Task: Text Completion
Input (English): 1. In light of Lewis’ refusal (or inability) to hire her own attorney, to accept appointed counsel, or to represent herself, the district court’s determination that she forfeited her right to counsel was “fair and reasonable.” United States v. Kelm, 827 F.2d 1319, 1322 (9th Cir.1987) (<HOLDING>). 2. The district court did not abuse its 
 Holding statements: (A) holding that where the insurer retains an attorney to represent the insured pursuant to an insurance policy the attorney acts in the capacity of an independent contractor for the insured (B) holding that defendant forfeited his right to counsel by verbally abusing and threatening to harm his attorney threatening to sue his attorney on four different occasions and attempting to persuade his attorney to engage in unethical conduct (C) holding courts have inherent authority to compel compensation for an attorney appointed to represent an indigent defendant (D) holding attorney general could not contract on behalf of the state to employ an assistant attorney beyond the attorney generals own term (E) holding that in light of kelms persistent refusal to accept an appointed attorney to hire his own attorney or to expressly waive his right to an attorney the district courts decision forcing kelm to represent himself was fair and reasonable
Output (English): (E)