Read the following excerpt from a US court opinion:
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Digital Technologies Corp., 306 B.R. 505, 509 (Bankr.D.Del.2004) ("In fact an overwhelming majority of courts have concluded that liability insurance policies fall within § 541(a)(l)’s definition of estate property.”) (internal quotations omitted) (citing In re Matter of Vitek, Inc., 51 F.3d 530, 533 (5th Cir.1995)). 30 . In re Allied Digital, 306 B.R. at 509; see In re SN Liquidation, 388 B.R. at 584 ("Who owns the proceeds of an insurance policy presents a more complicated issue and requires a more careful analysis.”); In re CyberMedica, Inc., 280 B.R. 12, 16 (Bankr.D.Mass.2002) (observing that "courts are in disagreement on whether or not insurance proceeds are property of the estate.”) (emphasis in original); e.g., In re Adelphia Communications Corp., 298 B.R. 49 (S.D.N.Y.2003) ; In re First Central Financial Corp., 238 B.R.
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What is the most suitable continuation to the opinion? Your options are:
A. holding that where the policy names only the directors or officers as insured the proceeds are not property of the estate
B. holding the real estate sale proceeds
C. holding directors and officers liability policy was not property of the estate because it did not increase or decrease the worth of the bankruptcy estate
D. holding that because proceeds of a letter of credit were not secured by estate collateral the proceeds were not property of the estate
E. holding that the proceeds of a liability insurance policy were not property of the estate
Reply with [A, B, C, D, E] only.