With no explanation, chose the best option from "A", "B", "C" or "D". note that the record shows that Safeway amended its by-laws to provide broader indemnification and entered into indemnification agreements with all its directors in anticipation of litigation over the merger. See E.R. at 227, exh. 5, p. 17, & exh. 6. 26 . This argument has been roundly rejected by the courts. See, e.g., Wayne County Neighborhood Legal Servs. v. National Union Fire Ins. Co., 971 F.2d 1, 4 (6th Cir.1992); Harbor, 922 F.2d at 366; Ameriwood Indus. Int'l Corp. v. American Casualty Co., 840 F.Supp. 1143, 1158 (W.D.Mich.1993). 27 . E.R. at 195, p. 18, 20. 28 . We assume that the district court acted under this subsection in denying Safeway's claim for prejudgment interest. See E.R. at 239, p. 14. 29 . See also Hansen v. Covell, 218 Cal. 622, 629, 24 P.2d 772, 775-76 (1933) (<HOLDING>); but cf. National Union Fire Ins. Co. v. Showa

A: holding that the insured was entitled to prejudgment and postjudgment interest and attorney fees as found by the jury
B: holding that prejudgment interest should not be added to damages awarded for misrepresentation because the amount of damages were not liquidated or ascertainable before the verdict
C: holding that prejudgment interest may include compound interest
D: holding that plaintiff is entitled to prejudgment interest even though its ascertainable claim was reduced by defendants unliquidated setoff or counterclaim
D.