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.

n. 7, 713 P.2d at 960 n. 7 (1986) (“Counsel has no right to cast upon the court the burden of searching through a voluminous record to find the ground of an objection. It is counsel’s duty to cite accurately the portions of the record supporting counsel’s position.” (Internal citation omitted.)); Hoang, 93 Hawaii at 336, 3 P.3d at 602 (2000) (“Because the factual basis of [appellant’s] alleged point of error is not part of the record on appeal, this court has no basis upon which to rule on the merits of his claim.” (Citation omitted.)) Even if Appellants’ allegations of fraudulent inducement are taken at face value, they fall short of “clear and convincing” evidence of fraudulent inducement. Honolulu Federal Savings & Loan Ass’n v. Murphy, 7 Haw. App. 196, 202, 753 P.2d 807, 812 (1988) (<HOLDING>). At a more fundamental level, they do not 
 Holding statements: (A) holding that a finding of fraud may be reversed only for clear error but that the finding must be judged in view of the clear and convincing burden of proof (B) holding that despite the lack of a statutory requirement that severe child abuse be shown by clear and convincing evidence due to the consequences of such a finding the clear and convincing standard must be applied (C) holding that the standard of proving fraudulent inducement with respect to written contracts is extremely high and a written contract will be cancelled only in a clear ease of fraud supported by clear and convincing evidence citations omitted (D) holding that fraud on the court must be supported by clear unequivocal and convincing evidence (E) holding clear and convincing standard to prove fraud or fraudulent intent and preponderance of the evidence to prove other elements under  727
holding that a finding of fraud may be reversed only for clear error but that the finding must be judged in view of the clear and convincing burden of proof

. . . there was a causal connection between the protected activity and the adverse employment decision[s].” Murray v. St. Michael’s Coll., 164 Vt. 205, 210, 667 A.2d 294, 299 (1995). In Burlington Northern, the Supreme Court held that a plaintiff bringing a retaliation claim under Title VII need show only that “a reasonable employee [in the employee’s situation] would have found the challenged action materially adverse,” meaning that it well might have dissuaded a reasonable employee from engaging in the protected activity. 548 U.S. at 68. ¶ 34. Assuming, without deciding, that this is the standard to apply with respect to retaliation claims brought under 21 V.S.A. § 710(b), we conclude that the limited video surveillance in this case in connectio v., 37 F.3d 1146, 1150 (5th Cir. 1994) (<HOLDING>). ¶ 35. But in this case, if the release 
 Holding statements: (A) holding that the former wife did not waive her attorneyclient privilege simply because the credibility of her claim that she relied on her husbands representations could be impeached by deposing her former attorney (B) holding that threatening employee to mind her own business investigating her videotaping her without her permission and forcing her to take polygraph could not be considered adverse employment actions because they had no effect on conditions of employment (C) holding that because a claimant testified that she had no insurance and could not afford treatment her failure to take medication for her symptoms is not a clear and convincing reason for discrediting her symptom testimony (D) holding that a teachers complaint to school authorities that her principal had instructed her to make improper changes in her own students grades was unprotected because it was made pursuant to her official duties (E) holding that the employee was acting within the course of her employment when she died while returning from the workrelated session because her death occurred on a public highway which was brought within the scope of her employment by her employers requirement that she attend training at the state police academy
holding that the former wife did not waive her attorneyclient privilege simply because the credibility of her claim that she relied on her husbands representations could be impeached by deposing her former attorney

an attorney. With respect to the first explanation, this Court has repeatedly held that while pro se litigants are entitled to special solicitude, “[a]ll litigants, including pro ses, have an obligation to comply with court orders.” Valentine, 29 F.3d at 50 (quoting Minotti, 895 F.2d at 103); see also Agiwal, 555 F.3d at 302. Houghton failed to seek clarification from the district court of any order he found unclear. In rejecting Houghton’s explanation based on his purported difficulties in retaining an attorney, the district court reasonably took into account Houghton’s termination of two separate attorneys over the course of the litigation and that he fired his last attorney in April 2009 — some 18 months before the scheduled trial date. See S. New England Tel. Co., 624 F.3d at 144 (<HOLDING>) (internal quotation omitted). Moreover, 
 Holding statements: (A) holding that the district court is not free to consider the potential for issue reduction when determining whether a putative intervener has a protectable interest in the merits of the action (B) holding that the appropriate sanction was to require the defendant to disclose the nature of the agreement with the witness (C) holding that in exercising its discretion in choosing the appropriate sanction the trial court is not limited to considering only the specific violation committed but is entitled to consider other matters which have occurred during the litigation (D) holding that while the nonprevailing partys financial condition is not appropriate to consider in determining whether to award attorneys fees it is appropriate to consider when determining the amount of the attorneys fees (E) holding that the district court is free to consider the full record in the case when selecting the appropriate sanction

holding that the district court is not free to consider the potential for issue reduction when determining whether a putative intervener has a protectable interest in the merits of the action