With no explanation, chose the best option from "A", "B", "C" or "D". showing only that he responded to further police-initiated custodial interrogation even if he has been advised of his rights_[Rather,] an accused, ... having expressed his desire to deal with the police only through counsel, is not subject to further interrogation by the authorities until counsel has been made available to him, unless the accused himself initiates further communication, exchanges, or conversations with the police. Id. at 484-85, 101 S.Ct. at 1884-85; see also Minnick v. Mississippi 498 U.S. 146, 153, 111 S.Ct. 486, 491, 112 L.Ed.2d 489 (1990) (stating “that when counsel is requested, interrogation must cease, and officials may not reinitiate interrogation without counsel present, whether or not the accused has consulted with his attorney”); Savino, 82 F.3d at 599-600 (<HOLDING>). Polk, to whom Howard initially confessed, did

A: recognizing that not all statements obtained by the police after a person has been taken into custody are to be considered the product of interrogation
B: holding that any confession obtained by interrogation reinitiated by police in the absence of counsel is inadmissible unless the defendant reinitiates discussion with police and then confesses
C: holding in a plurality opinion that a confession obtained through a twostep questions first interrogation technique whereby the police deliberately questioned a defendant in custody until that defendant confessed followed by a miranda warning and reiteration of the confession was inadmissible because the police strategy undermined the effectiveness of the miranda warning
D: holding that witness statements in police report inadmissible
B.