Read the following excerpt from a US court opinion:
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a party from prosecuting two actions for the same cause and against the same party, is tantamount to making the defendant with a compulsory counterclaim in the first action a ‘plaintiff in that action (for purposes of § 6-5-440) as of the time of its commencement. See, e.g., Ex parte Parsons & Whittemore Alabama Pine Constr. Corp., 658 So.2d 414 (Ala.1995); Penick v. Cado Systems of Cent. Alabama, Inc., 628 So.2d 598 (Ala.1993); Ex parte Canal Ins. Co., 534 So.2d 582 (Ala.1988). Thus, the defendant subject to the counterclaim rule who commences another action has violated the prohibition in § 6-5-440 against maintaining two actions for the same cause.” Ex parte Breman Lake View Resort, L.P., 729 So.2d 849, 851 (Ala.1999). See also University of South Alabama Found., 788 So.2d at 165 ; Ex parte Parsons & Whittemore Alabama Pine
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What is the most suitable continuation to the opinion? Your options are:
A. holding that the federal claims which arose from state court criminal contempt proceedings were inextricably intertwined with the state court action and thus the federal district court lacked subject matter jurisdiction over the claims pursuant to the rookerfeldman doctrine
B. holding that the prosecution in a subsequent action of claims that had been compulsory counterclaims in a previously filed declaratoryjudgment action violated  65440
C. holding that district court did not abuse its discretion in considering merits of state law counterclaim that formed part of the same case as federal counterclaim even though court had dismissed federal counterclaim quoting 28 usc  1367a
D. holding that federal district court had subject matter jurisdiction to hear case notwithstanding rookerfeldman doctrine where plaintiff filed federal suit while certiorari petition to new mexico supreme court was pending in similar state court action
E. holding that a party in an action pending in a federal court was subject to the counterclaim rule and thus violated  65440 by commencing another action in a state court
Reply with [A, B, C, D, E] only.