Read the following excerpt from a US court opinion:
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The relevant question at the motion-to-dismiss stage is not whether Plaintiffs have alleged an exact sum of money in their complaint. Indeed, the case primarily relied upon by Defendants shows that alleging an exact sum of money is not itself enough to support a conversion claim. See, e.g., High View Fund, L.P. v. Hall, 27 F.Supp.2d 420, 429 (S.D.N.Y. 1998) (dismissing conversion claim seeking $1 million because “plaintiffs do not claim ownership of a specifically identifiable, segregated $1 million” (internal quotation marks, alteration, and citation omitted)). Rather, the question is whether the money alleged to have been converted is specifically “identifiable” or, put another way, whether it is capable of “being desc l & Vaccaro, 187 A.D.2d 384, 385, 590 N.Y.S.2d 201 (1992) ; Brennan’s Bus Serv., Inc. v. Brennan, 107
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What is the most suitable continuation to the opinion? Your options are:
A. holding that notwithstanding the chapter 7 trustees postpetition settlement of state court litigation attorney had a valid charging lien in settlement proceeds for the attorneys prepetition services where services were beneficial to the estate
B. holding that contract debt  was not subject to an act in tort for conversion
C. holding that proceeds of a litigation settlement were an identifiable fund and thus a proper subject of a misappropriation and conversion claim
D. holding that the entirety of litigation settlement proceeds was taxable income to client not net after payment of attorney fees
E. holding that defendant was entitled to summary judgment on conversion claim because the claim seeks merely to recover an allegedly unpaid debt and does not seek to recover money from a discrete identifiable fund
Reply with [A, B, C, D, E] only.