Read the following excerpt from a US court opinion:
```
Karras argues that the trial court lacked jurisdiction over Hoy’s motion to determine his attorney’s lien. Karras contends that Hoy could only recover fees due through a separate action in quantum meruit. We disagree. First, quantum meruit is not the only remedy available to Hoy. Quantum meruit is “an equitable doctrine, based on the concept that no one who benefits by the labor and materials of another should be unjustly enriched thereby; under those circumstances, the law implies a promise to pay a reasonable amount for the labor and materials furnished, even absent a specific contract therefor.” Black’s Law Dictionary 1243 (6th ed.1990). However, South Dakota law explicitly allows an attorney to recover fees by operation of an attorney’s lien , 619 P.2d 620, 623 (Okla.1980) . We specifically adopt the reasoning of the
```
What is the most suitable continuation to the opinion? Your options are:
A. holding that the words allowed secured claim in  506d refer to a claim that is secured by a lien and allowed under  502
B. holding that a lawyers claim for impression of his statutory charging lien upon the recovery secured in an action may be prosecuted as an ancillary proceeding to the main litigation
C. holding that the attorneys charging lien may be asserted and enforced in the civil action which gave rise to the lien claim or in an independent action
D. holding that the lien bond releases the property from the lien but the lien is then secured by the bond
E. holding that a notice of appeal filed in an adversary proceeding could not appeal the main proceeding
Reply with [A, B, C, D, E] only.