Read the following excerpt from a US court opinion:
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we affirm the trial court’s decision, and we remand the case for further proceedings consistent with this opinion. 1 . The trial court noted that the detective asked Arroya whether or not she needed a kleenex, something to drink, and even whether she wanted an opportunity to smoke. Additionally, the court found, based its on review of the entire interrogation, that the detective had not used “unscrupulous techniques.” 2 . The law has developed differently in the area of a request for counsel. Building on a distinction first articulated in Miranda, 384 U.S. at 473-74, 86 S.Ct. 1602, the Supreme Court provides greater procedural safeguards for the right to counsel than for the right to remain silent. Compare Edwards v. Arizona, 451 U.S. 477, 484-85, 101 S.Ct. 1880, 68 L.Ed.2d 378 (1981)  with Mosley, 423 U.S. at 104 & n. 10, 96 S.Ct.
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What is the most suitable continuation to the opinion? Your options are:
A. holding that the interrogation must cease once the suspect invokes his miranda right to counsel
B. holding that interrogation must cease if the suspect unambiguously asserts his right to counsel
C. holding that the right to have counsel present means the right to have counsel physically present during the interrogation not merely the right to consult an attorney by telephone
D. holding that once the right to counsel is invoked custodial interrogation must cease until the suspects attorney is present
E. holding that when an accused has invoked his right to have counsel present during custodial interrogation a valid waiver of that right cannot be established by showing only that he responded to further policeinitiated custodial interrogation even if he has been advised of his rights an accused  having expressed his desire to deal with the police only through counsel is not subject to further interrogation by the authorities until counsel has been made available to him unless the accused himself initiates further communication exchanges or conversations with the police
Reply with [A, B, C, D, E] only.