With no explanation, chose the best option from "A", "B", "C" or "D". 941, 944 (1937); Meunier v. Bernich, 170 So. 567, 572 (La.Ct.App.1936); Fitchette v. Taylor, 191 Minn. 582, 254 N.W. 910, 911 (1934); Akron Bar Ass’n v. Bojonell, 88 Ohio St.3d 154, 724 N.E.2d 401, 402 (2000); Cincinnati Bar Ass’n v. Cromwell, 82 Ohio St.3d 255, 695 N.E.2d 243, 244 (1998); Mazzacaro, 351 A.2d at 234; Brown v. Unauthorized Practice of Law Comm., 742 S.W.2d 34, 42 (Tex.Ct.App.1987); accord 16 John A. Appleman and Jean Appleman, Insurance Law and Practice § 8649, at 137 (1981) (“generally the courts have held that if a lay adjuster attempts to handle claims on behalf of plaintiffs, or to effect settlements for them, even though litigation is not required, such amounts to the practice of law”); cf. Unauthorized Practice of Law Comm. v. Jansen, 816 S.W.2d 813, 814-16 (1991) (<HOLDING>). The reasoning of these courts is helpful in

A: holding that legal injury occurred for purposes of negligence action against insurance agent when insurance company rejected the claim
B: holding that the proceeds of a liability insurance policy were not property of the estate
C: holding claims for negligent procurement of insurance accrued on date the insured purchased the insurance policies
D: holding that public insurance adjusters were not engaged in the practice of law when they merely documented and presented firstparty claims for property damage to insurance compa nies even though they discussed the competing valuations with the inhouse insurance adjuster the court distinguished these activities from the evaluation and presentation of personal injury claims and from the negotiation of settlements
D.