Read the following excerpt from a US court opinion:
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findings. Furthermore, although Jin’s brief identifies the requirements for raising an ineffective assistance of counsel claim, as described in In re Lozada, 19 I. & N. Dec. 637 (BIA 1988), there is no assertion or evidence suggesting that Jin complied with these requirements. Jin has also failed to show any error in the agency’s determination that she did not prove past persecution or a probability of future harm as required for withholding of removal or CAT relief. The record establishes that Jin assisted a North Korean refugee, was detained for 15 days, and fined 4,000 RMB. At no time was Jin physically harmed or threatened by authorities. These allegations are insufficient to establish past persecution. See Jian Qiu Liu v. Holder, 632 F.3d 820, 822 (2d Cir.2011) (per curiam) ; Ivanishvili v. U.S. DOJ, 433 F.3d 332, 341
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What is the most suitable continuation to the opinion? Your options are:
A. holding that where no factual dispute is raised no hearing is required
B. holding that plaintiff had no claim under fmla because she had suffered no diminution in income and incurred no costs as a result of alleged violation
C. holding that petitioner had established persecution even though he had not been physically harmed and received only an indirect threat relayed by a neighbor
D. holding that plaintiff had no standing because he had no intention of seeking further medical advice or treatment from defendant
E. holding that petitioner failed to establish persecution where he suffered only minor bruising from an altercation with family planning officials which required no formal medical attention and had no lasting physical effect
Reply with [A, B, C, D, E] only.