Detailed Instructions: 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: an offset against the alimony award by the amount stolen by defendant and now due to plaintiff. We recognize, as did the trial judge, that alimony and equitable distribution are distinct but related types of relief. However, the discretionary application of the equitable maxim of unclean hands applies to matrimonial cases. Heuer v. Heuer, 152 N.J. 226, 238, 704 A.2d 913 (1998). It is well settled that a party " 'in equity must come into court with clean hands and ... must keep them clean ... throughout the proceedings.' " Chrisomalis v. Chrisomalis, 260 N.J.Super. 50, 53-54, 615 A.2d 266 (App.Div.1992) (quoting A. Hollander & Son, Inc. v. Imperial Fur Blending Corp., 2 N.J. 235, 246, 66 A.2d 319 (1949)). See also Thompson v. City of Atlantic City, 190 N.J. 359, 384, 921 A.2d 427 (2007) (<HOLDING>) (quoting Ryan v. Motor Credit Co., 132 N.J.
Holding statements: (A) holding he who seeks equity must do equity (B) holding that the formula in section 522f2a creates equity for purposes of lien avoidance even if debtors otherwise have no equity in the property (C) holding that an insufficient pleading in equity is a nullity (D) holding that an action for specific performance lies in equity (E) holding that when the company seeks cancellation or rescission it must as a condition of obtaining relief do equity by returning or tendering back the premium paid with interest
A:
holding that the formula in section 522f2a creates equity for purposes of lien avoidance even if debtors otherwise have no equity in the property