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.

[EX Q]: n. 7, 713 P.2d at 960 n. 7 (1986) ("Counsel has no right to cast upon the court the burden of searching through a voluminous record to find the ground of an objection. It is counsel's duty to cite accurately the portions of the record supporting counsel's position." (Internal citation omitted.)); Hoang, 93 Hawaii at 336, 3 P.3d at 602 (2000) ("Because the factual basis of [appellant's] alleged point of error is not part of the record on appeal, this court has no basis upon which to rule on the merits of his claim." (Citation omitted.)) Even if Appellants' allegations of fraudulent inducement are taken at face value, they fall short of "clear and convincing" evidence of fraudulent inducement. Honolulu Federal Savings & Loan Ass'n v. Murphy, 7 Haw. App. 196, 202, 753 P.2d 807, 812 (1988) (<HOLDING>). At a more fundamental level, they do not
Holding statements: (A) holding that a finding of fraud may be reversed only for clear error but that the finding must be judged in view of the clear and convincing burden of proof (B) holding that despite the lack of a statutory requirement that severe child abuse be shown by clear and convincing evidence due to the consequences of such a finding the clear and convincing standard must be applied (C) holding that the standard of proving fraudulent inducement with respect to written contracts is extremely high and a written contract will be cancelled only in a clear ease of fraud supported by clear and convincing evidence citations omitted (D) holding that fraud on the court must be supported by clear unequivocal and convincing evidence (E) holding clear and convincing standard to prove fraud or fraudulent intent and preponderance of the evidence to prove other elements under 727
[EX A]: holding that a finding of fraud may be reversed only for clear error but that the finding must be judged in view of the clear and convincing burden of proof

[EX Q]: and seeking to dismiss the four new claims asserted against them in the amended complaint. Also on January 8, 2010, Wells Fargo filed a supplemental motion to dismiss [26], addressing the new claims against it and renewing its request that all counts be dismissed. II. Discussion The Court must determine whether: (1) Giscombe eliminated the deficiencies of his previous shotgun pleading, and (2) if so, whether the complaint should be dismissed for the other reasons asserted by ABN, Citimortgage, and Wells Fargo in their motions to dismiss. A. Legal Standard The sufficiency of Giscombe's amended complaint depends on whether it is a shotgun pleading; if so, it will fall short of the pleading requirements of Fed.R.Civ.P. 8. Magluta v. Samples, 256 F.3d 1282, 1284-85 (11th Cir.2001) (<HOLDING>). The defining characteristic of a shotgun
Holding statements: (A) recognizing the liberal notice and simplified pleading principles underlying the federal rules of civil procedure (B) holding that under leatherman a federal court may not apply a pleading requirement more stringent than that provided for in the federal rules of civil procedure even in 1983 litigation (C) holding that discovery under the federal rules of civil procedure is broad in scope and freely permitted (D) holding that the fact that federal rule of civil procedure 9b requires a heightened pleading standard for some claims but not for a section 1983 claim against a municipality means that the rules do not require a heightened pleading standard for such a claim (E) holding that a shotgun pleading is in no sense the short and plain statement of a claim required by rule 8 of the federal rules of civil procedure
[EX A]: recognizing the liberal notice and simplified pleading principles underlying the federal rules of civil procedure

[EX Q]: ("A tangible employment action in most cases inflicts direct economic harm."); HuntGolliday v. Metro. Water Reclamation Dist. of Greater Chicago, 104 F.3d 1004, 1014-15 (7th Cir.1997) (suspension and suspension pending termination); Hunt v. City of Markham, Illinois, 219 F.3d 649, 654-55 (7th Cir.2000) (denial of a raise); Ribando v. United Airlines, Inc., 200 F.3d 507, 511 (7th Cir.1999) (denial of a promotion). Markel could be considered to have been constructively discharged, though not in the traditional sense, or suspended pending termination. See Tutman v. WBBM-TV, Inc./CBS, Inc., 209 F.3d 1044, 1050 (7th Cir.2000) (a constructive discharge normally occurs where an employer drives the employee to quit by making working conditions miserable); Hunt-Golliday, 104 F.3d 7th Cir.2001) (<HOLDING>); Murray v. Chicago Transit Authority, 252 F.3d
Holding statements: (A) holding that denial of a request for reimbursement for travel expenses did not constitute an adverse employment action (B) holding that termination is an adverse employment action (C) holding that a transfer to a worksite 180 miles away from plaintiffs home did not necessarily constitute an adverse employment action while noting that such a transfer could under some circumstances constitute an adverse employment action (D) holding that a transfer of job duties can constitute an adverse employment action (E) holding that denial of a bonus was not an adverse employment action
[EX A]:
holding that termination is an adverse employment action