that Mr. Foster did not bring his claims to the USPS before initiating this suit. Thus, the district court correctly dismissed these claims for lack of subject matter jurisdiction. II Mr. Foster also challenges the district court’s denial of his motion for reconsideration and its denial of sanctions against USPS. We review these determinations for abuse of discretion. Q-Pharma, Inc. v. Andrew Jergens Co., 360 F.3d 1295, 1299 (Fed.Cir.2004) (<HOLDING>); Gary v. The Braddock Cemetery, 517 F.3d 195, 
 Holding statements: (A) holding that a motion for rule 11 sanctions is dispositive (B) holding that state law provides the standard of review for a denial of a rule 50 motion in a diversity case (C) holding under third circuit law that denial of rule 11 sanctions is reviewed for abuse of discretion (D) holding that courts of appeals should review all aspects of the district courts rule 11 determination for abuse of discretion and noting that the district court has broad discretion to impose rule 11 sanctions (E) holding that the standard of review for the denial of rule 11 sanctions is governed by the law of the regional circuit
[EX A]: holding that a motion for rule 11 sanctions is dispositive

[EX Q]: was merely acting as Casey’s nominee by allowing him to park 28th Place in her name without relinquishing the benefits of ownership of the property. The district court agreed with the government and allowed forfeiture on this ground. Black’s Law Dictionary defines a “nominee” (in the context of property law) as a “party who holds bare legal title for the benefit of others or who receives and distributes funds for the benefit of others.” Black’s Law Dictionary 1149 (9th ed.2009). Unlike a party with a cognizable property interest, a nominee cannot claim a viable third-party interest sufficient to render a forfeiture invalid. See People v. Chicago Title and Trust Co., 75 Ill.2d 479, 27 Ill.Dec. 476, 389 N.E.2d 540, 544 (1979); United States v. Herrero, 893 F.2d 1512, 1542 (7th Cir.1990) (<HOLDING>), abrogated on other grounds by United States 
 Holding statements: (A) holding lopez was inapplicable to the language prior conviction for a felony drug offense in 21 usc  841b1a because felony drug offense was defined in 21 usc  80244 as an offense that is punishable by imprisonment for more than one year under any law of the united states or of a state (B) recognizing that we held in tilley that the forfeiture of proceeds from illegal drug sales pursuant to 21 usc  881a6 does not constitute punishment (C) holding that drug quantity is an element of an offense under 21 usc  841 (D) holding that scope of property subject to forfeiture is defined by the instrument creating an interest in the property (E) holding that property held by another as nominal owner for benefit of a drug dealer subject to forfeiture under 21 usc  853
[EX A]: holding lopez was inapplicable to the language prior conviction for a felony drug offense in 21 usc  841b1a because felony drug offense was defined in 21 usc  80244 as an offense that is punishable by imprisonment for more than one year under any law of the united states or of a state

[EX Q]: property is properly analyzed under takings law, a court must first examine whether the government intended to invade a protected property interest or whether the alleged invasion of a claimant’s property was the direct, natural, or probable result of defendant’s intentional actions. Id. at 1355-56. Next, the court must determine whether the government appropriated a benefit for itself at the property owner’s expense or preempted the owner’s right to enjoy their property for an extended period of time. Id. at 1357-58. In order to meet the second prong of the test, plaintiffs must prove that defendant’s interference with their property “was substantial and frequent enough to rise to the level of a taking.” Id. at 1357; see also Moden v. United States, 404 F.3d 1335, 1342 (Fed.Cir.2005) (<HOLDING>); Wilfong v. United States, 480 F.2d 1326, 1329 
 Holding statements: (A) holding that the measure of damages of converted property is the market value at the time of conversion (B) holding that testimony by the owners expert to the value of trees on appropriated property was properly admitted to rebut or impeach testimony by the appropriating agencys expert that the trees had no value in terms of their effect on the propertys market value (C) holding that the state is obligated to pay property owners when it regulates private property under its police power in such a manner that the regulation effectively deprives the owner of the economically viable use of that property (D) holding that a takings claimant must show that the invasion appropriated a benefit to the government at the expense of the property owner at least by preempting the property owners right to enjoy its property for an extended period of time rather than merely by inflicting an injury that reduces the propertys value (E) holding that the property owners testimony alone placed the value of the stolen property above the amount necessary to constitute grand larceny
[EX A]:
holding that the measure of damages of converted property is the market value at the time of conversion