Read the following excerpt from a US court opinion:
```
99 S.Ct. at 1757. Here, defendant’s silence and his participation in the debriefing sessions did not constitute waiver. More than a failure to request counsel and subsequent conversations with the prosecutor pursuant to a cooperation agreement are required to find waiver in the debriefing context. For purposes of clarity, it is helpful to explain precisely what is required. Defendant and his counsel should be given reasonable notice of the time and place of the scheduled debriefing so that counsel might be present. A cooperating witness’s failure to be accompanied by counsel at debriefing may later be construed as a waiver, providing defendant and counsel have had notice so that the consequences of counsel’s failure to attend could be explained to defendant. Cf. Auen, 864 F.2d at 5 ; United States v. Weninger, 624 F.2d 163, 167
```
What is the most suitable continuation to the opinion? Your options are:
A. recognizing that a criminal defendants right to counsel is the right to the effective assistance of counsel
B. holding that an ijs failure to obtain a knowing and voluntary waiver of the right to counsel from a pro se petitioner is a due process violation
C. holding that defendants waiver of counsel when pleading guilty was an implied waiver as to any subsequent proceedings including sentencing four days later
D. holding that defendants failure to obtain counsel despite opportunities to do so implied a waiver of counsel
E. holding that in order for a waiver of counsel to be valid the trial court must ensure that the defendants waiver of his right to counsel is done knowingly and intelligently so that the record establishes that the defendants choice is made with eyes open
Reply with [A, B, C, D, E] only.