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. The four incorrect answers are other holding statements. You should find the correct option. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

Q: diligent effort' requires such pointed measures as an examination of telephone company records, utility company records, and records maintained by the county treasurer, county recorder, or similar ree-ord keepers."). {47 Here, the motion for publication Brown filed in 1978 states that "search has been made of the public records of the County of Weld and County of Morgan, State of Colorado." Such a search, if undertaken with reasonable diligence, should have resulted in the discovery of the 1950 Deeds, as they were readily available matters of public record and part of the relevant chain of title. Each document identified Tulsa, Oklahoma, as the city of the Gadbois' residence. Brown could-and should-have discovered this information. See In re Colon, 563 F.3d 1171, 1178 (10th Cir.2009) (<HOLDING>) 4 48 Sunﬂarly, Brown could-and should-have 
 Holding statements: (A) holding that implied easement arose because each deed in chain of title referenced community plan (B) holding that a typographical error in a security deed does not necessarily invalidate the legal description when the deed also referred to the propertys physical address (C) holding that trustees have a duty to exercise the same judgment and prudence that a careful owner would exercise in the sale of his own property (D) recognizing that a per son exercising reasonable prudence and diligence in examining propertys chain of title would have located a deed containing a misstatement in its descmptlon of the property (E) recognizing that the right to seek reformation of a deed is limited to the original parties to the deed and their successors in title

A: (D)
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Q: v. Jones, 993 P.2d 424, 427-28 (Alaska 1999) (construing a statute to give rise to an equitable lien because it established "an interest in and a right to seek reimbursement from" a particular source). 13 . Cf. AS 09.35.160 (giving a judgment creditor and the process server who levies on property under a writ of execution full control over the timing of a sale in satisfaction of the judgment). 14 . See Alaska R. Civ. P. 89(a). 15 . AS 13.16.505. 16 . AS 13.06.050(39). This definition comports with the definition set out in Uniform Probate Code section 1-201(33), which states: " 'Property' includes both real and personal property or any interest therein and means anything that 'may be the subject of ownership." 17 . Cf. Goldstein v. Prien, 143 Cal.App.2d 123, 299 P.2d 344, 346 (1956) (<HOLDING>). 18 . Since AS 13.16.505 prohibits liens from 
 Holding statements: (A) holding that it is improper for a trustee to liquidate claims that benefit only select creditors with the only benefit to the estate being the recoupment of administrative costs (B) holding that there is a difference between a debtor attempting to pursue an action for his own benefit and a trustee pursuing an action for the benefit of the creditors (C) recognizing under analogous section of california code that the right to recover property conveyed by a decedent in fraud of creditors is an asset of his insolvent estate and that the executor or administrator is a trustee thereof for the benefit of creditors (D) holding that directors of an insolvent corporation are trustees for the creditors (E) recognizing that the bangor punta doctrine was not applicable to suit brought by receiver of insolvent insurance company for the benefit of creditors

A: (C)
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Q: "fraud” to mean actual or positive fraud rather than fraud implied by law. 3 Collier on Bankruptcy ¶ 523.08[5], at 523-58 (footnotes omitted). [17] 17. Some courts require the creditor to have reasonably relied on the representations, but the Fifth Circuit does not. See In re Allison, 960 F.2d at 484-85 & n. 3 (citing cases). 18 . Other circuits have applied a uniform standard resembling our "actual fraud” standard to all debts falling under § 523(a)(2)(A). See, e.g., Britton v. Price (In re Britton), 950 F.2d 602, 604 (9th Cir.1991) ("The Ninth Circuit has employed a five-part test for determining when a debt in nondischargeable under section 523(a)(2)(A).”); Caspers v. Van Home (In re Van Home), 823 F.2d 1285, 1287 (8th Cir.1987) ("To succeed in a F.2d 1061, 1064 (11th Cir.1987) (<HOLDING>); see also In re Lacy, 947 F.2d at 1277 
 Holding statements: (A) holding that statecourt breach of fiduciary duty judgment precluded relitigation of same issue in dischargeability proceeding (B) recognizing that even though standards of proof and findings in care and protection proceeding are identical to those in subsequent consent to adoption proceeding collateral estoppel inapplicable because incentive to litigate custody or appeal findings from earlier proceeding which are limited and do not carry same degree of finality may be substantially less than incentive to litigate or appeal findings in adoption proceeding which permanently terminates legal parentchild relationship (C) holding that resolution of issue underlying statecourt fraud judgment precluded relitigation of same issue in nondischargeability proceeding (D) holding that statecourt consent judgment containing findings of fraud precluded relitigation of same issue in dischargeability proceeding (E) holding that because relitigation of issue was barred by collateral estoppel res judicata determination of finality of judgment dismissed for lack of standing was not relevant

A:
(D)
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