Read the following excerpt from a US court opinion:
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157 F.Supp.2d 1345, 1354-55 (S.D.Fla.2001). Although the Sinaltrainal court interpreted a claim of failure to exhaust as a chal lenge to subject matter jurisdiction, 256 F.Supp.2d at 1357, other district courts have treated the same claim as non-jurisdictional. See Abiola, 267 F.Supp.2d at 910 (finding that the TVPA “is not a jurisdictional statute, such that failure to comply with its requirements strips the Court of jurisdiction” and that the TVPA’s exhaustion requirement did not apply to claims raised under the ATCA); Mehinovic v. Vuckovic, 198 F.Supp.2d 1322, 1347 n. 30 (N.D.Ga.2002) (noting that the burden is on defendant to raise non-exhaustion and defendant in that case had not met the burden); Wiwa v. Royal Dutch Petroleum Co., et al., 2002 WL 319887, at *17 (S.D.N.Y.2002) ; Cabiri v. Assasie-Gyimah, 921 F.Supp. 1189,
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What is the most suitable continuation to the opinion? Your options are:
A. holding that administrative remedies must be exhausted prior to filing a claim in court
B. holding that if adequate administrative remedies are available it is improper to seek relief in court before those remedies are exhausted
C. holding that the prisoner has the burden of demonstrating he has exhausted his administrative remedies in his complaint
D. holding that defendant raising exhaustion defense did not meet initial burden of demonstrating that plaintiffs had not exhausted alternative and adequate remedies in nigeria
E. recognizing that issue exhaustion requirement and requirement exhaustion of remedies are different
Reply with [A, B, C, D, E] only.