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.
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Question: are differences between sanctions under Rule 37(a) and substitution of counsel conditioned on payment of fees, the parallel considerations convince us that the Cunningham rationale applies here. Like Rule 37(a) sanctions, the present situation invokes concerns regarding finality, avoiding piecemeal appeals, and availability of effective appellate review." Id. Cases from the First, Second, Third, and Fifth Circuits further support interpreting Cunningham as applying more broadly than to Rule 37(a) sanctions alone. The First Circuit recognized in Empresas Omajede, Inc. v. Bennazar-Zequeira, 213 F.3d 6, 9 n. 4 (1st Cir.2000), that Cunningham affirmed its precedents denying interlocutory appeals in the sanctions area. See, e.g., United States v. Kouri-Perez, 187 F.3d 1, 14 (1st Cir.1999) (<HOLDING>); Appeal of Licht & Semonoff 796 F.2d 564, 573
Holding statements: (A) holding district courts order postponing ruling on defendants qualified immunity defense was immediately appealable (B) holding sanctions pursuant to rule 26g not immediately appealable (C) holding sanctions order pursuant to district courts inherent powers not immediately appealable (D) holding such denial to be an immediately appealable collateral final order (E) holding an order of rule 37a sanctions against an attorney is immediately appealable under 1291

Answer: holding district courts order postponing ruling on defendants qualified immunity defense was immediately appealable

Question: court, in addition to other disbursements allowed by law, the following costs: . . . For travel, such sum as the court may allow"); Mass.RCiv.P. 54(d) ("Except when express provision therefore is made either in a statute of the Commonwealth or on these rules, costs shall be allowed as of course to the prevailing pariy unless the court otherwise directs"). However, the Supreme Judicial Court cautioned that "(i]n taxing costs, courts do not seek to compensate litigants fully for the cost of litigation." Waldman v. American Honda Motor Co., supra, 413 Mass, at 322. Furthermore, the Supreme Judicial Court has advised that "where such costs are permitted, an award of costs is allowable only when based on 'specific affirmative authority.' " Demoulas v. Demoulas, 432 Mass. 43, 64 (2000) (<HOLDING>). 4.Travel Costs of Prevailing Party In
Holding statements: (A) holding that attorneys fees and court costs are recoverable under general hold harmless indemnity agreement (B) holding costs of service of subpoenas recoverable (C) holding that costs of daily transcripts during trial are not recoverable (D) holding attorneys fees not generally recoverable unless party prevails under cause of action for which attorneys fees are recoverable and damages are recovered (E) holding that fees are not recoverable for work for which the client could not be charged

Answer: holding that attorneys fees and court costs are recoverable under general hold harmless indemnity agreement

Question: court's interim order and the entirety of its findings of fact and conclusions of law. 1 . See Johnson v. Johnson, 836 P.2d 930, 933 (Alaska 1992); Burrell v. Burrell, 537 P.2d 1, 7 (Alaska 1975). 2 . See Ulsher v. Ulsher, 867 P.2d 819, 821 (Alaska 1994). 3 . See Monette v. Hoff, 958 P.2d 434, 436-37 (Alaska 1998); Vachon v. Pugliese, 931 P.2d 371, 375 (Alaska 1996); J.F.E. v. J.A.S., 930 P.2d 409, 411 (Alaska 1996). 4 . See Lewis v. Lewis, 785 P.2d 550, 552 (Alaska 1990). 5 . See Burrell, 537 P.2d at 7. 6 . See Vachon, 931 P.2d at 375. 7 . See Kowalski v. Kowalski, 806 P.2d 1368, 1370 (Alaska 1991). 8 . See Alaska R. Civ. P. 52(a) (requiring trial courts to make findings in support of their decisions in non-jury cases); see also Duffus v. Duffus, 932 P.2d 777, 779 (Alaska 1997) (<HOLDING>); Bird v. Starkey, 914 P.2d 1246, 1249 (Alaska
Holding statements: (A) holding it improper to independently review the record to find support for a trial courts decision so long as it is unclear whether the trial court considered statutory factors (B) holding that as long as the findings are supported by substantial evidence the board must defer to the hearing committees credibility determinations because they are subsidiary findings of basic facts (C) holding that wjhile trial courts are encouraged to state all findings in their written child custody orders they are not required to do so as long as the basis for their decisions is clear from the record and thus susceptible to review (D) holding that that choices as to selection and arrangement are entitled to copyright protection only so long as they are made independently (E) holding that even though defendants response does not affirmatively state in the document itself that they are competent to testify as to the facts to which they swore does not necessarily doom their testimony so long as the record taken as a whole demonstrates that their testimony meets the requirements of rule 56

Answer:
holding it improper to independently review the record to find support for a trial courts decision so long as it is unclear whether the trial court considered statutory factors