Read the following excerpt from a US court opinion:
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523.1 0[ I ][c], 523-71 (15th ed. rev.Mar. 1997). It is the Plaintiffs burden to show by a preponderance of the evidence that the dischargeability exception is warranted. Grogan v. Garner, 498 U.S. 279, 291, 111 S.Ct. 654, 661, 112 L.Ed.2d 755 (1991). The Sixth Circuit Court of Appeals has recently addressed the nondischargeability provision under § 523(a)(4) for debts arising from defal (Bankr.M.D.Fla.1997) (noting that the traditional meaning of the term fiduciary is far too broad for bankruptcy purposes.); Ducey v. Doherty (In re Ducey), 160 B.R. 465, 469 (Bankr.D.N.H.1993) (noting that the term fiduciary in § 523(a)(4) is narrower in scope than the word as traditionally used under sate law); Hartwood Aviation, Inc. v. Hamilton (In re Hamilton), 147 B.R. 779, 783 (Bankr.D.Col.1992) . Fowler Bros., 91 F.3d at 1371 (holding that
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What is the most suitable continuation to the opinion? Your options are:
A. holding that an attorney is a fiduciary under section 523a4
B. holding a duty of care without more insufficient to satisfy the fiduciary relationship element of  523a4 the federal courts adopting this narrow interpretation of fiduciary for purposes of the bankruptcy code gen erally hold that an express or technical trust is necessary to trigger the defalcation provision of  523a4
C. holding that the fraud or defalcation prong of  523a4 requires the showing of an express trust
D. holding that a statutorilyimposed fiduciary obligation created an express trust fiduciary relationship for purposes of  523a4
E. holding general fiduciary duties of confidence trust loyalty and good faith insufficient to establish the necessary fiduciary relationship for purposes of  523a4
Reply with [A, B, C, D, E] only.