Given the task definition and input, reply with output. 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.

Mac Pherson expressly argued to the state trial court, and subsequently to the Appellate Division, that the Order for Service by Publication was predicated on a misrepresentation of material fact, that sustaining jurisdiction over him based on publication would be a denial of his constitutional right to due process, that procedural due process requires notice reasonably calculated to apprise interested parties of the pendency of an action affecting a person's property interest, and that the state court should have ordered a hearing to determine whether service by other means was available before ordering service by publication. Accordingly, res judicata applies to preclude Mac Pherson from asserting in federal court the claims he has raised in this action. See Brooks, 84 F.3d at 1463 (<HOLDING>). We have considered all of Mac Pherson's
Holding statements: (A) holding that claims to the vsf benefits under various theories were barred by the res judicata effect of the state court judgment in castellano iii (B) holding that the plaintiffs due process claims were completely barred by res judicata because the underlying factual predicate for each of these claims is substantially identical to the allegations presented in state court (C) holding that when claims regarding the employment relationship arise after the plaintiffs first case is initiated the second case is not barred by res judicata (D) holding second action barred by res judicata because plaintiff asserted identical claims and jurisdictional grounds as the first action (E) holding that the plaintiffs claims were barred by res judicata when the federal courts judgment was finalized by denial of his petition for certiorari
holding that claims to the vsf benefits under various theories were barred by the res judicata effect of the state court judgment in castellano iii