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.

seeking to invoke the exception must establish that they agreed to engage in a joint effort and to keep the shared information confidential from outsiders. See, e.g., United States v. Schwimmer, 892 F.2d 237, 243-44 (2d Cir.1989) (finding valid joint defense privilege where information was “imparted in confidence” between parties “who had agreed upon and undertaken a joint strategy”); United States v. Sawyer, 878 F.Supp. 295, 297 (D.Mass.1995) (despite similar interests between employer and employee, insufficient evidence that communications were made during the course of a joint defense effort; proponent could neither establish time frame of agreement nor acts creating and/or terminating the agreement); United States v. United Tech. Corp., 979 F.Supp. 108, 110, 112 (D.Conn.1997) (<HOLDING>); Libbey Glass, Inc. v. Oneida, Ltd., 197 
 Holding statements: (A) holding common interest doctrine shielded information consortium members shared pursuant to collaboration agreement (B) recognizing doctrine (C) recognizing that tribes and states understood that they shared the right to manage the exercise of in common hunting and fishing rights (D) recognizing a subset of the common interest privilege as parents and schools have a corresponding interest in the free flow of information about administrators and faculty members (E) holding that there was no waiver of the work product protection because the business and public relations firm specializing in litigationrelated crisis management shared a common interest
recognizing doctrine

search a premises, Weston, 67 M.J. at 393 (citing Matlock, 415 U.S. 164, 94 S.Ct. 988), I do not believe that case to be controlling. Matlock was arrested on the front lawn of the house, Matlock, 415 U.S. at 166, 94 S.Ct. 988, and placed in a nearby police car. Id. at 179, 94 S.Ct. 988 (Douglas, J., dissenting). The arresting officers subsequently approached the house, spoke with a resident who shared a bedroom with Matlock, and received permission to search that bedroom. Id. at 166, 94 S.Ct. 988. The police did not ask Matlock for his consent to search the bedroom, nor did he offer it. Id. The Supreme Court recognized the consent of the cotenant may be valid against a eotenant who has not objected. Id. at 170, 94 S.Ct. 988; see also Rodriguez, 497 U.S. at 179-80, 186, 110 S.Ct. 2793 (<HOLDING>). This case differs from Matlock and Rodriguez 
 Holding statements: (A) holding cotenants consent to search valid where rodriguez who was asleep inside the house was not asked for his consent if police reasonably believed the consenter possessed common authority over the premises (B) holding that the agents superficial and cursory questioning of the consenting party did not disclose sufficient information for the agent reasonably to believe that she had common authority over the premises and that further inquiry was required under rodriguez (C) holding that mother who was resident of house shared with adult daughter could give valid consent to search premises (D) holding that consent to search premises includes consent to search washing machine on those premises (E) holding that there is no violation of the fourth amendment when the government reasonably believed that the individual giving consent to the search had authority to do so
holding that the agents superficial and cursory questioning of the consenting party did not disclose sufficient information for the agent reasonably to believe that she had common authority over the premises and that further inquiry was required under rodriguez

making of competent parents.” (citing Troxel v. Granville, 530 U.S. 57, 67-69, 120 S.Ct. 2054, 147 L.Ed.2d 49 (2000))). We have further held that it is the party opposing termination of the guardianship who bears the burden of proving that the petitioning parent is currently unfit to regain custody of the child. Guardianship of David C., 2010 ME 136, ¶¶ 4, 7, 10 A.3d 684. [¶ 12] Although the Legislature has established the standard of a preponderance of the evidence for addressing the best interest of the child.in a proceeding to terminate a guardianship, neither we nor the Legislature has made clear what specific standard of proof the existing guardian must meet in proving the petitionin 174-75 (2010) (same); In re Guardianship of D.J., 268 Neb. 239, 682 N.W.2d 238, 243-46 (2004) (<HOLDING>). [¶ 13] We need not decide the applicable 
 Holding statements: (A) recognizing that the child custody act required that the natural parent presumption must be seriously considered and heavily weighted in favor of the parent but that the presumption is rebutted if the clear and convincing evidence establishes that the best interest of the child is served by awarding custody to the third party (B) holding that the guardianship must terminate unless the guardian proves by clear and convincing evidence that the petitioning parent is either unfit or has forfeited the right to custody (C) holding custody and guardianship of child whose natural parent is adjudicated unfit mandatorily vests with social services (D) holding that on a parents petition the guardianship must terminate unless the guardian proves by clear and convincing evidence that terminating the guardianship would result in physical or emotional harm to the child (E) recognizing the fundamental liberty interest a parent has in his or her child and concluding that the state must provide a parent with fundamentally fair procedures including a clear and convincing evidentiary standard when seeking to terminate parental rights

recognizing that the child custody act required that the natural parent presumption must be seriously considered and heavily weighted in favor of the parent but that the presumption is rebutted if the clear and convincing evidence establishes that the best interest of the child is served by awarding custody to the third party