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.
--------
Question: the future because she continues to own and operate Helping Hands and intends to remain in the childcare services profession. Docket No. 17 at 112. She posits no other basis for establishing her standing to seek prospective relief against the Secretary. Docket No. 26 at 6-9. Her status as the owner and operator of a child-care facility does not provide her with standing to seek the declaratory and injunctive relief that she seeks. Mosby v. Ligon, 418 F.3d 927, 933-934 (8th Cir.2005) (recognizing that an attorney's status as a member of the bar does not afford him or her standing to prospectively attack the implementation of the professional disciplinary procedures applicable to attorneys practicing in a particular jurisdiction); Brown v. Fauver, 819 F.2d 395, 400, n. 5 (3d Cir.1987) (<HOLDING>). Burns does not allege that she has been
Holding statements: (A) holding that counsel cannot raise his or her own ineffectiveness (B) holding that plaintiff must on his or her own initiative prove that the product reached him or her without substantial change (C) holding that for a legal malpractice claim to accrue a plaintiff need not know the precise extent of his or her damages or even have suffered all of the damages attributable to his or her attorneys negligence (D) holding that a prisoner cannot establish his or her standing to prospectively challenge the validity of a facilitys disciplinary procedures simply by referring to his or her status as an individual incarcerated in that facility (E) holding that an expert can comply with the timing requirement if an experts research even after his or her deposition revealed that the standard of care in his or her community was the same or similar to the standard of care in the community in which he or she is testifying when the injury occurred

Answer: holding that counsel cannot raise his or her own ineffectiveness

Question: 10-987-AC, 2010 WL 5148473, at *3-5 (D.Or. Dec. 13, 2010) (collecting cases); see also Nelson v. Bank of Am., N.A., 446 Fed.Appx. 158, 158 (11th Cir.2011) (similar). 93 . See, e.g., Wright v. Chase Home Finance, LLC, No. CV 11-00095-PHX-FJM, 2011 WL 4101513, at *2 (D.Ariz. Sept. 14, 2011) (citing Fletcher v. OneWest Bank, FSB, 798 F.Supp.2d 925, 930 (N.D.Ill.2011)). 94 . Vida, 2010 WL 5148473, at *5. 95 . Lucia v. Wells Fargo Bank, N.A., 798 F.Supp.2d 1059, 1069 (N.D.Cal.2011) (citations omitted). 96 . Cervantes v. Countrywide Home Loans, Inc., 656 F.3d 1034, 1039 (9th Cir.2011). 97 . Id. at 1040 (citations omitted). 98 . Id. 99 . Id. at 1039. 100 . Id. 101 . Id. (citation omitted). 102 . Dkt. 30 at 5-6; Dkt. 47 at 17-27. 103 . See In re Wilhelm, 407 B.R. 392, 397-405 (D.Idaho 2009) (<HOLDING>); Saxon Mortg. Servs. v. Hillery, No. C-08-4357
Holding statements: (A) holding that creditors could not seek relief from a bankruptcy stay because they were not the real parties in interest and lacked standing as they were not holders of the notes and failed to establish that mers was the holder or had authority to transfer the notes (B) holding that the creditors had standing because the plan eliminated their interests in the borrower notes and deeds of trust and disposed of the assets in the estate from which they seek to be paid (C) holding that plaintiffs lacked standing to seek injunctive relief because they failed to demonstrate any likelihood that they would end up back in jail where alleged constitutional violations occurred (D) holding that despite evidence of voluntary transfer of promissory notes and the plaintiffs possession thereof the plaintiff was not the holder of the note under the ucc as the notes were not drawn issued or indorsed to her to bearer or in blank the plaintiff testified to some of the circumstances under which she obtained possession of the notes but the trial court made no findings of fact with respect thereto (E) holding that mers was not the beneficiary of a deed of trust under the oregon trust deed act absent conveyance to mers of the beneficial right to repayment and that mers could not hold or transfer legal title to the deed as the lenders nominee

Answer: holding that the creditors had standing because the plan eliminated their interests in the borrower notes and deeds of trust and disposed of the assets in the estate from which they seek to be paid

Question: and that he acted alone in pulling the trigger. The affiants also indicated that there were no heated discussions between Mr. Cool and any other persons prior to the firing of the fatal wound by Mr. Cool. The depositions of Ms. Wilkins and Mr. Coffinbarger also assert that Mr. Cool was acting alone as he pulled the trigger. 2 . The Appellant bases this speculation primarily upon evidence of holes in the kitchen wall behind the seat occupied by the decedent immediately prior to his death. The Appellant submits that such holes indicate a possible struggle of some sort. Christopher Coffinbarger testified during his deposition, however, that he struck the wall with his fists in frustration after the decedent lulled himself. 3 . See Lennon v. Pieper, 411 N.W.2d 225, 228 (Minn.Ct.App.1987) (<HOLDING>). 4 . One night prior to his death, the insured
Holding statements: (A) holding that the intervening act breaks the chain of causation set in operation by a defendants negligence thereby insulating his negligence as a direct cause of the injury (B) holding that negligence must be the proximate cause of injury (C) holding that the basis of liability is negligence and not injury (D) holding that in negligence actions florida courts follow the more likely than not standard of causation ie they require proof that the negligence probably caused the plaintiffs injury (E) holding that citys negligence in determining the legal status of plaintiffs property wasnt negligence in the operation of the storm drain that city installed on that property because citys negligence was unrelated to actual operation of storm drain

Answer:
holding that negligence must be the proximate cause of injury