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. The four incorrect answers are other holding statements. You should find the correct option. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

[EX Q]: Statement. They were, however, obtained prior to this Court’s actual approval of the Amended Disclosure Statement, which occurred on December 19, 2008 (i.e. at the joint hearing on approval of the Amended Disclosure Statement and the Amended Plan). Although typically a disclosure statement should be approved before the proponent solicits votes for the plan, here the premature solicitation was harmless and, as noted by the Bankruptcy Court for the Northern District of Georgia, a harmless failure to comply with § 1125’s solicitation requirements “is not necessarily fatal to the success of a Chapter 11 reorganization.” In re N.W. Recreational Activities, Inc., 8 B.R. 10, 12 (Bankr.D.Ga.1980); see also First Am. Bank of N.Y. v. Century Glove, Inc., 81 B.R. 274, 278-80 (D.Del.1988) (<HOLDING>). Pursuant to 11 U.S.C. § 105(d)(2)(B)(vi), 
 Holding statements: (A) holding that order denying confirmation of plan became final when upon being notified that the debtors did not intend to seek confirmation of an alternate plan the court dismissed their case (B) holding such agreements to be per se illegal (C) holding that per se statutory rule is not permissible under fourth amendment (D) holding hearing in chambers was not per se a violation of due process (E) holding that a plan proponents failure to obtain court approval of solicitation materials is not per se fatal to the confirmation process
[EX A]: (E)

[EX Q]: in original). With the possible exception of his claim that he was not permitted to testify, Man-giardi has not satisfied either prong of the Strickland test. Because each of Mangiardi’s claims relating to the proceedings is meritless, appellate counsel was not unreasonable for any failure to raise any of them on direct appeal. See Williams, 166 F.Supp.2d at 305 (finding that where each of the claims raised in the defendant’s § 2255 motion was meritless, appellate counsel was not deficient for failing to raise them on direct appeal). The same reasoning applies to appellate counsel’s failure to raise Man-giardi’s claims for ineffective assistance of trial counsel. See id., James v. Superintendent of SCI Huntington, No. CIV.A. 97-2864, 2000 WL 5196, at *3 (E.D.Pa. January 4, 2000) (<HOLDING>). Moreover, as discussed above, claims for 
 Holding statements: (A) holding that counsel cannot be deemed ineffective for failing to raise a meritless claim (B) holding that where trial counsel was not ineffective appellate counsel was not ineffective for failing to raise claim of ineffectiveness of trial counsel (C) recognizing a constitutional claim for ineffective assistance of counsel (D) holding no ineffective assistance of appellate counsel claim for failure to raise as basis for appeal of conviction ineffective assistance of trial counsel where basis for the latter claim was inadequate (E) holding trial counsel was not ineffective for failing to pursue a meritless issue
[EX A]: (B)

[EX Q]: the theory that it tended to prove the criminal ‘system’ of [the defendant].” Id. at 914. The court required the extraneous offense to be “so nearly identical in method to the charged offense as to earmark them as the handiwork of the accused.” Id. at 914-15 (internal quotations omitted). The similarity required to prove a “defendant’s system” naturally is high because the extraneous offense evidence is being used to show the defendant’s distinctive and idiosyncratic manner of committing the criminal acts. Id. We hold that it does not follow that an extraneous offense admitted to rebut the defensive theory of frame-up requires this same degree of exacting similarity between the extraneous and charged offenses. Cf. Plante v. State, 692 S.W.2d 487, 492-93 (Tex.Crim.App.1985) (En banc) (<HOLDING>). Moreover, the facts in Wheeler do not support 
 Holding statements: (A) holding evidence of virtually identical offense was relevant to show intent among other things in trial of charged offense (B) holding extraneous conduct subsequent to the charged offense admissible (C) holding proof of racially discriminatory intent or purpose required to show equal protection violation (D) holding that high degree of similarity between extraneous and charged offense used in cases proving modus operandi not required when purpose of proof is to show intent (E) holding extraneous acts relevant to show intent in charged offense
[EX A]:
(D)