Read the following excerpt from a US court opinion:
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need not be treated as an •element required to be found by the jury suggests that the same fact need not be treated as an element that is required to be alleged in the charging instrument. See Harris, 536 U.S. at 568, 122 S.Ct. 2406 (stating that factor increasing a defendant’s minimum sentence “need not be alleged in the indictment, submitted to the jury, or proved beyond a reasonable doubt”). The symmetry between charging and fact finding suggested by Apprendi has not been universally embraced. Some courts have concluded that the notice guarantee of the Sixth Amendment may be satisfied with respect to a fact that is an element under Apprendi by means other than an allegation in the charging instrument. See, e.g., State v. Nichols, 201 Ariz. 234, 33 P.3d 1172, 1176 (Ariz.Ct.App.2001) . But other courts have followed the line of
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What is the most suitable continuation to the opinion? Your options are:
A. holding that notice to the attorney of record constitutes notice to the petitioner
B. holding that alien need not receive actual notice for due process requirements to be satisfied
C. holding that facts related to commission of offense necessary to establish eligibility for enhanced penalty of life imprisonment need not be alleged in the charging document provided that the notice of them given to the defendant comports with arizonas traditional notice requirements for alleging sentence enhancements
D. holding that the notice afforded by a document determines its sufficiency as a notice of appeal
E. holding that an indictment charging one offense during the commission of another crime need not allege the elements of the latter offense
Reply with [A, B, C, D, E] only.