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. The four incorrect answers are other holding statements. You should find the correct option. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

Example Input: before it was in assumpsit for attorney fees purposes. See Schulz, 67 Haw. at 436, 690 P.2d at 282. Although Higa is not directly on point, its reasoning is a compelling indication of how the Hawaii Supreme Court would rule on the attorney fee question before us. The plaintiffs also seek to distinguish Higa because it involved a client suing his own attorney, and thus in that case there was privity of contract between the two parties. In the present case, Mrs. Helfand was a third-party beneficiary to the contract between the defendants and Mr. Helfand. This distinction is irrelevant. Courts have extended the right to sue for breach of contract to intended third-party beneficiaries. See, e.g., Dawes v. First Ins. Co. of Hawai'i, 77 Hawai'i 117, 128 n. 12, 883 P.2d 38, 48 n. 12 (1994) (<HOLDING>); Hunt v. First Insurance Co. of Hawaii, 82
Holding statements: (A) holding that thirdparty claimants are intended beneficiaries under optional automobile liability insurance policies (B) recognizing common law cause of action as thirdparty beneficiary (C) holding that the shareholders were not thirdparty beneficiaries because they were not directly benefited by the contract between the government and the thrifts (D) recognizing noncontracting parties rights as thirdparty beneficiaries of an insurance contract (E) holding that shareholders lack standing to sue as thirdparty beneficiaries to allegedly breached contract unless the contract indicates the intent to benefit them directly independently of their shareholder status
Example Output: (D)

Example Input: Defendants contend that the amount awarded was excessive and shocking, such as to raise an irresistible inference that passion, prejudice or other improper influence invaded the trial. Defendants initially make this argument on the grounds that the disparity between punitive damages assessed against the "passive wrongdoer" (AGF) is too large in contrast to the amount assessed against the "active wrongdoer" (Risser). We reject this argument for many reasons. First, it assumes that AGF should not have been found liable for negligent retention of an employee. Obviously, the jury disagreed with this assessment. Second, the legal basis for assessing punitive damages on respondeat superior grounds is well-established. Plains Resources, Inc. v. Gable, 235 Kan. 580, 682 P.2d 653, 665 (1984) (<HOLDING>). In the U.S. Supreme Court's recent deci sion,
Holding statements: (A) recognizing that restatement second of torts 323 and 324a correctly state pennsylvania law (B) recognizing kansas courts adoption of restatement second of torts 909 1977 (C) recognizing that restatement second of torts 416 to 429 are often overlapping (D) recognizing tentative draft of restatement second of torts 652e (E) recognizing that kansas supreme court would accept the final draft of the restatement second of torts 652e adopted in 1977
Example Output: (B)

Example Input: raised, the purported defect in the notice of foreclosure is insufficient to withstand summary judgment. Under 44-14-162.2, a secured creditor must provide the debtor with notice of a foreclosure sale that, in relevant part, "shall be in writing [and] shall include the name, address, and telephone number of the individual or entity who shall have full authority to negotiate, amend, and modify all terms of the mortgage with the debtorf.]" O.C.G.A. 44-14-162.2(a). Georgia courts have concluded that substantial compliance with this statute's notice provision is sufficient. See TKW Partners, LLC v. Archer Capital Fund, L.P., 302 Ga.App. 443, 446, 691 S.E.2d 300 (Ga.Ct.App.2010). See also Stowers v. Branch Banking & Trust Co., 317 Ga.App. 893, 895, 731 S.E.2d 367 (Ga.Ct.App.2012) (<HOLDING>). Viewing the facts in the light most favorable
Holding statements: (A) holding that notice to the attorney of record constitutes notice to the petitioner (B) recognizing that the applicant received notice from the plea form even though such notice was not required (C) holding that a defendant is not entitled to relief from default judgment because notice to an attorney of filing of motions and orders is constructive notice to the client even when the client did not have actual notice (D) holding that the court lacked jurisdiction to consider an award of sanctions entered against attorney because the notice of appeal did not provide that attorney was appealing in his own name (E) holding that notice of foreclosure listing name address and phone number of attorney rather than the lender was sufficient under 44141622 even though the attorney did not have full authority to negotiate amend and modify the loan and the notice listed no entity or individual with such authority
Example Output:
(E)