Read the following excerpt from a US court opinion:
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himself. To the extent VanHoesen sought new counsel because his third assigned attorney proposed to pursue an insanity defense, the request is properly reviewed in the context of defendant’s unwillingness to work with any of the three attorneys appointed for him. See United States v. Schmidt, 105 F.3d 82, 89 (2d Cir.1997) (rejecting defendant’s claim that “she was coerced into self-representation because the district court, on the eve of trial, refused to replace her third court-appointed attorney”). In sum, a court does not deprive a defendant of the Sixth Amendment right to counsel when it is the defendant himself who creates the conflicts that result in a breakdown of attorney-client communication. See generally Morris v. Slappy, 461 U.S. 1, 14, 103 S.Ct. 1610, 75 L.Ed.2d 610 (1983) . 3. Sufficiency of the Evidence Having failed
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What is the most suitable continuation to the opinion? Your options are:
A. holding that there is no due process right to appellate review
B. holding there is no meaningful distinction between due course and due process
C. recognizing that where there is no express attorneyclient relationship there may exist nevertheless a fiduciary obligation or an implied professional relation citations brackets and ellipsis omitted
D. holding that the information is not protected by attorneyclient privilege
E. holding that there is no right to a meaningful attorneyclient relationship
Reply with [A, B, C, D, E] only.