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.
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Question: 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

Answer: recognizing doctrine


Question: while the parties informally agreed to extend the discovery deadline in order to allow further expert depositions, we do not regard this arrangement as a waiver by plaintiffs of their right to receive documents of such volume and complexity in a sufficiently timely manner to allow an effective response. We recognize, of course, the normal tendency for preparations to intensify as trial approaches and, thus, suggest no general bar to material produced seasonably and in good faith. See Fusco v. General Motors Corp., 11 F.3d 259, 266 (1st Cir.1993). In this case, however, we believe that, if Ford intended to rely on this evidence at trial, it should have made more diligent efforts at its timely production. Cf. Glover v. Grace Pac. Corp., 86 Hawai'i 154, 164, 948 P.2d 575, 585 (App.1997) (<HOLDING>). The trial court, nevertheless, distinguished 
 Holding statements: (A) holding that a request for admission is a tool of discovery subject to discovery cutoff dates (B) holding the record which included the opinion of several physicians was sufficient for the alj to arrive at a decision (C) holding that the trial court properly excluded an expert who failed to arrive at his final opinion before the discovery cutoff date (D) holding that plaintiff need not have submitted requests for admissions by the august 15 discovery motion cutoff date or by the discovery cutoff date of september 15 because requests for admissions are distinct from other general discovery devices and are not subject to discovery cutoff dates (E) holding that requests for admissions are subject to discovery cutoff dates

Answer: holding that a request for admission is a tool of discovery subject to discovery cutoff dates


Question: 879 (citations omitted). We think there is a reasonable fit here between the State’s purpose of protecting society from persons who have been determined to be likely to reoffend if not placed in a secure facility and their placement in such a facility. Therefore, Garren has failed to show a substantive due process violation. VII. Vagueness. Although Garren states in a division heading in his brief that chapter 229A is vague as applied and on its face, he makes no argument in his brief in support of the contention that the statute is vague as applied to him. We deem this issue waived. See Iowa R.App.P. 14(a)(3) (“Failure in the brief to state, to argue or to cite to authority in support of an issue may be deemed waiver of that issue.”); State v. Cooley, 608 N.W.2d 9, 13-14 (Iowa 2000) (<HOLDING>). Consequently, Garren is precluded from 
 Holding statements: (A) holding issue first addressed in appellants reply brief was not waived because it was in response to argument first presented in appellees brief (B) holding issue waived where matter not addressed beyond reference in heading in brief (C) holding that an issue mentioned in a brief but not addressed is waived (D) holding issues argued orally but not addressed in brief were waived (E) holding an issue listed in statement of issues on appeal but not addressed in brief is abandoned

Answer:
holding issue first addressed in appellants reply brief was not waived because it was in response to argument first presented in appellees brief