Read the following excerpt from a US court opinion:
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Commentary to ABA Defense Function Standard 4-8.2. See also United States v. Ruth, 768 F.Supp. 1428, 1435 (D.Kan.1991). For other cases where courts have applied the Flores-Ortega standard to privately retained counsel who informed their clients that they would not continue to represent them on appeal, see Raney v. State, 986 So.2d 468 (Ala.Crim.App.2007); Esters v. State, 894 So.2d 755 (Ala.Crim.App.2003); and Wallace v. State, 121 S.W.3d 652 (Tenn.2003); Cabinatan v. United States, unpublished, 2011 WL 255691, *5 (D.Haw.2011) (rejecting the contention that, because the defendant's trial attorney "was not retained or paid to prosecute an appeal, he therefore owed no duty to Cabinatan to file a notice of appeal."); Richardson v. United States, 612 F.Supp.2d 709, 715-16 (N.D.W.Va2009) ; Schaefer v. United States, unpublished, 2008
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What is the most suitable continuation to the opinion? Your options are:
A. holding the court lacked jurisdiction where the defendant failed to file a notice of appeal on the attorneys fee issue because a supplemental notice of appeal is required for us to have jurisdiction over an attorneys fees issue that becomes final subsequent to the initial notice of appeal
B. holding that equitable tolling of the time to file a notice of appeal is not permitted
C. holding that trial counsel owes a criminal defendant a duty to file a notice of appeal regardless of whether the attorney was retained for the appeal or not
D. recognizing that exception to requirement of timely filing of notice of appeal exists in cases where defendant either was not told of right to appeal or was not furnished attorney to exercise those rights or was furnished attorney for that purpose who failed to perfect and complete appeal
E. holding on appeal from a habeas corpus denial that counsel was not ineffective for failure to file a notice of appeal because of defendants escape
Reply with [A, B, C, D, E] only.