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.

motion at which Pritchett would be represented by counsel or at which the court would determine that Pritchett knowingly, intelligently, and voluntarily waived his right to counsel. Ex parte Pritchett, 117 So.3d at 362. In the instant case, the circuit court immediately appointed new counsel to represent Trimble after Trimble gave his oral notice of appeal. Despite having newly appointed counsel who could file a motion for a new trial attacking his trial counsel's alleged deficiencies, Trimble elected to file a pro se motion for a new trial. Therefore, unlike the defendant in Pritchett, Trimble had the benefit of newly appointed appellate counsel who represented him and who could file a motion for a new trial on his behalf. See King v. State, 613 So.2d 888 (Ala.Crim.App.1993)
Holding statements: (A) holding that a valid waiver of counsel at an early stage of the proceeding does not continue in effect through a subsequent stage (B) holding that posttrial motion for new trial is critical stage requiring counsel or valid waiver (C) holding postindictment lineup is critical stage of trial at which defendant is entitled to presence of counsel (D) holding that the filing of a motion for a new trial is a critical stage of the prosecution and that an indigent defendant is constitutionally entitled to the assistance of counsel at that stage (E) holding that sentencing is a critical stage of criminal proceedings and the offer of counsel must be renewed at each critical stage where the defendant appears without counsel
holding that a valid waiver of counsel at an early stage of the proceeding does not continue in effect through a subsequent stage

conclude that the Civil Rights Act of 1991 did not render Title VII and 1981 the exclusive remedies for employment discrimination by a municipality and its employees, thereby preempting a constitutional cause of action under 1983. Accordingly, we affirm the district court's order denying the defendants' motion to dismiss Johnson's 1983 claims. AFFIRMED. 1 . Count Eight asserts a 42 U.S.C. 1985 claim against the individual defendants for alleged conspiracy to violate Johnson's 1981 and Thirteenth Amendment rights. This count is not at issue on this appeal. 2 . The defendants also moved to dismiss the 1981 claim. The district court granted dismissal against the City only, citing Jett v. Dallas Indep. Sch. Dist., 491 U.S. 701, 733, 109 S.Ct. 2702, 2722, 105 L.Ed.2d 598 (1989) (<HOLDING>). 3 .We review de novo a question of law
Holding statements: (A) holding that 1983 is the exclusive federal remedy for violation of the rights guaranteed in 1981 by state governmental units (B) holding that title vii provides the exclusive judicial remedy for claims of discrimination in federal employment (C) holding that title vii of the civil rights act of 1964 provides the exclusive remedy for claims of employment discrimination by federal agencies (D) holding that where it is alleged that state has violated rights conferred by constitution governmental immunity is not available in state court action but declining to infer a right to sue the state for damages on the basis of a violation of the michigan constitution (E) holding that 1983 does not provide a remedy if there is no violation of federal law
holding that title vii provides the exclusive judicial remedy for claims of discrimination in federal employment

12-4) ("Cantor Aff."); (9) Samsung's Reply Brief (Docket No. 16) ("Def. Reply"); (10) Byung Jik Cha's second affidavit (Docket No. 16) ("Cha II Aff.") and (11) the letter from Dr. Edward Michna (Docket No. 18) ("Michna Letter"). 2 . This information comes from Samsung's website and refers to Samsung's business in 2008. (Cantor Aff. at Ex. A). 3 . The First Circuit has clarified that "the term 'oppressiveness and vexation' neither created an independent standard nor raised the bar for dismissal in forum non conveniens cases." Iragorri v. Int'l Elevator, Inc., 203 F.3d 8, 15 (1st Cir.2000). 4 . This concession may be insufficient as defendant has not proffered any evidence that a defendant has the ability to waive a statute of limitations defense in Korea. See Mercier I, 935 F.2d at 426 (<HOLDING>). However, even assuming that the statute of
Holding statements: (A) recognizing that the statute of limitations provision of the aedpa is an affirmative defenses rather than jurisdictional (B) holding that generally the question of waiver and estoppel is a question of fact (C) holding that the courts statute of limitations is jurisdictional in nature and is thus not subject to waiver or estoppel (D) holding that a foreign judgment filed under the montana uefja may not be subjected to the same defenses and proceedings for reopening or vacating as a domestic judgment and remain consistent with full faith and credit the only defenses that may be raised to destroy the full faith and credit obligation owed to a final judgment are those defenses directed at the validity of the foreign judgment (E) holding that despite defendants willingness to abandon statute of limitations defenses the plaintiffs must be given an opportunity to address the question of whether foreign courts would accept such a waiver
recognizing that the statute of limitations provision of the aedpa is an affirmative defenses rather than jurisdictional