Read the following excerpt from a US court opinion:
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in question required no ‘distinctive knowledge’ or ‘specialized skill.’ ” Thangaraja, 428 F.3d at 876. Ramon-Sepulveda, the sole case on which the government relies, noted that plaintiffs “legal claim against the INS involved established principles of res judicata-principles with which the majority of attorneys are, or should be, familiar. Additionally, there is no shortage of attorneys in Los Angeles qualified to assist aliens in deportation proceedings.” Ramon-Sepulveda, 863 F.2d at 1463. See Thangaraja, 428 F.3d at 876 (declining to apply an upward adjustment for representation of an alien in connection with the review of a Board of Immigration Appeals decision regarding applications for asylum and withholding of removal); Ruedar-Menicucci v. I.N.S., 132 F.3d 493, 496 (9th Cir.1997) ; see also Johnson v. Gonzales, 416 F.3d 205,
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What is the most suitable continuation to the opinion? Your options are:
A. holding that no specialized skill or distinctive knowledge was needed to represent an alien at asylum and withholding of deportation hearings
B. holding that the standard of care applicable to a reasonable pharmaceutical company marketing product after minimum testing and without a warning does not entail specialized knowledge or skill unique to a scientific discipline and beyond the knowledge and experience of the average jury
C. recognizing that withholding of removal claims must fail if petitioner is unable to show the objective likelihood of persecution needed to make out an asylum claim and the claims are based on the same factual predicate
D. holding that the clear probability standard applies in withholding of deportation actions
E. holding that to qualify for a special factor increase the attorney must have some distinctive knowledge or specialized skill needful for the litigation in question  
Reply with [A, B, C, D, E] only.