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]: by the parties. These considerations are consistent with the principle [sic] legislative purpose behind enactment of the Uniform Arbitration Act: to provide and encourage an expedited, efficient, relatively uncomplicated, alternative means of dispute resolution, with limited judicial intervention or participation, and without the primary expense of litigation— attorneys’ fees. Id. at 153-54, 423 S.E.2d at 750. The court concluded that “in arbitration proceedings, both the arbitrator or arbitration panel and the superior courts upon confirmation are limited to applying only [our AR.S. § 12-1510] in determining whether attorneys’ fees should be or were properly awarded.” Id. at 155, 423 S.E. at 751; see also Floors, Inc. v. B.G. Danis, Inc., 380 Mass. 91, 97, 401 N.E.2d 839, 843 (1980) (<HOLDING>). In our view, to permit a trial court to award 
 Holding statements: (A) holding merely that the evidence was sufficient to support the award of attorneys fees (B) holding that attorneys fee statute does not overpower the policy expressed in our ars  121510 against the award of attorneys fees in arbitration proceedings (C) holding that an award of attorneys fees under supreme court rule 38 precursor to rule 222 did not preempt an award of attorneys fees to which one is otherwise entitled and thus appellant could seek an award of attorneys fees pursuant to section 1577300 which permits an award of fees for a party prevailing in an action against a state agency (D) holding trial court erred in awarding attorneys fees to physicians in absence of any evidence of attorneys fees (E) holding trial court had no authority to award attorneys fees when arbitrator had stated he would not award attorneys fees
[EX A]: holding merely that the evidence was sufficient to support the award of attorneys fees

[EX Q]: the report and recommendation did not notify the parties that they must file timely objections to preserve their right to appellate review. He argues that the firm waiver rule should not be enforced in the absence of such an explicit notification. While we have held that the firm waiver rule is inapplicable when pro se litigants are not given explicit notice of the rule, see id. at 659, we have never extended that practice to counseled cases. We decline to do so today, because we expect counsel to know the rules. See Nasious v. Two Unknown B.I.C.E. Agents, 492 F.3d 1158, 1163 n. 5 (10th Cir.2007) (“[W]e expect counsel to know the pleading rules of the road without being given personal notice of them by the district court.”); United States v. Windrix, 405 F.3d 1146, 1157 (10th Cir.2005) (<HOLDING>). While 28 U.S.C. § 636(b)(1) provides that a 
 Holding statements: (A) holding that district court did not abuse its discretion in striking fact statements that did not comply with the local rules (B) holding that a criminal defendants counsel is charged with knowledge of the local criminal rules in their entirety including those parts of the local civil rules incorporated by reference (C) holding the district court did not abuse its discretion in applying its own local rules even though those rules prevented it from considering some facts improperly alleged by plaintiffs that might have been relevant to the summary judgment motion (D) holding that the federal expert witness compensation rules are in direct conflict with the state rules even when the state rules allow for a greater recovery (E) holding that defendants have a right to counsel in criminal proceedings
[EX A]: holding that district court did not abuse its discretion in striking fact statements that did not comply with the local rules

[EX Q]: for the jury was whether Dr. Cooper consented, and not whether a battery had been committed. Id. at 4-6. The trial court again overruled Appellants’ objection. Following deliberations, the jury answered the aforementioned inquiry in the negative, finding that no battery had been committed. The jury further found in favor of Appellees on all remaining claims. On appeal, Appellants raised various issues. Relevant here is their challenge to the jury instruction on lack of consent. The trial court explained in its Pa.R.A.P. 1925(a) opinion that there is no separate tort of lack of consent, and that an action based on the absence of a patient’s consent constitutes a battery. Trial Court Opinion, dated 10/15/09, at 8-9 (citing Montgomery v. Bazaz-Sehgal, 568 Pa. 574, 798 A.2d 742 (2002) (<HOLDING>)). Thus, the trial court found that its 
 Holding statements: (A) holding that battery is an inherently included offense of aggravated battery (B) holding that under maryland common law an assault is an attempted battery an actual battery or a combination of the two (C) holding that an operation without the patients consent sounds in battery (D) holding that in pennsylvania lack of informed consent claims utilize a battery standard that is a physician commits battery where the patient does not consent to the procedure on his person thus constituting a harmful or offensive contact (E) holding that a patient who endures an operation without his consent may base his action on a tortious battery
[EX A]:
holding that battery is an inherently included offense of aggravated battery