Read the following excerpt from a US court opinion:
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invocation of his right to counsel was certainly unfortunate, it does not merit habe-as relief. I will deny Pursell’s claims under the Fifth, Sixth, and Fourteenth Amendments, and deny him a certificate of appealability on these claims. 28 U.S.C. § 2253(c). (b) Testimony About Pursell’s Prior Criminal Record and Counsel’s Withdrawal of Motion for Mistrial Pursell’s second claim concerning Krahe’s testimony focuses on Krahe’s statement that Pursell had a prior criminal record. When asked by the court for the name of Pursell’s lawyer, Krahe said the following: “He said Gary Skiba. ‘He got me out of jail before.’ ” (Tr. 1/21/82, at 121). Pursell’s counsel objected to this statement and moved for mistrial. He later withdrew that motion when the governmen .Ct. 1880, 68 L.Ed.2d 378 (1981) . The Commonwealth concedes the inadmissibility
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What is the most suitable continuation to the opinion? Your options are:
A. holding that defendants statements not admissible once he had invoked right to counsel without proof of waiver
B. holding that a defendants statements regarding offenses for which he had not been charged were admissible notwithstanding the attachment of his sixth amendment right to counsel on other charged offenses
C. 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
D. holding that petitioners videotaped statement made after he invoked his right to counsel was wrongfully admitted at trial and not harmless error
E. recognizing that a criminal defendants right to counsel is the right to the effective assistance of counsel
Reply with [A, B, C, D, E] only.