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]: v. Libbey-Owens-Ford Glass Co., 376 F.2d 711 (7th Cir. 1967), stated that section 2(d) shows that the legislature contemplated multiplicity of actions and provides a court with two options: stay the entire proceeding pending arbitration, or, if the issue is severable, the stay may be granted with respect to that issue only. 710 ILCS 5/2(d) (West 1994). The Galt court explained: “In enacting the Uniform Arbitration Act, the [Illinois] Legislature has not eradicated a chancellor’s inherent powers, but the legislature has determined in Section 2 that it is no longer equitable to enjoin arbitration to prevent multiplicity of actions.” Galt, 376 F.2d at 716. See Moses H. Cone Memorial Hospital v. Mercury Construction Corp., 460 U.S. 1, 20, 74 L. Ed. 2d 765, 782, 103 S. Ct. 927, 939 (1983) (<HOLDING>). Accord Dean Witter Reynolds Inc. v. Byrd, 470 
 Holding statements: (A) holding that where an arbitration agreement between an employer and employee does not specifically provide for the handling of arbitration costs california courts should interpret the arbitration agreement  as providing  that the employer must bear the arbitration forum costs (B) holding that once the party seeking to compel arbitration establishes the existence of an arbitration agreement and that the claims raised fall within the scope of that agreement the trial court must compel arbitration (C) holding that the federal arbitration act requires piecemeal resolution when necessary to give effect to an arbitration agreement and mandates enforcement of an arbitration agreement notwithstanding the presence of other persons who are parties to the underlying dispute but not to the arbitration agreement emphasis added (D) holding that an arbitration agreement is separable from the underlying agreement (E) holding that the faa mandates courts to direct parties to arbitration on issues to which a valid arbitration agreement has been signed
[EX A]: holding that where an arbitration agreement between an employer and employee does not specifically provide for the handling of arbitration costs california courts should interpret the arbitration agreement  as providing  that the employer must bear the arbitration forum costs

[EX Q]: issue in question.” Bradley Ventures, Inc. v. Farm Bureau Mut. Ins. Co. of Ark., 371 Ark. 229, 264 S.W.3d 485, 490 (2007). UAMS maintains that collateral estoppel applies to Dodson I and II, barring both of Dodson’s pending claims, but our discussion is considerably narrower. First, I would set aside Dodson I because I am uncertain that the court’s relevant finding was “essential to the judgment.” Powell, 289 S.W.3d at 444. Second, I would set aside Count II, which is Dodson’s impliedeontract claim. Importantly, Count II is premised on UAMS’s conduct after Dodson II, i.e., sending Dodson bills for the embryo storage fees, and therefore cannot be precluded by the earlier chancery court decision. See Ripplin Shoals Land Co. v. U.S. Army Corps of Eng’rs, 440 F.3d 1038, 1044 (8th Cir.2006) (<HOLDING>); cf. id. at 1042 (“[R]es judicata does not 
 Holding statements: (A) holding that an assignment does not modify the terms of the underlying contract (B) recognizing that a final judgment may provide for a particular standard upon which to modify a final judgment (C) holding that a prior judgment regarding a permit to modify an existing bridge does not preclude a plaintiff from challenging a decision on a new application describing and a different bridge design (D) holding that district court did not abuse its discretion in refusing to permit a design defect products liability expert to submit an untimely addendum stating a new claim of failure to warn after defense expert refuted the basis of original design defect opinion (E) holding untimeliness of motion to modify medical insurance payment did not preclude motion to modify maintenance
[EX A]: holding that an assignment does not modify the terms of the underlying contract

[EX Q]: armed. Those are machinations drawn up by the defense attorney.” At that point, Davis’s attorney objected that such a statement attacked Davis over the shoulders of defense counsel, violated his due process rights, and deprived him of his right to a fair trial. The trial court overruled Davis’s objection, and the prosecutor continued, “There’s no evidence to suggest that.” Viewing the prosecutor’s statement in the context of the entire argument, the comment was made in rebuttal, specifically in response to Davis’s claim that Latarsha was armed and had attacked Davis. See Mosley, 983 S.W.2d at 256; York v. State, No. PD-1753-06, 2008 WL 2677368, at *5 (Tex.Crim.App. July 2, 2008) (not designated for publication). By saying that the idea that Latarsha was armed was a “machinatio pp.1973) (<HOLDING>); Guy, 160 S.W.3d at 616-17 (holding 
 Holding statements: (A) holding that prosecutors remarks that defense counsel was a zealot in the courtroom and thank god hes a defense attorney and not part of the government were improper (B) holding prosecutors argument that defense counsel was manufacturing evidence and thus suborning perjury was improper (C) holding prosecutors argument that defense counsels goal was to keep evidence from the jury was improper (D) holding prosecutors statement that defendant and defense counsel were lying when they pleaded not guilty was improper (E) holding that the prosecutors question to the defendant about a prior unrelated offense was improper
[EX A]:
holding that prosecutors remarks that defense counsel was a zealot in the courtroom and thank god hes a defense attorney and not part of the government were improper