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.

[EX Q]: the effect that the code-fendant’s confession must be disregarded in determining the defendant’s guilt or innocence is ineffective and cannot overcome the prejudicial effect of the incriminating statement on the jury. Id. at 124, 88 S.Ct. 1620. As such, the trial court’s curative instruction in the instant case was insufficient to cure the erroneous admission of Hertz’s statement to Hathcock. Nonetheless, this Court has also recognized that a Bruton violation does not automatically require reversal of an otherwise valid conviction but, rather, is subject to a harmless error analysis. See Farina v. State, 679 So.2d 1151, 1155 (Fla.1996) (citing Harrington v. California, 395 U.S. 250, 254, 89 S.Ct. 1726, 23 L.Ed.2d 284, (1969)); see also Franqui v. State, 699 So.2d 1312, 1322 (Fla.1997) (<HOLDING>); Smith v. State, 699 So.2d 629, 644-45 
 Holding statements: (A) holding that confrontation clause violation was not harmless beyond a reasonable doubt in part because it concerned the limitation of crossexamination of the prosecutions key witness (B) holding that the sixth amendment confrontation clause violation in that case was harmless beyond a reasonable doubt and therefore did not require the conviction to be overturned (C) holding that a confrontation clause violation constituted harmless error (D) holding confrontation clause violation was harmless beyond a reasonable doubt and thus upholding firstdegree murder conviction (E) holding that testimony at trial in violation of defendants constitutional confrontation right was harmless beyond a reasonable doubt because the testimony was cumulative
[EX A]: holding that confrontation clause violation was not harmless beyond a reasonable doubt in part because it concerned the limitation of crossexamination of the prosecutions key witness

[EX Q]: judicial review of an arbitration award. See UHC Management Co., 148 F.3d at 998 (“ “We may not set an award aside simply because ... the arbitrators erred in interpreting the law or in determining the facts.’ ”) (quoting Stroh Container Co., 783 F.2d at 751). This third challenge is nonetheless partially cognizable, but only to the extent it can be read as an assertion that there was evident partiality or corruption in the arbitrators, a statutory ground under 9 U.S.C. § 10(a)(2), as a claim of misconduct by the arbitrators in refusing to hear evidence or to provide a reasonable opportunity to present evidence, another statutory ground under 9 U.S.C. § 10(a)(3), or as an extra-statutory challenge to the “fundamental fairness” of the proceedings. See P & P Indus., Inc., 179 F.3d at 870 (<HOLDING>). Hoffman’s fourth challenge is to the denial 
 Holding statements: (A) recognizing such a ground for judicial review of arbitration awards in this circuit (B) holding right to be fundamental (C) holding that section 34810 is an adequate and independent state ground (D) recognizing plain or fundamental error (E) recognizing review for fundamental unfairness of the proceedings as an independent extrastatutory ground
[EX A]: recognizing such a ground for judicial review of arbitration awards in this circuit

[EX Q]: Cas. and Sur. Co., 435 F.3d 252, 260 (3d Cir.2006) (“It has long been the rule in this Circuit that insurance policies are considered part of the property of a bankruptcy estate”) (citing Estate of Lellock v. The Prudential Ins. Co. of Am., 811 F.2d 186, 189 (3d Cir.1987)); In re Louisiana World Exposition, Inc., 832 F.2d 1391, 1399 (5th Cir.1987); In re SN Liquidation, Inc., 388 B.R. 579, 583-584 (Bankr.D.Del.2008) ("Insurance policies purchased and paid for by a debtor are property of the estate.”); In re World Health Alternatives, Inc., 369 B.R. 805, 809 (Bankr.D.Del.2007) ("It is clear that insurance policies purchased and paid for by a debtor are property of the estate."); In re A (Bankr.E.D.N.Y.1999) (same); but see In re Circle K Corp., 121 B.R. 257 (Bankr.D.Ariz.1990) (<HOLDING>). 31 . See In re Allied Digital, 306 B.R. at 
 Holding statements: (A) holding the real estate sale proceeds (B) holding that where the policy names only the directors or officers as insured the proceeds are not property of the estate (C) holding that because proceeds of a letter of credit were not secured by estate collateral the proceeds were not property of the estate (D) holding that the proceeds of a liability insurance policy were not property of the estate (E) holding directors and officers liability policy was not property of the estate because it did not increase or decrease the worth of the bankruptcy estate
[EX A]:
holding the real estate sale proceeds