You will be given a definition of a task first, then some input of the task.
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.

("Rule 804(b)(6) is an attempt to respond to the problem of witness intimidation[.]"). As a result, the plain language of the rule requires that the defendant not only be involved in causing the witness's unavailability, but also that the defendant commit the relevant act with the intent to prevent the witness from testifying. {20} Some state and federal courts, however, have decided that the "intent to silence" requirement is only mandated by the federal rules and not by the constitution. See, e.g., United States v. Garcia-Meza, 403 F.3d 364, 370 (6th Cir.2005) ("Though the Federal Rules of Evidence may contain [the intent to silence] requirement, the right secured by the Sixth Amendment does not[.]" (internal citation omitted)); Gonzalez v. State, 155 S.W.3d 603, 611 (Tex.App.2004) (<HOLDING>); Ruiz, 2005 WL 1670426, at *6 ("Ultimately, if
Holding statements: (A) recognizing that some states it should be noted have adopted a hybrid approach (B) holding that since the reference in 2461c to the procedures of 853 includes the latter statutes implicit authorization of in personam money judgments we see no reason why this reference should not also include the forfeiture of substitute assets (C) holding that no exception to the invited error doctrine has ever been adopted by this circuit (D) holding that while some courts have adopted the intent to silence requirement we see no reason why the forfeiture doctrine should be limited to such cases (E) holding that the fifth amendment in its direct application to the federal government and in its bearing on the states by reason of the fourteenth amendment forbids either comment by the prosecution on the accuseds silence or instructions by the court that such silence is evidence of guilt
Output:
recognizing that some states it should be noted have adopted a hybrid approach