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]: re Haddad), 68 B.R. 944, 948 (Bankr.D.Mass.1987); Williams v. Clark (In re Clark), 91 B.R. 324, 332-34 (Bankr.E.D.Pa.1988). And, although § 105 “does not authorize the bankruptcy courts to create substantive rights that are otherwise unavailable under applicable law,” Pertuso, 233 F.3d at 423, n. 1; “[b]ankruptcy courts ... enjoy inherent power to sanction parties for improper conduct.” Mapother & Mapother v. Cooper (In re Downs), 103 F.3d 472, 477 (6th Cir.1996). This inherent power authorizes federal courts “to protect their proceedings and judgments in the course of discharging their traditional responsibilities.” Degen v. United States, 517 U.S. 820, 823, 116 S.Ct. 1777, 135 L.Ed.2d 102 (1996). See also Chambers v. NASCO, Inc., 501 U.S. 32, 50, 111 S.Ct. 2123, 115 L.Ed.2d 27 (1991)(<HOLDING>); Jones v. Bank of Santa Fe (In re Courtesy 
 Holding statements: (A) recognizing that court has inherent power to control the judicial business before it (B) recognizing inherent power of courts of appeals (C) recognizing district courts inherent authority to dismiss with prejudice for abuse of judicial process (D) recognizing inherent power of federal district court to sanction conduct abusive of judicial process (E) recognizing courts inherent power to impose sanctions including attorneys fees for conduct that abuses the judicial process
[EX A]: recognizing that court has inherent power to control the judicial business before it

[EX Q]: as independent entities that solicited and accepted customer orders but used the services of FCMs for clearing, record keeping and retaining customer funds. See id. at 41. To guarantee the accountability of introducing brokers, the Commission was authorized to require them to meet “minimum financial requirements.” See id. First American Discount Corp. v. CFTC, 222 F.3d 1008, 1012 (D.C.Cir.2000). Thus, the legislative history behind the creation of IBs demonstrates Congressional intent not to render IBs agents of FCMs merely because of their status as IBs. Where, as here, the IB is engaged in non-CEA regulated activity, the court concludes that an IB of an FCM is not rendered an agent of the FCM by its mere IB status. See Cunningham v. Waters Tan & Co., 65 F.3d 1351, 1359 (7th Cir.1995) (<HOLDING>); cf. Tatum v. Legg Mason Wood Walker, Inc., 83 
 Holding statements: (A) holding that an alien is entitled to the fifth amendment guarantee of due process which is satisfied by a full and fair hearing (B) holding that the sixth amendments guarantee of the assistance of counsel is made obligatory upon the states by the fourteenth amendment (C) recognizing that a broad definition of stolen is consistent with the guidelines purposes and finding that the enhancement was properly applied where a defendant found a gun that was lost or mislaid by its owner who never authorized anyone to take the gun never sold it and never gave it away as a gift (D) holding that an fcm by entering into a guarantee agreement with ib as an individual never agreed to guarantee ibs other venture as a commodity pool operator  an activity of which fcm was never made aware (E) holding an attorney does not have a duty to insure or guarantee that the most favorable outcome possible and because no amount of work can guarantee a favorable result attorneys would never know when the work they do is sufficiently more than adequate to be enough to protect not only their clients from error but themselves from liability
[EX A]: holding that an alien is entitled to the fifth amendment guarantee of due process which is satisfied by a full and fair hearing

[EX Q]: Inc., 415 U.S. 125, 127, 94 S.Ct. 1002, 39 L.Ed.2d 209 (1974) (internal quotations and citations omitted). Indeed, the federal questions “must be disclosed upon the face of the complaint, unaided by the answer or by the petition for removal.” Gully v. First Nat’l Bank, 299 U.S. 109, 113, 57 S.Ct. 96, 81 L.Ed. 70 (1936). A federal defense cannot serve as the basis for federal jurisdiction. Caterpillar Inc. v. Williams, 482 U.S. 386, 393, 107 S.Ct. 2425, 96 L.Ed.2d 318 (1987) (“Thus, it is now settled law that a case may not be removed to federal court on the basis of a federal defense.”)(emphasis in original). Similarly, federal jurisdiction cannot be predicated on a counterclaim. Holmes Group v. Vornado Air Circulation Sys., Inc., 535 U.S. 826, 831, 122 S.Ct. 1889, 153 L.Ed.2d 13 (2002)(<HOLDING>) Fannie Mae’s Charter The Davises final 
 Holding statements: (A) holding that a defendants counterclaim that is based on the breach of the same maritime insurance contract as the main claim  cannot be granted a jury trial because the resolution of the defendants claim would dispose of all or part of the plaintiffs action the net result would be to resolve the case in a jury trial despite the plaintiffs 9h election (B) holding that district court did not abuse its discretion in considering merits of state law counterclaim that formed part of the same case as federal counterclaim even though court had dismissed federal counterclaim quoting 28 usc  1367a (C) holding that a challenge to part b determinations in an order involving both part a and part b must begin in district court (D) holding that under the law of the district of columbia the filing of a complaint does not toll the statute of limitations on a counterclaim (E) holding that a counterclaim  which appears as part of the defendants answer not as part of the plaintiffs complaint  cannot served as the basis for arising under jurisdiction
[EX A]:
holding that a defendants counterclaim that is based on the breach of the same maritime insurance contract as the main claim  cannot be granted a jury trial because the resolution of the defendants claim would dispose of all or part of the plaintiffs action the net result would be to resolve the case in a jury trial despite the plaintiffs 9h election