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]: the defendant’s applicable guideline range because of the operation of another guideline or statutory provision (e.g., a statutory mandatory minimum term of imprisonment).” Id., app. note 1(A). In November 2007, the Sentencing Commission issued Amendment 706, which reduced the base offense level for crack cocaine offenses under § 2Dl.l(c) by two levels. See U.S.S.G. App. C, Amend. 706 (Nov. 1, 2007). The Commission later made the amendment retroactively applicable. See U.S.S.G. App. C, Amend. 713 (Supp. May 1, 2008). As indicated, Jefferson sought to have his sentence reduced as result of those amendments. However, they do not apply here because Jefferson was sentenced to a mandatory minimum sentence required by statute. See United States v. Doe, 564 F.3d 305, 311-12 (3d Cir.2009) (<HOLDING>). Because the District Court did not abuse its 
 Holding statements: (A) holding that the operative provision in determining the defendants applicable sentencing range is the statutory minimum  not the crack cocaine guideline and that the defendants were still subject to the mandatory minimum upon which their substantial assistance departures  and thus them ultimate sentences  were based (B) holding that a defendant whose original sentence was based upon the careeroffender guideline and not  2d11 could not receive a sentence reduction based on amendment 706 because it did not have the effect of lowering the applicable guideline range (C) holding that while amendment 706 was applicable to the defendants in question because it reduced their base offense levels a reduction was not authorized because the amendment did not have the effect of lowering their applicable guideline ranges because of the application of the career offender guideline (D) holding that amendment 706 did not have the effect of lowering the applicable guideline range where the defendants received statutory mandatory minimum sentences and thus the defendants were not eligible for relief under  3582 (E) holding that while amendment 706 was applica ble to the defendants in question because it reduced their base offense levels a reduction was not authorized because the amendment did not have the effect of lowering their applicable guideline ranges because of the application of the career offender guideline
[EX A]: holding that the operative provision in determining the defendants applicable sentencing range is the statutory minimum  not the crack cocaine guideline and that the defendants were still subject to the mandatory minimum upon which their substantial assistance departures  and thus them ultimate sentences  were based

[EX Q]: 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
[EX 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

[EX Q]: retail installment sales contract for eight vehicles nonexecutory where debtor’s only obligation was payment and creditor’s only obligation concerned limited repair warranty); Riggs Nat. Bank of Wash, D.C. v. Perry (In re Perry), 25 B.R. 817, 819-20 (Bankr.D.Md.1982) (finding installment sales contracts for vehicles not executory within meaning of § 365); Brock v. Am. Sec. Bank (In re Brock), 23 B.R. 998, 1002 n. 8 (Bankr.D.D.C.1982) (noting, without deciding, that installment sales contract for vehicle purchase “would not ordinarily be deemed an executory contract simply because the sole and remaining obligation under the contract is that of the debtor to maintain periodic contractual payments called for in the contract itself’); In re Whatley, 16 B.R. 394, 398 (Bankr.N.D.Ohio 1982) (<HOLDING>). Accordingly, we affirm the nonexe-cutory 
 Holding statements: (A) holding that a lien cannot be estopped into existence where the borrowers promised to execute a lien in the manner mandated by the constitution and then failed to do so (B) holding the beginning of a creditors action to subject an equitable estate to the payment of a judgment gives a specific lien upon the property which it is sought to reach and this lien continues while the cause is pending (C) holding that the lien bond releases the property from the lien but the lien is then secured by the bond (D) holding that insurance obligation was primary to indemnity obligation (E) holding creditors obligation to cancel lien not sufficient to make the contract execute ry
[EX A]:
holding that a lien cannot be estopped into existence where the borrowers promised to execute a lien in the manner mandated by the constitution and then failed to do so