Read the following excerpt from a US court opinion:
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two fundamental reasons. First, appellant’s reliance on the fact that she was convicted of murder under a theory of accomplice liability is misplaced in this context. As we implicitly held in Ramsey, in determining whether Wharton’s Rule applies to a substantive offense the conviction of which is based on accomplice liability, the focus must be on the underlying criminal act of the particular substantive offense rather than on the accomplice aspect of the offense. 2 Va.App. at 272, 343 S.E.2d at 470. The accompliceship itself is not the completed criminal act upon which the conviction is based but simply the means by which criminal responsibility for the completed criminal act is incurred under Code § 18.2-18. See Snyder v. Commonwealth, 202 Va. 1009, 1017, 121 S.E.2d 452, 458 (1961) . Thus, the accomplice aspect of the
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What is the most suitable continuation to the opinion? Your options are:
A. holding that a statute imposing a one dollar court cost for law enforcement on every person convicted of a crime was not a violation of the separation of powers doctrine because it is reasonable that one convicted of a crime should be made to share in the improvement of agencies that society has had to employ in defense against the very acts for which he has been convicted
B. holding the crime of conspiracy is committed or not before the substantive crime begins
C. holding that code  18218 directs that an accessory before the fact is accountable in all respects as the principal who carries out the intended crime as well as any of its natural probable and incidental crimes
D. holding that before the accessory to a crime can be convicted as such it must be shown that the crime has been committed by the principal
E. holding punishment must be proportional to the crime convicted
Reply with [A, B, C, D, E] only.