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: 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

A: holding district courts order postponing ruling on defendants qualified immunity defense was immediately appealable
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Q: and began questioning the two men. The fact that the detectives in this ease requested that Peterkin answer questions apart from Durovic, and separated them by about ten feet, does not convert an otherwise voluntary encounter into a seizure under the Fourth Amendment. The first moment at which Peterkin may have been seized was when Detective Lascik took Peterkin’s identification back to the van to run a background cheek. By that time, however, Peterkin and Durovic had already given the detectives conflicting stories, including whether they knew each other. This inconsistency, together with the detectives’ earlier observations of their unusual behavior, was enough to create reasonable suspicion to support a Terry stop. See United States v. Givan, 320 F.3d 452, 458-59 (3d Cir.2003) (<HOLDING>); United States v. Brown, 345 F.3d 574, 578 
 Holding statements: (A) holding an officer may order a passenger to get out of a car during a traffic stop and may frisk a passenger for weapons if the officer reasonably suspects the passenger is armed and dangerous (B) holding that after receiving conflicting stories from a driver and passenger the officer had reasonable suspicion to expand the scope of the terry stop and conduct background checks on them both (C) holding that receiving conflicting stories from the driver and passenger of a stopped car about their travel gave the officer reasonable suspicion to extend the terry stop (D) holding that it was impermissible for an officer to question a driver about matters unrelated to the traffic stop after the officer had fulfilled the purpose of the stop by issuing a written warning to the driver (E) holding that a police officer may stop a driver where the officer has a reasonable and articulable suspicion regarding the commission of a civil traffic violation

A: holding an officer may order a passenger to get out of a car during a traffic stop and may frisk a passenger for weapons if the officer reasonably suspects the passenger is armed and dangerous
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Q: 909, 435 P.2d 248, 249 (1967). The plain language of I.R.E. 201(d) requires specificity in identifying what documents or items the district court is requested take notice of. See, e.g., Taylor v. McNichols, 149 Idaho 826, 835, 243 P.3d 642, 651 (2010). The Idaho Supreme Court held that where a party is requesting that a court take judicial notice of a document or items, that party must state with particularity what he or she is asking the court to take notice of. Id. at 835, 243 P.3d at 652. Where a party does not meet this requirement, it is improper for a court to take judicial notice under I.R.E, 201(d). Taylor, 149 Idaho at 835, 243 P.3d at 652. If a party fails to specify which material from the underlying case he or she is requesting, judicial notice is not mandatory. See id. (<HOLDING>). Fortin argues that Taylor is not controlling 
 Holding statements: (A) holding that a notice of deficiency was invalid where it was the second notice mailed for that year and the taxpayer timely petitioned the court as to the first notice (B) holding that a notice to produce personal papers was unconstitutional and void and that the inspection by the district attorney of said invoice when produced in obedience to said notice and its admission in evidence by the court were erroneous and unconstitutional proceedings (C) recognizing that the court may take judicial notice of its own docket (D) holding that where it was erroneous for the district court to take judicial notice it certainly cannot be said that such notice was mandatory and therefore ire 201d is inapplicable (E) holding statute requiring parties in tax suit to take notice of subsequent pleadings was not unconstitutional when city failed to take such notice

A:
holding that a notice of deficiency was invalid where it was the second notice mailed for that year and the taxpayer timely petitioned the court as to the first notice
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