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.

The motions alleged the mother was seeking to intervene in the proceedings, individually and on behalf of the minor child, for the purpose of challenging the agreement and the order terminating parental rights as the termination had deprived the child of support and a father/child relationship. The trial court denied the motions to intervene, indicating the mother's remedies, if any, "lie in # 09-15176 [the custody case] ... with Kelley Lynn Reed as Petitioner." In this appeal, the mother challenges the denial of her motions to intervene. There is no question that the parents' agreement for termination of the father's parental rights and the subsequent order adopting such agreement are void and subject to challenge. See, e.g., Casbar v. Dicanio, 666 So.2d 1028 (Fla. 4th DCA 1996) (<HOLDING>); Fleming v. Brown, 581 So.2d 202 (Fla. 5th DCA
Holding statements: (A) holding that in parental termination proceedings the parent is entitled to effective assistance of counsel (B) recognizing this substantial interest in context of termination of parental rights (C) recognizing that the department is required to present clear and convincing evidence to support termination of a parents parental rights (D) holding that termination of fathers parental rights should be reversed since it was done to facilitate childs adoption and would prejudice rights of child and mother to receive support from father (E) recognizing that termination of parental rights can be accomplished only by resort to chapters 63 adoption and 39 termination of parental rights and any attempt by a parent to contract away the childs right to support is void and unenforceable as contrary to public policy
holding that in parental termination proceedings the parent is entitled to effective assistance of counsel