instruction:
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.
question:
to pay the purchase price. 3.Pursuant to the Securities Purchase Agreement, dated September 2, 2004, Mer-vyn's Holdings purchased 100% of the interests in Holdings I and Holdings II for $429,746,414,84. At the closing, Mervyn’s Holdings used these funds to pay the purchase price. (Am.Compl.$ 58). 5 . Brandt v. Trivest II, Inc. (In re Plassein Int’l Corp.), 352 B.R. 36, (Bankr.D.Del.2006) ("Accordingly, the Court joins with those decisions that have (either implicitly or explicitly) evaluated fraudulent transfer complaints using Rule 8(a)(2)’s notice pleading standard”) Id. at 40-41. See. e.g., Giuliano v. U.S. Nursing Corp. (In re Lexington Healthcare Group, Inc.), 339 B.R. 570, 574-75 (Bankr.D.Del.2006) (applying "liberal notice pleading standard”); AstroPower, 335 B.R. at 333 (<HOLDING>); Official Comm, of Unsecured Creditors v. DVI 
 Holding statements: (A) holding despite collective allegations in complaint the complaint was not deficient under rule 8a because it stated with sufficient particularity facts establishing a causal connection between the defendants actions and the constitutional deprivation (B) holding that a fraudulent transfer complaint need only set forth the facts with sufficient particularity to apprise the defendant fairly of the charges made against him (C) holding that the fraud claims against the defendant should not have been dismissed as the complaint provided him with fair notice of the claims made against her (D) holding that the information must set forth each element of the crime that it charges as well as fairly inform a defendant of the charge against which he must defend (E) holding that a criminal defendant is entitled to know the charges against him and to be tried solely upon the charges against him internal quotation marks and citation omitted
answer:
holding despite collective allegations in complaint the complaint was not deficient under rule 8a because it stated with sufficient particularity facts establishing a causal connection between the defendants actions and the constitutional deprivation


question:
(Tex.2010) (orig. proceeding). Failure to exhaust administrative remedies creates a jurisdictional bar to proceeding with the claim. See City of Waco v. Lopez, 259 S.W.3d 147, 154 (Tex.2008) (“[Njoncompliance [with Chapter 21’s administrative procedures] deprives courts of subject-matter, jurisdiction.”); Smith v. Univ. of Tex. Sw. Med. Ctr. of Dallas, 101 S.W.3d 185, 188 (Tex.App.-Dallas 2003, no pet.). A would-be Chapter 21 claimant must first file an administrative complaint with the civil rights division of the Texas Workforce Commission. See Tex. Lab.Code Ann. § 21.201(a) .(stating that an aggrieved person “may file a complaint with the commission”); id. § 21.0015 (defining “commission” as “the Texas Workforce ■Commission civil rights division”); Schroeder, 813 S.W.2d at 486-88 (<HOLDING>). The complaint must be filed “not later than 
 Holding statements: (A) holding use of word may generally indicates permissive rather than mandatory intent (B) holding that a states use of the word shall is mandatory language (C) holding that exhaustion is mandatory and jurisdictional (D) holding that administrative exhaustion is mandatory despite legislatures use of the word may (E) recognizing that exhaustion is mandatory and jurisdictional
answer:
holding use of word may generally indicates permissive rather than mandatory intent


question:
of Rule 13.1(a) in 2002. See Tex.R.App. P. 13.1(a). However, the 2002 amendment followed substantial discussion of whether the duty should be mandatory or only upon request. See Hearing of the Supreme Court Advisory Committee, 5398-5425 (Jan. 25, 2002). The Supreme Court Advisory Committee on the Rules of Civil Procedure initially recommended that the rule be modified to make the duty operative only upon request. Id. 5398-99. However, the Supreme Court of Texas responded that it was “not inclined to change the Rule substantively.” Id. In the discussion that followed, it was pointed out that most trial court proceedings are not recorded, id. at 5403-04; section 52.046 of the Texas Government Code made the court reporter’s duty operative on Tex.App.-Houston [1st Dist.] 2000, pet. ref'd) (<HOLDING>); but see Nabelek, — S.W.3d at -, 2005 WL 
 Holding statements: (A) recognizing collateral attack on void order (B) holding annexation ordinance void (C) holding that the word void is not sufficient (D) holding rule 131a void (E) holding void judgment must be vacated
answer:

recognizing collateral attack on void order