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.

are differences between sanctions under Rule 37(a) and substitution of counsel conditioned on payment of fees, the parallel considerations convince us that the Cunningham rationale applies here. Like Rule 37(a) sanctions, the present situation invokes concerns regarding finality, avoiding piecemeal appeals, and availability of effective appellate review.” Id. Cases from the First, Second, Third, and Fifth Circuits further support interpreting Cunningham as applying more broadly than to Rule 37(a) sanctions alone. The First Circuit recognized in Empresas Omajede, Inc. v. Bennazar-Zequeira, 213 F.3d 6, 9 n. 4 (1st Cir.2000), that Cunningham affirmed its precedents denying interlocutory appeals in the sanctions area. See, e.g., United States v. Kouri-Perez, 187 F.3d 1, 14 (1st Cir.1999) (<HOLDING>); Appeal of Licht & Semonoff 796 F.2d 564, 573 
 Holding statements: (A) holding district courts order postponing ruling on defendants qualified immunity defense was immediately appealable (B) holding sanctions pursuant to rule 26g not immediately appealable (C) holding sanctions order pursuant to district courts inherent powers not immediately appealable (D) holding such denial to be an immediately appealable collateral final order (E) holding an order of rule 37a sanctions against an attorney is immediately appealable under  1291
holding district courts order postponing ruling on defendants qualified immunity defense was immediately appealable

issue, we need not consider the second argument raised. 7 . In a dissent to Smith, Judge Friedman, joined by Judges Pellegrini and Kelley, objected to following the Miller/Lewis/Selan line of cases which automatically equated the refusal to sign a hospital consent form with a refusal to submit to chemical testing. The dissenting judges expressed preference for the other line of caselaw, particularly Conrad, and noted that because Smith orally agreed to the blood test and only refused to sign the hospital consent form, which was a pre-test procedure linked to the test, although not required by section 1547, Smith did not make a knowing and conscious refusal to submit to chemical testing. 8 . Wheatley v. Commonwealth, Department of Transportation, 104 Pa.Cmwlth. 171, 521 A.2d 507 (1987) (<HOLDING>). 9 Although Renwick does not expressly 
 Holding statements: (A) holding refusal to sign hospital waiver of liability form is not a refusal under section 1547 (B) holding that refusal to consent to search cannot support a finding of reasonable suspicion (C) holding that refusal to submit to breathalyzer test did not result from custodial interrogation (D) holding that a refusal to sign an implied consent form is not a refusal to submit to a breathalyzer test for purposes of section 1547 (E) holding that a district court did not clearly err in crediting agents testimony that a defendant had orally consented despite his refusal to sign consent form
holding refusal to sign hospital waiver of liability form is not a refusal under section 1547

The Steins contend that those remedies are not good enough to “obligate” Paradigm to construct the condominium in two years, as required by § 1702(a)(2) of the Disclosure Act. They argue that without the remedies of special, consequential, punitive, speculative, and indirect damages, which they expressly waived in the contract, they cannot inflict enough legal pain on Paradigm to force it to carry out its contractual duty to finish within two years. Specific performance or injunctive relief, if vigorously pursued, ordinarily will be enough to force a seller to fulfill its contractual obligations within the time a contract requires. Florida law provides that a party may sue for specific performance and obtain an injunction that “shall specify the time within which the ac 3d DCA 1979) (<HOLDING>). A court order requiring a party to perform as 
 Holding statements: (A) holding that a party does not automatically qualify as a real party in interest merely because it has been named as a defendant in a declaratory judgment action (B) holding that a party may be held in contempt for refusing to comply with a specific performance judgment requiring the party to sell a piece of real estate (C) holding that a party may not contract away the protection that a statute is intended to afford him nor may the other party to the contract exempt itself from its duty to comply with such statute (D) holding prospectively that a vendees interest in a real estate contract constitutes real estate within the meaning of the judgment lien statute (E) holding that trustee may bring assigned creditor claims where estate is the real party in interest

holding that a party does not automatically qualify as a real party in interest merely because it has been named as a defendant in a declaratory judgment action