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.

opposing party’s motion. We have held that there is an “overarching liberal policy of allowing amendments under Rule 15.” Ex parte Liberty Nat’l Life Ins. Co., 858 So.2d 950, 954 (Ala.2003). However, Rule 15 “‘is not carte blanche authority to amend ... at any time.’ ” Burkett v. American Gen. Fin., Inc., 607 So.2d 138, 141 (Ala.1992)(quoting Stallings v. Angelica Uniform Co., 388 So.2d 942, 947 (Ala.1980)). The trial court has discretion to deny an amendment for good cause. Ex parte GRE Ins. Group, 822 So.2d 388, 390 (Ala.2001); Stallings, 388 So.2d at 947. The deadline in the scheduling order does not curtail the trial court’s discretion in considering the merits of the offered amendment. See Moses.com Sec., Inc. v. Comprehensive Software Sys., Inc., 406 F.3d 1052, 1066 (8th Cir.2005)(<HOLDING>). The trial court can refuse to allow an 
 Holding statements: (A) holding that the date of the federal indictment not the date of the state arrest was the triggering date for the speedytrial act (B) holding that interest does not begin to accrue until the date of judgment not the date of verdict (C) holding that although the defendant filed a number of motions because the original trial date never changed as a result of those motions no delay could be attributed to the motions (D) holding in part that the presumption of public access attaches to pretrialnondiscovery motions whether preliminary or dispositive and the materials briefs and documents filed with the court in support of or in opposition to such motions but not to pretrial discovery motions (E) holding that the scheduling order merely prescribes the date by which all motions to amend shall be filed the date on the scheduling order does not confine the district courts consideration of the merits of such motions and does not preclude it from finding that an amendment would result in prejudice
holding that the date of the federal indictment not the date of the state arrest was the triggering date for the speedytrial act

cap in determining the amount of benefits another person was able to receive. Id. at 615. Although in Parisi, the child was suffering from the technical entitlement, the case stands for the proposition that a technical entitlement of zero should be counted as zero when computing family máximums. Considering that the purpose of the family maximum is to set a maximum that can be given from one wage earner’s account, Parisi complies with this purpose. IV. BY CITING PARISI, HAS PLAINTIFF RAISED A NEW ISSUE THAT IS NOT PROPERLY INCLUDED IN THIS JUDICIAL REVIEW? “[I]f petitioner wishes to preserve an issue for appeal, he must first raise it in the proper administrative forum_” Tejeda-Mata v. INS, 626 F.2d 721, 726 (9th Cir.1980); See Chung Young Chew v. Boyd, 309 F.2d 857, 861 (9th Cir.1962) (<HOLDING>). Yet, in Tejeda-Mata the court held this “in 
 Holding statements: (A) recognizing that failure to observe the required process deprives the court of jurisdiction (B) holding that the court lacked jurisdiction over the petition for review because the aliens did not appeal the ijs denial of their motion to reopen to the board resulting in failure to exhaust their administrative remedies (C) holding that partys failure to file a timely internal administrative appeal as required by regulations of the department of agriculture constituted failure to exhaust administrative remedies and precluded judicial action (D) recognizing that failure by state to provide the required certification deprives appeals court of jurisdiction over appeal (E) holding that failure to take available appeal to board of immigration appeals constitutes failure to exhaust administrative remedies and deprives the court of appeals of jurisdiction to review
recognizing that failure to observe the required process deprives the court of jurisdiction

the Second, Fourth and Seventh Circuits that actual innocence applies to a sentencing enhancement. Even assuming it does, courts applying actual innocence for non-capital sentencing have noted that for purposes of the actual innocence exception, “ ‘actual innocence’ means factual innocence, not mere legal insufficiency.” Bousley, 523 U.S. at 623, 118 S.Ct. 1604. Thus, some circuits have held that “for the actual innocence exception to apply in the noncapital sentencing context, a movant must show that he is factually innocent of the conduct or underlying crime that serves as the predicate for the enhanced sentence.” McKay v. United States, 657 F.3d 1190, 1198-99 (11th Cir.2011) (involving career offender guidelines). See also United States v. Pettiford, 612 F.3d 270, 284 (4th Cir.2010) (<HOLDING>); cf. Poindexter v. Nash, 333 F.3d 372, 381-82 
 Holding statements: (A) holding that the actual innocence exception applies to a sentencing enhancement in a noncapital sentence (B) holding that no complete innocence exception to the doench doctrine exists (C) holding under acca that the actual innocence of sentence exception applies in the context of habitual offender provisions only where the challenge to eligibility stems from factual innocence of the predicate crimes and not from the legal classification of the predicate crimes (D) holding that as to each predicate act the plaintiff must allege the time place and contents of the misrepresentations (E) holding that presumption of innocence and reasonable doubt standard are constitutionally required in criminal cases

holding that the actual innocence exception applies to a sentencing enhancement in a noncapital sentence