Read the following excerpt from a US court opinion:
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we conclude that the NTEU standard is inapplicable on these facts. 4 . Implicit in the Pickering test is a requirement that the public employer have taken some adverse employment action against the employee. See Koch v. City of Hutchinson, 847 F.2d 1436, 1440 (10th Cir.1988) (noting that Pickering and its progeny "establish the basic framework for analyzing a claim by a public employee that his or her governmental employer made an adverse employment decision in violation of the employee’s First Amendment rights” (emphasis added)). If the action taken by the employer in response to the employee's speech is inconsequential or has only speculative consequences, there can be no basis for a First Amendment claim. See, e.g., Thomsen v. Romeis, 198 F.3d 1022, 1027-28 (7th Cir.2000) . Defendants argue that the written reprimand
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What is the most suitable continuation to the opinion? Your options are:
A. holding that unsubstantiated oral reprimands do not constitute an adverse em ployment action absent evidence that they had some impact on the employees employment status
B. holding that written reprimands with only speculative consequences do not constitute adverse actions
C. holding not only that court had no obligation to predict consequences but also that court could not have predicted consequences
D. holding that poor evaluations alone do not constitute an adverse employment action
E. recognizing that a set of actions may constitute an adverse employment action when considered collectively even though some actions do not rise to the level of an adverse employment action individually
Reply with [A, B, C, D, E] only.