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: 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

A: holding debtor could cure default partly because the bank held a recourse loan and therefore could recover against the original borrower personally
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Q: on the circuit court orders and the statements of defense counsel at the hearing. We hold that neither the doctors nor the trial court could rely on facts and legal conclusions within the circuit court orders. Thus, the doctors’ assertions at the hearing, which were based on facts within the orders, constituted factual statements of counsel. Moreover, the orders were, in effect, memoranda submitted by counsel. In any event, the trial court could not properly consider factual statements from either when deciding the motions, however they are characterized. Cf. Stiles v. Onorato, 318 S.C. 297, 457 S.E.2d 601 (1995) (noting that the ruling on a 12(b)(6) motion to dismiss must be based solely upon the allegations set forth on the face of the complaint); Gilmore, 290 S.C. 53, 348 S.E.2d 180 (<HOLDING>). This is not to say that circuit court orders 
 Holding statements: (A) holding that the judge cannot consider factual statements of counsel in a motion for summary judgment (B) holding that unsworn statements may not be considered on a motion for summary judgment (C) holding that a trial court can only consider admissible evidence in ruling on a motion for summary judgment (D) holding that motion to dismiss cannot be treated as summary judgment (E) holding that conclusory statements without factual support are of no value to the court when deciding a summary judgment motion

A: holding that unsworn statements may not be considered on a motion for summary judgment
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Q: lack of subject-matter jurisdiction. However, none of the parties to the district-court actions filed an appeal of the June 11, 2012, orders to the trial court to challenge the district court’s determination that it lacked jurisdiction to consider the drivers’ appeals. See § 12-12-71, Ala. Code 1975 (“[A]ll appeals from final judgments of the district court shall be to the circuit court for trial de novo.”). Rather, the drivers and the city proceeded in the trial court, apparently under the assumption that the district court could properly transfer the three actions to the trial court. In fact, a district court may transfer an action that it determines is not within its jurisdiction but, rather, is within the jurisdiction of the circuit court: “If a case filed in the circuit p. 2008) (<HOLDING>); cf. Ex parte Smith, 438 So.2d 766, 767-68 
 Holding statements: (A) holding that a transfer order issued by a district court in another circuit is reviewable only in the circuit of the transferor district court (B) holding that when the district court improperly purported to transfer to the circuit court an action over which the circuit court lacked subjectmatter jurisdiction the circuit court was without jurisdiction to enter its judgment which was void and dismissing the appeal from that void judgment (C) holding that because the circuit court did not have subjectmatter jurisdiction over the unlawfuldetainer action the district courts unauthorized transfer of the action could not transfer jurisdiction over that action to the circuit court (D) holding that a subsequent action was not barred because the initial court did not have jurisdiction over the claim (E) holding that when the district court dismissed rather than transferred a case not within its jurisdiction and a party appealed that dismissal the circuit court could consider only the propriety of the dismissal on appeal and determining that the circuit court lacked jurisdiction on appeal to consider the merits of the action

A:
holding that a transfer order issued by a district court in another circuit is reviewable only in the circuit of the transferor district court
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