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.

[Q]: pain and suffering, demonstrated his reliance on a prohibited tort theory); Strock v. Pressnell, 38 Ohio St.3d 207, 527 N.E.2d 1235, 1242-43 (1988) (declining to consider an intentional infliction of emotional distress action, in which the plaintiff sought damages for “anguish, shock, nervousness, and depression,” because the abolition of claims for alienation of affections was intended to preclude these allegations); see also Wilson v. Still, 819 P.2d 714, 716 (Okla.1991) (finding a suit for intentional infliction of emotional distress was barred because the plaintiff basically sued the defendant for “wil-fully taking away her husband” and stating the legislature immunized that conduct from tort liability). But see Erickson v. Christenson, 99 Or.App. 104, 781 P.2d 383, 385-86 (1989) (<HOLDING>), appeal dismissed, 311 Or. 266, 817 P.2d 758 
 Holding statements: (A) holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute (B) holding a plaintiff could proceed on a claim alleging intentional infliction of emotional distress because the alleged losses were different from those for seduction but also stating plaintiffs previously suing for seduction could recover for damage to character and reputation as well as for mental anguish and pecuniary losses (C) recognizing validity of cause of action for intentional infliction of emotional distress (D) holding that police officers were immune from liability for damages resulting from alleged intentional infliction of emotional distress (E) recognizing the tort of intentional infliction of emotional distress
[A]: holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute


[Q]: it was minor and that Zhang only had five years of education. The IJ reasonably found these explanations insufficient. Zhang also testified inconsistently regarding whether he was fired from his job after authorities arrested him in 2010, or simply did not return to work. Zhang argues that this inconsistency was “nonexistent” because there was more than one reason why he did not return to work. Zhang does not explain, however, why he did not state that he was terminated when he was first asked why he did not- return to work. The agency reasonably found that Zhang’s failure to mention his termination until prompted by the IJ undermined his credibility, and that his explanation that he “did not listen clearly” was unpersuasive. See Majidi v. Gonzales, 430 F.3d 77, 80-81 (2d Cir.2005) (<HOLDING>). Finally, the agency reasonably found that 
 Holding statements: (A) holding that the court need not accept as true  unwarranted factual inferences (B) holding that district court need not accept the governments recommendation of a minor role reduction (C) holding that a plaintiffs complaint need only establish a plausible entitlement to relief (D) holding that a reasonable factfinder would not be compelled to conclude that the petitioner would more likely than not be subjected to torture if removed to china based solely on the fact that she had illegally departed china without more particularized evidence (E) holding that ij need not accept plausible explanation for inconsistency unless reasonable factfinder would be compelled to do so
[A]: holding that the court need not accept as true  unwarranted factual inferences


[Q]: proceeding arid concerns of undue burden or intrusiveness ... in determining whether to grant a section 1782 application.” In re Consorcio Ecuatoriano, 685 F.3d at 998 n. 7. Any requests that are “unduly intrusive or burdensome ... may be rejected or trimmed.” 542 U.S. at 265, 124 S.Ct. 2466. For instance, “[a] person may not be compelled to give his testimony or statement or to produce a document or other thing in violation of any legally applicable privilege.” 28 U.S.C. § 1782(a). The Court finds, contrary to NextEra’s assertions, that most of Mesa Power’s discovery requests materially comply with the requirement that the discovery be “relevant to the foreign proceeding.” In re Dr. Braga, 789 F.Supp.2d 1294, 1304 (S.D.Fla.2011); compare In re Consorcio Ecuatoriano, 685 F.3d at 999 (<HOLDING>), with Kang v. Noro-Moseley Partners, 246 
 Holding statements: (A) holding that the discovery relating to  the rates charged  to conocel or the procedure or methodology for applying the rates to be charged  are plainly relevant to the foreign proceedings as they formed the basis of conocels defense (B) holding extraneous acts relevant to show intent in charged offense (C) holding that fedrevid 404b does not restrict evidence of crimes that arose out of the same series of transactions as the charged offense or that are necessary to complete the story of the charged crime (D) holding but offering no authority for the position that the defense counsel could neither argue nor receive an instruction distinguishing the crime charged from a lesserunincluded offense not charged (E) holding that prior convictions relevant only to the sentencing of an offender found guilty of the charged crime do not need to be charged in an indictment or proven to a jury beyond a reasonable doubt
[A]:
holding extraneous acts relevant to show intent in charged offense