Read the following excerpt from a US court opinion:
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the level of persecution; 2) that the persecution was on account of one or more of the five protected grounds; and 3) that the persecution was committed either by the government or by forces that the government was unable or unwilling to control. Chand v. INS, 222 F.3d 1066, 1073 (9th Cir.2000). We have defined persecution as “the infliction of suffering or harm upon those who differ (in race, religion or political opinion) in a way regarded as offensive.” Fisher v. INS, 79 F.3d 955, 961 (9th Cir. 1996) (en banc) (internal quotation marks omitted); see also Kovac v. INS, 407 F.2d 102, 107 (9th Cir.1969). Threats and attacks can constitute persecution even where an applicant has not been beaten or physically harmed. See, e.g., Artiga Turcios v. INS, 829 F.2d 720, 723-24 (9th Cir. 1987) . Here, Ganut and his party were attacked by
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What is the most suitable continuation to the opinion? Your options are:
A. holding that trial court abused its discretion in denying petitioners request for counsel in evidentiary hearing where petitioner had requested counsel and had indicated in his motion that all documents had been prepared by prison law clerk he had only ninthgrade education he had no training in the law and he lacked the skills necessary to participate in hearing
B. holding that petitioner had established persecution even though he had not been physically harmed and received only an indirect threat relayed by a neighbor
C. holding that a claim for surcharge had been plausibly stated even though the precise term had not been used
D. holding that alien must show that he faces a particularized threat of persecution
E. holding that where petitioner testified that some of her cousins had been killed because they served in the military and that she had received two threatening notes she had demonstrated past persecution
Reply with [A, B, C, D, E] only.