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]: v. Paine, Webber, Jackson & Curtis, Inc., 565 F.Supp. 663, 667 n. 10, 669 (N.D.Ill.1983)). However, in all the cases on this issue, the courts made it clear that the client must have made disclosures to the attorney after manifesting an intent to seek legal advice. Herbes, 180 Ill.App.3d at 698-99, 129 Ill.Dec. 480, 536 N.E.2d 164 (finding that counsel for the plaintiff, who was suing a township over its open-space acquisition program, was ineligible to conduct said representation because he had previously engaged in an attorney-client relationship with the township when it interviewed only him for a possible position representing the township in the same program, evidencing the township’s intent to hire him and therefore speak freely regarding the program), Hughes, 565 F.Supp. at 670 (<HOLDING>), Int’l. Paper Co. v. Lloyd Manufacturing Co., 
 Holding statements: (A) holding that an attorney may only undertake to represent a new client against a former client  where there is no confidential information received from the former client that is in any way relevant to representation of the current client (B) holding that in order to determine whether disqualification of plaintiffs attorney is appropriate because of a previous attorneyclient relationship he had with the defendant the court must determine whether confidential information was passed from client to attorney (C) holding that attorneys should be disqualified where the substantial relationship test is met in order to assure that the confidentiality of the attorneyclient relationship and the loyalty between attorney and client are preserved (D) holding that the district court did not abuse its discretion in drawing an adverse inference where the relief defendant refused to give information necessary to determine whether he still possessed any of the funds or whether he had a legitimate claim to them (E) holding that normal attorneyclient relationship does not bar rule 60b relief when the evidence is clear that the attorney and his client were not acting as one
[A]: holding that an attorney may only undertake to represent a new client against a former client  where there is no confidential information received from the former client that is in any way relevant to representation of the current client


[Q]: Sept. 3, 1998)(variance is not material “where the allegations and proof substantially correspond, the variance is not of a character which could have misled the defendant at trial and is not such as to deprive the accused of his right to be protected against another prosecution for the same offense”). A material variance is sometimes referred to as a “fatal variance.” We have not been consistent in requiring materiality, but have sometimes reversed upon a finding of variance without exploring the further question of materiality. Compare Rowan v. State, 57 Tex.Crim. 625, 124 S.W. 668 (1910)(variance is not material unless it could mislead defense or expose defendant to danger of subsequent prosecution for same offense); Plessinger v. State, 536 S.W.2d 380 (Tex.Crim.App.1976)(<HOLDING>) with Pedrosa v. State, 155 Tex.Crim. 155, 232 
 Holding statements: (A) holding that a defendant must demonstrate that he would not have pled guilty but for the error (B) holding that heightened evidentiary standard of proof is not required where the sentencing enhancement is based entirely on the extent of the conspiracy to which the defendant pled guilty (C) holding that where a defendant is misled and induced to plead by his counsels mistaken advice then he may be allowed to withdraw his plea (D) holding variance between enhancement allegation and proof renders evidence legally insufficient only if variance is material (E) holding variance in style of case pled for enhancement not material where defendant not surprised or misled to his prejudice
[A]: holding that a defendant must demonstrate that he would not have pled guilty but for the error


[Q]: the statutory restrictions were justified. See generally 696 F.3d at 458-⅜7. 209 . Pickering v. Board of Educ., 391 U.S. 563, 88 S.Ct. 1731, 20 L.Ed.2d 811 (1968); 210 . Connick v. Myers, 461 U.S. 138, 103 S.Ct. 1684, 75 L.Ed.2d 708 (1983). 211 . Garcetti, 547 U.S. at 413, 126 S.Ct. 1951 (quoting this statement of the principle — as the first sentence of the opinion — from Connick, 461 U.S. at 142, 103 S.Ct. 1684); see also Connick, 461 U.S. at 143-45, 103 S.Ct. 1684 (explaining that the first case in the line, Pickering, was rooted in same rationale as 1950s-era cases invalidating loyalty oaths and political disclosure requirements made a condition of government employment). 212 . See Connick, 461 U.S. at 144-45, 103 S.Ct. 1684; see also Garcetti, 547 U.S. at 419, 126-S.Ct. 1951 (<HOLDING>). 213 . See .Garcetti, 547 U.S. at 418-19, 126 
 Holding statements: (A) holding that georgias revised death 4356 penalty sentencing scheme differed from that ruled unconstitutional in furman v georgia 408 us 238 92 sct 2726 33 led2d 346 1972 because it focused the jurys attention on the particularized nature of the crime and the particularized characteristics of the individual defendant (B) recognizing that the first amendment limits the ability of a public employer to leverage the employment relationship to restrict incidentally or intentionally the liberties employees enjoy in their capacities as private citizens citing perry v sindermann 408 us 593 597 92 sct 2694 33 led2d 570 1972 (C) holding that when public employees make statements pursuant to their official duties the employees are not speaking as citizens for first amendment purposes and the constitution does not insulate their communications from employer discipline (D) holding that if the harm alleged in fact affects the recreational or even the mere aesthetic interests of the plaintiff that will suffice for standing purposes citing sierra club v morton 405 us 727 73436 92 sct 1361 31 led2d 636 1972 (E) holding that a new york city family court judge had no constitutionally protected property right to reappointment after her tenyear term expired and the mayor decided not to reappoint her and explaining that the fact that many or even most incumbent judges have been reappointed cannot operate to raise appellants subjective expectation to a constitutionally protected right  appellant has failed entirely to demonstrate any mu tually explicit understanding sufficient to establish a property right citing perry 408 us at 601 92 sct 2694 bd of regents of state colls v roth 408 us 564 577 92 sct 2701 33 led2d 548 1972
[A]:
holding that georgias revised death 4356 penalty sentencing scheme differed from that ruled unconstitutional in furman v georgia 408 us 238 92 sct 2726 33 led2d 346 1972 because it focused the jurys attention on the particularized nature of the crime and the particularized characteristics of the individual defendant