You will be given a definition of a task first, then some input of the task.
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.

in the earlier proceeding commensurate with those in the subsequent proceeding, Maryland Cas. Co. v. Messina, 874 P.2d 1058, 1062 (Colo.1994), but also that the party against whom collateral estoppel is asserted have had the same incentive to vigorously defend itself in the previous action, Salida Sch. Dist. R-32-J v. Morrison, 782 P.2d at 1166-67; Restatement (Second) of Judgments 28(5)(c) & emt. j (1982). A party necessarily lacks the same incentive to defend where its exposure to liability is substantially less at the earlier proceeding. Salida, 732 P.2d at 1166-67. In addition to the amount of potential money awards, significant variations in exposure may arise from differences in the finality or permanence of judgments, see In re C.M., 675 N.E.2d 1134, 1137-38 (Ind.Ct.App.1997) (<HOLDING>); In re Frederick, 405 Mass. 1, 537 N.E.2d
Holding statements: (A) holding that consortium is not a part of the parentchild relationship (B) recognizing that parents incentive to defend in a child in need of supervision proceeding where resulting order is temporary in nature and entitles parent and child to government services is dramatically different from incentive to vigorously litigate same issues in parentaltermination proceeding where the result is permanent and completely severs parentchild relationship (C) holding when real estate is conveyed to a child and consideration is paid by the parent the presumption is that the purchase was a gift to the child and thus no resulting trust arises (D) holding that a workers compensation proceeding is a legal proceeding (E) holding that attorneys fees and costs may not be awarded as child support when they are incurred in a suit to modify the parentchild relationship that does not involve the enforcement of a child support obligation
Output:
holding that consortium is not a part of the parentchild relationship