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

nonetheless entitled to claim derivative asylum relief based on the possibility that their citizen child would be subjected to FGM. In so assuming, the majority’s remand is illusory. Although the practice of FGM is considered persecution under our law, there is no threat here since a United States citizen child cannot be deported to the country of her parents’ birth, and the parents cannot claim an unrecognized form of derivative relief when they themselves cannot establish entitlement to asylum. By usurping the prerogative of Congress, which alone has the power to create a new basis for cancellation of removal, the majority violates the separation of powers doctrine and creates an unnecessary conflict with the Seventh Circuit. See Oforji v. Ashcroft, 354 F.3d 609, 618 (7th Cir.2003) (<HOLDING>). Like the petitioner in Oforji, Mr. and Mrs. 
 Holding statements: (A) holding that an aliens express waiver of his right to appeal to the bia deprives this court of jurisdiction to consider the aliens subsequent petition for review (B) holding that an alien parent may not establish a derivative claim for asylum by pointing to potential hardship to the aliens united states citizen child in the event of the aliens deportation (C) holding that inconsistencies in the aliens statements must go to the heart of the asylum claim to justify an adverse credibility finding (D) holding that the failure to notify aliens counsel of an order to appear for deportation violated the aliens statutory right to counsel (E) holding that the crime of bringing aliens to the united states is complete when the initial transporter who brings the aliens to the united states ceases to transport them
holding that an aliens express waiver of his right to appeal to the bia deprives this court of jurisdiction to consider the aliens subsequent petition for review

the verification letters clearly stated that Sterling intended to rely upon the verifications in order to provide financing to NSE. In addition, Small's designated affidavit stated that Sterling relies on the verification letters before purchasing invoices to reduce or eliminate its assumed risk of nonpayment by an account debtor. Having found both a promise and detrimental reliance, we find that promissory estoppel applies in this case and that Ham-mert's is estopped to deny payment on Invoice 3 and place payment restrictions on the payment for Invoice 2. Although we have found no similar Indiana cases, our result is consistent with similar case law from other jurisdictions. See Quantum Corporate Funding Ltd. v. L.P.G. Associates, Inc., 246 A.D.2d 320, 323, 667 N.Y.S.2d 702 (1998) (<HOLDING>); Dimmitt & Owens Financial. Inc. v. Realtek 
 Holding statements: (A) holding that account debtors assurance to factor gives rise to an estoppel predicated upon the factors reliance on that assurance in purchasing the assignment from the vendor (B) holding that the existence of a written contract gives rise to the presumption that the parties have reduced their prior agreements to writing (C) holding that the unique nature of psychotherapistpatient relationship gives rise to a duty of care to the patient (D) holding that failure to record an assignment does not give rise to a cause of action (E) recognizing that the nature of the therapistpatient relationship gives rise to a duty  to refrain from  causing emotional or mental harm to the patient

holding that the existence of a written contract gives rise to the presumption that the parties have reduced their prior agreements to writing