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.

Input: Consider Input: 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

Output: recognizing doctrine


Input: Consider Input: in the petition no later than thirty days from the day on which the first defendant was served. Id. at 1262-63 (internal citations omitted). As a general premise, under the “first-served rule,” defendants who are properly served within thirty days of the first defendant’s service must join in the removal petition. The “failure to do so renders the petition defective.” Id. at 1262. Under the facts of Getty, however, the application of the first-served rule did not produce an inequitable result. Nonetheless, recognizing the potential for harsh results, other decisions provide that exceptional circumstances may sometimes require relief from strict application of the rule in order to achieve equitable results. See Milstead Supply Co. v. Cas. Ins. Co., 797 F.Supp. 569, 573 (W.D.Tex.1992) (<HOLDING>); Brown v. Demco, Inc., 792 F.2d 478, 482 (5th 
 Holding statements: (A) holding that all properly served defendants must join in petition for removal except for nominal unknown or fraudulently joined parties (B) holding that the defendants filing of a notice of removal before being served by plaintiffs did not render removal defective (C) holding that dismissal of some but not all of the defendants who had been served with complaint is not a final order (D) holding that joinder in or consent to the removal petition must be accomplished by only those defendants 1 who have been served and 2 whom the removing defendants actually knew or should have known had been served (E) holding that the defendants consent to search was voluntary although he had been served with a subpoena

Output: holding that all properly served defendants must join in petition for removal except for nominal unknown or fraudulently joined parties


Input: Consider Input: a conclusion that the defendant had been convicted in state court of an “escape” crime that generically qualifies as a violent felony under § 924(e).... [E]ven the facts outside the scope of Shepard, if they could have been considered, would have narrowed Mills’[s] conviction only to either a failure to report or a walkaway escape from a non-secure facility.... [T]he Government concedes that a simple walkaway escape from a nonsecure community residence does not constitute the sort of purposeful, aggressive and violent behavior that is required ... to constitute a “violent felony” for the purposes of § 924(e). Id. at 2-3. We need not address whether a “walkaway escape” is, as the government says, not a violent felony for these purposes under Chambers. Cf. Jackson, 301 F.3d at 63 (<HOLDING>). For the purpose of deciding this appeal, it 
 Holding statements: (A) holding prior to chambers that a walkaway escape is categorically a violent felony (B) holding that escape is categorically a violent felony under the acca (C) holding that walkaway from community treatment center conviction was a crime of violence consistent with chambers (D) holding that escape from secure custody is a violent felony (E) holding walkaway escape under north dakota statute a crime of violence


Output: holding that escape is categorically a violent felony under the acca