Read the following excerpt from a US court opinion:
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The generic offense does not necessarily require, however, one of the specific purposes identified by the MPC. Instead, the generic offense of kidnapping requires restraint plus the presence of some aggravating factor, such as circumstances that create a risk of physical harm to the victim, or movement of the victim from one place to another. See De Jesus Ventura, 565 F.3d at 877-78 (“The most common approach defines kidnapping to include a particular nefarious purpose. And the majority approach requires some kind of heightened intent beyond the mere intent to restrain the victim’s liberty. Most critically, a substantial majority of jurisdictions ... require some additional element of intent or severity.”). See also United States v. Moreno-Florean, 542 F.3d 445, 454 (5th Cir.2008) . The Michigan statute at issue in this case
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What is the most suitable continuation to the opinion? Your options are:
A. holding that a conviction under a texas robbery statute qualifies as generic robbery be cause its elements substantially correspond to the basic elements of the generic offense in that they both involve theft and immediate danger to a person
B. holding force to be an element of pre1994 amendment  111 which may be satisfied by proof of force or threat of force
C. holding that the enhancement requires that the defendant either threaten the codefendant witness or juror in his or her presence or issue the threat in circumstances in which there is some likelihood that the codefendant witness or juror will learn of the threat
D. holding that under  521 the coercive force applied against a plaintiff must result in an interference with a separate constitutional or statutory right and it is not sufficient that the right interfered with is the right to be free of the force or threat of force that was applied
E. holding that in addition to 1 knowing removal and confinement and 2 force threat or fraud the generic contemporary offense of kidnapping requires the specified purposes identified in the mpc or additional aggravating elements
Reply with [A, B, C, D, E] only.