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]: reasonably necessary. We affirm. Jurisdiction in the district court was proper based upon 18 U.S.C. § 3231. Jurisdiction in this court is proper based upon 28 U.S.C. § 1291. The notice of appeal was timely filed pursuant to Fed. ít.App. P. 4(b). Background In the underlying criminal matter, defendant was indicted on August 22, 1995, on one count of possession of materials involving the sexual exploitation of a minor, in violation of 18 U.S.C. § 2252(a)(4)(B). The indictment was based on three sexually explicit photographs, found in defendant’s home, which he had taken of his twelve-year-old stepdaughter. Defendant was tried before a jury and found guilty. On appeal, this court vacated the conviction based upon an evidentiary issue. United States v. Heidebur, 122 F.3d 577 (8th Cir.1997) (<HOLDING>). On remand, defendant pled guilty. On January 
 Holding statements: (A) holding that district courts admission of evidence that defendant had sexually molested his stepdaughter was improper because it showed propensity and was not probative of his knowing possession of the photographs (B) holding improper admission of hearsay evidence is reversible error only when the admission causes prejudice (C) recognizing trial courts discretion in weighing the allegedlyimproper prejudicial aspects of photographs of victims against the photographs probative value (D) holding that evidence of violent crimes and other illegal activities of defendants gang was not unduly prejudicial because defendant was not directly implicated and the evidence was probative of elements of the crimes that the defendant was charged with (E) holding that district courts findings were not clearly erroneous where there was  sufficient evidence  that the defendants waiver of his rights was knowing and intelligent
[EX A]: holding improper admission of hearsay evidence is reversible error only when the admission causes prejudice

[EX Q]: century context. We hold, therefore, that a plaintiff may not recover for mental anguish for a potential injury to her unborn child that is wholly unsupported by any physical suffering during and after the incident in question and that explicitly has been ruled out by routine medical diagnostics. We are mindful of the fact, however, that pregnancy and childbirth continue to pose great mysteries that escape complete comprehension and control, and that carry risks with them, which, despite the latest advancements in medical research and technology, cannot be fully assessed. This has led some of our sister states to sustain their holdings in cases involving mental anguish suffered by pregnant women in recent decisions. See, e.g., Simons v. Beard, 188 Or.App. 370, 72 P.3d 96 (2003) (<HOLDING>). We emphasize that in an appropriate case this 
 Holding statements: (A) holding that a woman who was six months pregnant at the time of the accident was permitted to recover damages for her apprehension that her child may be born dead or deformed as a result of striking her abdomen against the steering wheel in the accident (B) holding that a pregnant woman whose baby died just before being born as a direct result of defendantdoctors negligence was permitted to recover damages for her apprehension about the childs wellbeing before death after she learned that the baby was in a transverse position across the upper part of the birth canal and defendant did not undertake any steps to correct the position until after the baby had died (C) holding female supervisors alleged comments that she did not want to add stress to the baby were sufficient direct evidence in a pregnancy discrimination mixed motives case (D) holding woman who claimed she was terminated after giving birth because she became pregnant was part of the protected class (E) holding that there was sufficient evidence to show that the victim suffered before she died based on numerous bruises on her forearms that appeared to be defensive wounds and the large amount of blood found at the scene of the crime indicating that many of the wounds were inflicted before the victim died
[EX A]: holding that a woman who was six months pregnant at the time of the accident was permitted to recover damages for her apprehension that her child may be born dead or deformed as a result of striking her abdomen against the steering wheel in the accident

[EX Q]: service on an individual’s lawyer will not suffice. See Khachikian v. BASF Corp., No. 91-CV-573, 1994 WL 86702, at **1-2 (N.D.N.Y. Mar. 4,1994) (quashing subpoena that plaintiff mailed to the defendant corporation’s attorney rather than to the corporation itself, which was the party named in the subpoena); In re Deposition Subpoena Directed to Smith, 126 F.R.D. 461, 462 (E.D.N.Y.1989) (McLaughlin, J.) (denying plaintiffs motion to serve a deposition subpoena and a subpoena duces tecum on a non-party witness by delivering the subpoenas to the witness’s attorney where Rule 45 required service on the person named in the subpoena; noting that Rule 45 should be reevaluated to permit service of subpoenas other than by personal delivery); Harrison v. Prather, 404 F.2d 267, 273 (5th Cir.1968) (<HOLDING>); see also 9A Wright & Miller, Federal Practice 
 Holding statements: (A) holding that delivery of subpoena via federal express was sufficient because effective service under rule 45 is not limited to personal service (B) holding that service is not avoided by service on a partys attorney as service on an attorney is ineffective unless he has been authorized to accept such service (C) holding that service of subpoena on plaintiffs counsel as opposed to the plaintiff himself renders such service a nullity (D) holding that an attempted service on the partys counsel was insufficient without proof of the counsels actual authority to receive service (E) holding that if service is inadequate defendant never submitted to courts jurisdiction and underlying judgment is therefore a nullity
[EX A]:
holding that delivery of subpoena via federal express was sufficient because effective service under rule 45 is not limited to personal service