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.

Q: so complete a defense as he might reasonably have desired”), cert. denied, 513 U.S. 820, 115 S.Ct. 81, 130 L.Ed.2d 34 (1994); 2d Cir.: United States v. Lawal, 736 F.2d 5, 9-10 (1984) (applying authorities for non-constitutional error to erroneous exclusion of hearsay); 3d Cir.: United States v. Asher, 854 F.2d 1483, 1498-1500 (3d Cir.1988) (making "non-constitutional 'harmless error' determination” for erroneous exclusion of hearsay), cert. denied, 488 U.S. 1029, 109 S.Ct. 836, 102 L.Ed.2d 969 (1989); 4th Cir.: United States v. Jones, 976 F.2d 176, 184-85 (1992) (citing Kotteakos as authority for holding erroneous exclusion of hearsay was harmless), cert. denied, 508 U.S. 914, 113 S.Ct. 2351, 124 L.Ed.2d 260 (1993); 5th Cir.: United States v. Barnett, 945 F.2d 1296, 1301 n. 3 (1991) (<HOLDING>), cert. denied, 503 U.S. 941, 112 S.Ct. 1487, 
 Holding statements: (A) holding erroneous exclusion of hearsay harmless under fedrcrimp 52a (B) holding second sentence of a nearly identical exclusion did not limit the scope of the exclusion (C) holding erroneous exclusion of hearsay did not deny defendant a substantial right (D) holdingthat erroneous admission of hearsay did not prejudiceresults of trial so as to require reversal (E) holding that exclusion of hearsay statements violated due process even though statements were not admissible under mississippi law which did not recognize declarations against penal interest as a exception to the rule against hearsay

A: holding erroneous exclusion of hearsay harmless under fedrcrimp 52a
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Q: motion at which Pritchett would be represented by counsel or at which the court would determine that Pritchett knowingly, intelligently, and voluntarily waived his right to counsel. Ex parte Pritchett, 117 So.3d at 362. In the instant case, the circuit court immediately appointed new counsel to represent Trimble after Trimble gave his oral notice of appeal. Despite having newly appointed counsel who could file a motion for a new trial attacking his trial counsel’s alleged deficiencies, Trimble elected to file a pro se motion for a new trial. Therefore, unlike the defendant in Pritchett, Trimble had the benefit of newly appointed appellate counsel who represented him and who could file a motion for a new trial on his behalf. See King v. State, 613 So.2d 888 (Ala.Crim.App.1993) 
 Holding statements: (A) holding that a valid waiver of counsel at an early stage of the proceeding does not continue in effect through a subsequent stage (B) holding that posttrial motion for new trial is critical stage requiring counsel or valid waiver (C) holding postindictment lineup is critical stage of trial at which defendant is entitled to presence of counsel (D) holding that the filing of a motion for a new trial is a critical stage of the prosecution and that an indigent defendant is constitutionally entitled to the assistance of counsel at that stage (E) holding that sentencing is a critical stage of criminal proceedings and the offer of counsel must be renewed at each critical stage where the defendant appears without counsel

A: holding that a valid waiver of counsel at an early stage of the proceeding does not continue in effect through a subsequent stage
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Q: did so after Mr. Wilson’s appeal, his complaint that they failed to do so immediately, however justified, is now moot. 2. Scope of the Request Mr. Wilson further argues that the FHWA made an “unreasonable and unilateral assumption that the Plaintiff requested only ‘formal’ complaints.” Opp’n at 8. The FOIA Appeals Official determined that the FHWA’s interpretation that Mr. Wilson was seeking formal complaints, instead of informal records such as counseling logs, was “more than reasonable.” Nov. 20, 2009 Final Agency Decision at 2. An agency may decide to limit the scope of an ambiguous request as long as the narrowed scope is a reasonable interpretation of what the request seeks. See, e.g., Mogenhan v. Dep’t of Homeland Sec., No. 06-2045, 2007 WL 2007502, at *3 (D.D.C. July 10, 2007) (<HOLDING>); Adamowicz v. IRS, 552 F.Supp.2d 355, 362 
 Holding statements: (A) holding that counsels failure to file appeal was not deficient performance under strickland where the petitioner in  2255 action did not direct counsel to file an appeal and acquiesced in counsels decision to pursue as an alternative a reduction in sentence (B) holding that extraordinary circumstances did not include the mere neglect of the professional who was in a position to file a timely application (C) holding that it is proper to dismiss an appellants appeal for failure to file a brief or request an extension within the time allotted by the bankruptcy rules (D) holding reasonable an agency determination that a request for an investigative file did not include the employment file (E) holding defendant did not waive issues by failing to file posttrial motions where defendant did file petition for reconsideration which was intended to function as posttrial motion

A:
holding that counsels failure to file appeal was not deficient performance under strickland where the petitioner in  2255 action did not direct counsel to file an appeal and acquiesced in counsels decision to pursue as an alternative a reduction in sentence
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