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.

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
recognizing doctrine

motion at which Pritchett would be represented by counsel or at which the court would determine that Pritchett knowingly, intelligently, and voluntarily waived his right to counsel. Ex parte Pritchett, 117 So.3d at 362. In the instant case, the circuit court immediately appointed new counsel to represent Trimble after Trimble gave his oral notice of appeal. Despite having newly appointed counsel who could file a motion for a new trial attacking his trial counsel's alleged deficiencies, Trimble elected to file a pro se motion for a new trial. Therefore, unlike the defendant in Pritchett, Trimble had the benefit of newly appointed appellate counsel who represented him and who could file a motion for a new trial on his behalf. See King v. State, 613 So.2d 888 (Ala.Crim.App.1993)
Holding statements: (A) holding that a valid waiver of counsel at an early stage of the proceeding does not continue in effect through a subsequent stage (B) holding that posttrial motion for new trial is critical stage requiring counsel or valid waiver (C) holding postindictment lineup is critical stage of trial at which defendant is entitled to presence of counsel (D) holding that the filing of a motion for a new trial is a critical stage of the prosecution and that an indigent defendant is constitutionally entitled to the assistance of counsel at that stage (E) holding that sentencing is a critical stage of criminal proceedings and the offer of counsel must be renewed at each critical stage where the defendant appears without counsel
holding that a valid waiver of counsel at an early stage of the proceeding does not continue in effect through a subsequent stage

typographical error problem addressed in Greenstreet v. State, 392 Md. 652, 898 A.2d 961, (2006). In that case, the Court held that a police officer could not testify that the date in the affidavit in support of search warrant was a typographical errorthat instead of "4-14-03," it should have been "4-14-04." The Court reasoned that permitting such testimony would allow the officer to controvert his statement of the date in the affidavit, in "violation of the four corners rule and the purpose for its existence." Id. at 671, 898 A.2d 961. Here, the words "premise" and "premises" both are used in the application and warrant, and therefore we properly may infer that one word ("premise") is a mistaken use or spelling of the other word ("premises"). Greenstreet, supra, at 672, 898 A.2d 961 (<HOLDING>). 4 . The McTyre case has been distinguished on
Holding statements: (A) holding that an affidavit did not provide probable cause sufficient to validate a warrant where the affidavit stated an incorrect date uncontradicted by any other specific fact in the affidavit (B) recognizing cases from other jurisdictions that stand for the proposition that where a factual date in the affidavit material to the probable cause finding is an apparent typographical error because it is contradicted by another factual time or date more likely to be true also contained within the four comers of the affidavit then a reviewing court may infer that a typographical error was made by the affiant and treat it as something other than what was written in the affidavit (C) holding that the presence of the correct address in the sworn affidavit could correct a typographical error in the warrant (D) holding that section 144 requires both a factual affidavit and a separate certificate that the affidavit was made in good faith (E) holding that the court may disregard an affidavit submitted solely for the purpose of opposing a motion for summary judgment when that affidavit is directly contradicted by deposition testimony and the nonmovant does not explain the discrepancies
holding that an affidavit did not provide probable cause sufficient to validate a warrant where the affidavit stated an incorrect date uncontradicted by any other specific fact in the affidavit