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]: bar, of rule 32:1.3 for dilatory handling of estates despite notices and inquiries from beneficiaries). Johnson’s failure to respond to Neefs phone calls and requests for information, failure to notify Neef of what progress had or had not been made on the case, and failure to provide notice of termination, contact information, return of paperwork, or a return of unearned fees violated rules 32:1.4 (duty to keep client informed) and 32:1.16(d) (duty to protect client’s interests upon termination of representation). See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Carpenter, 781 N.W.2d 263, 268 (Iowa 2010) (finding attorney’s neglect of client’s legal matters and failure to keep clients informed about their cases violated rules 32:1.3, 32:1.4, and 32:1.16(d)); Earley, 774 N.W.2d at 307-08 (<HOLDING>). Johnson also violated rule 32:8.4(c) (duty 
 Holding statements: (A) holding that the attorney violated mlrpc 13 when he did not prosecute his clients claim after filing a complaint or protect against expiration of the statute of limitation for his clients complaint and caused discovery sanctions to be filed for his failure to respond to discovery requests (B) holding an attorney violated his duty of candor to the tribunal by changing his clients interrogatory answers without the clients knowledge (C) holding attorney violated rules 3214 and 32116d when he failed to keep his clients informed about the status of their cases failed to communicate with his clients after their repeated requests for information and failed to  account for or return client money from retainer fees (D) holding that a law firm receiving funds for a client was not an initial transferee because the firms role with respect to the received money was to accept the funds in settlement of its clients case deposit the money in trust keep as fees only what the the clients agreed to and pay the rest to the bank on behalf of the clients in satisfaction of their loan (E) holding that equitable tolling applied when the attorney informed his client there was no such thing as a oneyear filing deadline and consistently lied to his client and the clients wife
[EX A]: holding that the attorney violated mlrpc 13 when he did not prosecute his clients claim after filing a complaint or protect against expiration of the statute of limitation for his clients complaint and caused discovery sanctions to be filed for his failure to respond to discovery requests

[EX Q]: of other courts have concluded, outside the RICO and Clayton Act context, that "by reason of" should be read to require only "but for” rather than proximate causation. See, e.g., Gross v. FBL Fin. Servs., Inc., 557 U.S. 167, 129 S.Ct. 2343, 2350, 174 L.Ed.2d 119 (2009) ("The words ‘because of' mean ‘by reason of: on account of.’ Thus, the ordinary meaning of the ADEA's requirement that an employer took adverse action ‘because of age is that age was the ‘reason’ that the employer decided to act. To establish a disparate-treatment claim under the plain language of the ADEA, therefore, a plaintiff must prove that age was the ‘but-for’ cause of the employer’s adverse decision.” (citations omitted) (emphasis added)); Robinson Knife Mfg. Co. v. C.I.R., 600 F.3d 121, 131-32 (2d Cir. 2010) (<HOLDING>); Spirtas Co. v. Ins. Co. of Pa., 555 F.3d 647, 
 Holding statements: (A) holding that in 26 cfr  1263ale3i the language  directly benefit or are incurred by reason of boils down to a butfor causation test (B) holding that fees incurred by debtor were not in the nature of support (C) holding in an appeal from a postanswer default judgment that third prong of craddock test required appellant to offer to reimburse appellee for legal expenses he incurred in obtaining default judgment even though most of the fees incurred had not been paid (D) holding that pursuant to the eaja courts may not award expenses of an attorney that are not incurred or expended solely or exclusively in connection with the case before the court (E) holding a tribe subject to 1 a tax on the use of certain highway motor vehicles 26 usc  4481a 2 a tax on diesel fuel used in highway vehicles 26 usc  4041a 3 a tax on special fuels used in motor vehicles 26 usc  4041b and 4 a tax on manufacturing in this case a truck chassis assembled by the tribe 26 usc  4061a 4218a
[EX A]: holding that fees incurred by debtor were not in the nature of support

[EX Q]: by Kratzer’s testimony, not wife’s. As such, it is admissible béeause it is the admission of one co-conspirator uttered in the furtherance of a conspiracy. See Commonwealth v. Evans, 489 Pa. 85, 413 A.2d 1025 (1980). If any portion of the transcript should have been redacted to exclude wife’s conversation, such an omission was harmless error, since appellant’s participation in the conspiracy was established beyond a reasonable doubt through the conversations with Kratzer. See Commonwealth v. Jones, 540 Pa. 442, 446-447, 658 A.2d 746, 749 (1995) (stating that error is harmless when the evidence of guilt is overwhelming and the error insignificant so that it is clear beyond a reasonable doubt that the error did not contribute to the verdict); see also Evans at 92-94, 413 A.2d at 1029 (<HOLDING>). In sum, it was not an abuse of discretion for 
 Holding statements: (A) holding criminal conspiracy is sustained where the commonwealth establishes the defendant entered into an agreement to commit or aid in an unlawful act with another person with a shared criminal intent and an overt act was done in furtherance of the conspiracy a coconspirator may commit the overt act and conspirators are liable for acts of the coconspirators committed in furtherance of the conspiracy (B) holding that the conspiracy theory of personal jurisdiction requires that the outofstate coconspirator was or should have been aware of the acts performed in the forum state in furtherance of the conspiracy (C) holding that admission of evidence of activity not done in furtherance of the conspiracy was harmless error where defendants participation was fully established by the testimony of another coconspirator (D) holding that proof of overt act is not required to support admission of evidence of statement of coconspirator during course of conspiracy (E) holding that error from the erroneous admission of evidence was harmless in light of the overwhelming evidence of the defendants guilt
[EX A]:
holding criminal conspiracy is sustained where the commonwealth establishes the defendant entered into an agreement to commit or aid in an unlawful act with another person with a shared criminal intent and an overt act was done in furtherance of the conspiracy a coconspirator may commit the overt act and conspirators are liable for acts of the coconspirators committed in furtherance of the conspiracy