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.

Example Input: in Bowman were appointed by the court to make educational decisions for children who were wards of the district, so that the advocates effectively acted as “parents” under the IDEA. See id. Accordingly, even though they were licensed attorneys, they could not recover fees as educational advocates because they were not acting in an attorney-client capacity. See id. Pressley distinguishes from this scenario because she was employed by the Chris Anwah Law Firm, instead of being appointed by the court as an advocate. See Adewusi Deck ¶ 1. Furthermore, Pressley’s work on this matter was similar to that performed by the billing attorneys. See PL’s Mot., Ex. B. Yet because she is not a member of the D.C. Bar, Pressley is not entitled to attorney rates. See Dickens, 724 F.Supp.2d at 120 (<HOLDING>); Agapito v. District of Columbia, 477 
 Holding statements: (A) holding trial court erred in awarding attorneys fees to physicians in absence of any evidence of attorneys fees (B) holding that the magistrate judge did not abuse her discretion in considering the prevailing hourly rates in the southern district of new york when awarding attorneys fees (C) holding that lexis fees are not taxable as costs but reserving ruling on whether such fees are recoverable as attorneys fees (D) holding that attorneys not admitted to the dc bar are not entitled to reimbursement but awarding fees at paralegal rates as equitable relief (E) holding that the court lacked jurisdiction to consider the appeal because it was filed before the final order awarding attorneys fees
Example Output: holding trial court erred in awarding attorneys fees to physicians in absence of any evidence of attorneys fees

Example Input: were convicted of conspiring to use, carry, or possess a firearm in furtherance of, inter alia, a conspiracy to violate the Neutrality Act and a conspiracy to provide services to the Taliban. 18 U.S.C. §§ 924(c),(o); J.A. 3223. Both Count Five and Count Eleven, in other words, ■ expressly allow one conspiracy to serve as the predicate for another conspiracy. Nothing about this statutory framework is unconstitutional, improper, or even unusual. Courts have recognized that one conspiracy can serve as the predicate for another conspiracy when the “[overarching] conspiracy and the predicate conspiracy are distinct offenses with entirely different objectives.” United States v. Pungitore, 910 F.2d 1084, 1135 (3rd Cir.1990); see also United States v. Ruggiero, 726 F.2d 913, 918 (2nd Cir.1984) (<HOLDING>); United States v. Brooklier, 685 F.2d 1208, 
 Holding statements: (A) holding that two conspiracies existed where the members of the second conspiracy did not know about the first conspiracy did not benefit from the first conspiracy and were connected with the first conspiracy only through a middleman (B) holding that congress intended to allow multiple punishments for rico conspiracies and conspiracies to commit the underlying predicate offense even though the offenses were the same under the blockburger test (C) holding that conspiracies can serve as predicate acts for a rico conspiracy (D) holding that judge erred in not explaining to jury that it could consider predicate acts listed in relation to substantive rico count when deciding whether defendants had also conspired to violate rico (E) recognizing money laundering as a predicate act under rico
Example Output: holding that two conspiracies existed where the members of the second conspiracy did not know about the first conspiracy did not benefit from the first conspiracy and were connected with the first conspiracy only through a middleman

Example Input: with "the public policy of the forum,” and allowed the maintenance of the causes of action only after finding that Oregon statutes were "virtually identical” to Idaho’s. Id. at 1279-80. Thus, plaintiffs are mistaken in suggesting that Houston presents an instance in which the existence of a statutory cause of action precluded a court from conducting a choice-of-law analysis. 30 To be clear, plaintiffs did not assert a defamation claim nor complained in this appeal that their allegations should have been interpreted as if they had sought damages based on a claim of defamation. Nevertheless, their disparagement claims may — for these purposes — be viewed similarly due to their theoretical kinship. Cf. Dairy Stores, Inc. v. Sentinel Pub. Co., 104 N.J. 125, 133, 516 A.2d 220 (1986) (<HOLDING>). 31 We have appended to this opinion a graph 
 Holding statements: (A) recognizing that the torts of product disparagement and defamation sometimes overlap (B) recognizing torts of intentional and negligent infliction of emotional distress (C) recognizing tentative draft of restatement second of torts  652e (D) recognizing torts of negligent hiring supervision and retention (E) recognizing that restatement second of torts  323 and 324a correctly state pennsylvania law
Example Output:
recognizing torts of intentional and negligent infliction of emotional distress