Read the following excerpt from a US court opinion:
```
After reviewing the transcript of the suppression hearing, we conclude that the record amply supports the district court’s finding that this encounter between Cunningham and the officers was a consensual police-citizen encounter that does not trigger Fourth Amendment scrutiny. See id. at 310 (listing factors appropriate for consideration in reviewing whether a seizure has occurred). Cunningham also challenges the district court’s finding that he voluntarily consented to the search of the vehicle. We conclude, however, that the facts of the encounter between Cunningham and the officers confirm that Cunningham consented to the search of the vehicle and that such consent was voluntarily given. See Schneckloth v. Bustamonte, 412 U.S. 218, 219, 227, 93 S.Ct. 2041, 36 L.Ed.2d 854 (1973) ; United States v. Lattimore, 87 F.3d 647, 650
```
What is the most suitable continuation to the opinion? Your options are:
A. holding that in determining the voluntariness of a waiver of miranda rights a court must evaluate the totality of the circumstances
B. holding threat to obtain a search warrant if individual does not consent to a search is just one factor in deciding whether the totality of the circumstances supports a voluntary consent finding
C. holding that the government bears the burden of proving voluntary consent under the totality of the circumstances
D. recognizing that the ultimate question of the voluntariness of consent is one of law
E. recognizing that consent is an exception to the warrant requirement and that voluntariness of consent depends on the totality of the circumstances
Reply with [A, B, C, D, E] only.