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]: ” Boone v. Commonwealth, 14 Va.App. 130, 133, 415 S.E.2d 250, 251 (1992). “A battery is an unlawful touching of another.... Whether a touching is a battery depends on the intent of the actor, not on the force applied.” Adams v. Commonwealth, 33 Va.App. 463, 468-69, 534 S.E.2d 347, 350 (2000) (citation omitted). “ ‘[T]he slightest touching of another ... if done in a rude, insolent, or angry manner, constitutes a battery for which the law affords redress.’ ” Id. at 469, 534 S.E.2d at 350 (citation omitted). Accordingly, where Vaughn claims he only intended to scare Robinson and did not intend to shoot or wound him, Vaughn would not be entitled, in my opinion, to have the jury instructed on assault and battery. See Wynn v. Commonwealth, 5 Va.App. 283, 292, 362 S.E.2d 193, 198 (1987) (<HOLDING>). A second theory supported by the evidence is 
 Holding statements: (A) holding that shooting at a person intending only to scare the person where no touching or wounding occurs supports instructing the jury on simple assault (B) holding that simple assault includes urinating on another (C) holding with no analysis that any person or organization who may be legally liable therefor applies to a person legally liable for injuries caused by an accident   4 when under the facts of the case the only person to whom the clause could have applied was a tortfeasor (D) holding that punching another person is a statutory assault (E) holding simple assault is a lesser included offense of recklessly endangering another person
[EX A]: holding that simple assault includes urinating on another

[EX Q]: 188 (Bkrtcy.S.D.Ohio E.D.1981); In re Davis, 16 B.R. 473 (D.Kan.1981). Or after a judgment has been entered: In re Young, 22 B.R. 620 (Bkrtcy.N.D.Ill.E.D.1982); In re Breuer, 4 B.R. 499, 6 B.C.D. 136 (Bkrtcy.S.D.N.Y.1980). (5)Courts that hold that a debtor may cure a default where a foreclosure sale has been held provided that the debtor’s right of redemption under state law has not expired: In re Johnson, 29 B.R. 104 (Bkrtcy.S.D.Fla.1983); In re Chambers, 27 B.R. 687 (Bkrtcy.S.D.Fla.1983); In re Taylor, 21 B.R. 179 (Bkrtcy.W.D.Mo.1982); In re Thompson, 17 B.R. 748 (Bkrtcy.W.D.Mich.1982). 32 B.R. at 790. To the fourth group we add the following recent opinions by the Fifth and Seventh Circuits: Grubbs v. Houston First American Savings Association, 730 F.2d 236 (5th Cir.1984) (en banc) (<HOLDING>); Matter of Clark, 738 F.2d 869 (7th Cir.1984) 
 Holding statements: (A) holding debtor could cure default partly because the bank held a recourse loan and therefore could recover against the original borrower personally (B) holding that the debtor had the right to cure the default because the foreclosure sale was not complete under state law until it was confirmed by a court (C) holding debtor could cure after the debtor had previously made payments to the bank (D) holding that a debtor may cure a default after acceleration but expressing no limit on the right (E) holding debtor could include property because the bank accepted payments directly from the debtor and had previously allowed the debtor to cure default
[EX A]: holding debtor could cure default partly because the bank held a recourse loan and therefore could recover against the original borrower personally

[EX Q]: for the offenses on different days and under different cause numbers. Kennedy contends that, because the offenses were originally brought in the same indictment, they should have counted as one sentence for criminal-history purposes, but he fails to provide any legal authority either supporting his assertion or even addressing the district court’s implicit determination that the offenses being originally charged in one indictment did not alter the result under the guideline provision governing whether prior sentences are counted separately or as a single sentence. Accordingly, Kennedy cannot demonstrate counsel’s failure to object to the criminal-history calculation on prior felony offenses constituted deficient performance. E.g., McCoy v. Lynaugh, 874 F.2d 954, 968 (5th Cir.1989) (<HOLDING>). As for Kennedy’s claim that counsel was 
 Holding statements: (A) holding that appellate counsel could not be found to have rendered ineffective assistance for failing to raise issues that are without merit (B) holding that counsel was not deficient in failing to present a meritless argument (C) holding that an attorney is not ineffective for failing to make a meritless objection (D) holding counsel was not deficient for declining to make a meritless argument (E) holding that counsel was not deficient for failing to make an objection that lacked merit
[EX A]:
holding that appellate counsel could not be found to have rendered ineffective assistance for failing to raise issues that are without merit