With no explanation, chose the best option from "A", "B", "C" or "D". raising the continuity of counsel claim at trial. 11 . In Coleman, the Supreme Court held that ineffective assistance of state postconviction counsel could not supply cause to overcome a procedural default, reasoning that because there is no right to counsel at that stage, counsel's deficient performance would not amount to a violation of a petitioner's Sixth Amendment right to counsel and, therefore, could not be seen as an objective factor external to the defense. 501 U.S. at 752-57, 111 S.Ct. 2546. That holding was modified by Martinez, in which the Supreme Court held that ineffective assistance of state postconviction counsel can in some circumstances supply cause to excuse a procedural default. 132 S.Ct. at 1315. 12 . See also Manning v. Foster, 224 F.3d 1129, 1134 (9th Cir. 2000) (<HOLDING>); cf. United States v. Taglia, 922 F.2d 413,

A: recognizing conflict
B: holding the burden of proving that a conflict of interest rises to the level of ineffective assistance rests on the one asserting the conflict
C: holding that a conflict of interest independent of a claim of ineffective assistance of counsel  constitute cause where the conflict caused the attorney to interfere with the petitioners right to pursue his  1 claim
D: recognizing the conflict
C.