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]: of record rather than the alien. The Federal Rules of Civil Procedure also favor notice of counsel of record rather than actual notice of the client. See Fed.R.Civ.P. 5(b) (stating that “whenever service under these rules is required or permitted to be made upon a party represented by an attorney the service shall be made upon the attorney unless service upon the party is ordered by the court”). Case precedent also indicates that actual notice of an alien is not required under the INA. See Sewak v. INS, 900 F.2d 667, 669 n. 6 (3d Cir.1990) (noting in dicta that notice to attorney comprised actual notice to alien); Reyes-Arias v. INS, 866 F.2d 500, 502-3 (D.C.Cir.1989) (finding actual knowledge of attorney constitutes reasonable notice); Newton v. INS, 622 F.2d 1193, 1194 (3d Cir.1980) (<HOLDING>). Anin received notice as required by the INA. 
 Holding statements: (A) holding that notice to supervisor is notice to city (B) holding that notice to the attorney of record constitutes notice to the petitioner (C) holding that actual notice fulfills a notice requirement that an applicable federal regulation be conspicuously posted because actual notice is the best notice (D) 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to the client even when the client did not have actual notice (E) holding that notice to original attorney not formally withdrawn comprised proper notice
[EX A]: holding that notice to supervisor is notice to city

[EX Q]: matter. When it is clear, however, from the relevant parts of the contract taken together and considered with the facts and circumstances surrounding the execution of the agreement, that the obligation in question was within the contemplation of the parties or was necessary to effect their intention, then such obligation may be implied and enforced. But when the contract between the parties speaks to the obligation sought to be implied, the courts will not write that implied obligation into the contract. Stated conversely, there may be an implied covenant on the part of the lessee (in the absence of any expressed on the subject as in the lease).[ ] Id. (citations, alterations, and quotation omitted). See also Nearburg v. Yates Petroleum Corp., 123 N.M. 526, 943 P.2d 560, 569 (1997) (<HOLDING>). Thus, in accordance with New Mexico law, any 
 Holding statements: (A) recognizing that endorsement would prevail if inconsistent with policy provisions (B) holding that courts cannot imply covenants which are inconsistent with express provisions (C) holding that state courts may not enforce racially restrictive covenants (D) holding that the restrictive covenants at issue are unenforceable as a matter of public policy (E) holding that the law will not imply a contract where there is an existing express contract covering the same subject matter
[EX A]: recognizing that endorsement would prevail if inconsistent with policy provisions

[EX Q]: applies to both GMR and its attorneys, who “stand on the same legal footing” as their clients. See Hoai v. Vo, 935 F.2d 308, 313 n. 5 (D.C.Cir.1991). Carlson also relies on the Supreme Court’s decision in Connecticut v. Doehr, 501 U.S. 1, 111 S.Ct. 2105, 115 L.Ed.2d 1 (1991). Like Lugar, Doehr concerned a state statute that authorized prejudgment attachment without prior notice or hearing. Id. at 4, 111 S.Ct. 2105. The Court did not, however, consider whether the private party was a state actor. Doehr offers no guidance here. The district court correctly applied this court’s § 1983 case law when rejecting Carlson’s claim. Finding private parties liable as state actors, this court has required joint action or conspiracy with state authorities. See Wickersham, 481 F.3d at 595, 599 (<HOLDING>); DuBose v. Kelly, 187 F.3d 999, 1003 (8th 
 Holding statements: (A) holding that the state police is a state agency (B) holding that a state agency created under state law was a state actor (C) holding that a private air show is a state actor when its president is the final arbiter of what constituted unwanted protest and directs whom police arrest (D) holding that establishing the existence of an understanding among private parties and state actors for  1983 conspiracy purposes is really nothing more than another way to show state action by alleging a private partys connection to a state actor (E) holding that amtrak was a state actor
[EX A]:
holding that the state police is a state agency

