With no explanation, chose the best option from "A", "B", "C" or "D". 8 OES 136.643 provides, in relevant part: “In the trial of * * * a person accused or charged with the commission of a crime, the person so charged or accused shall, at the own request of the person, but not otherwise, be deemed a competent witness!.] * * * The defendant or accused, when offering testimony as a witness in the own behalf of the defendant, gives the prosecution a right to cross-examination upon all facts to which the defendant or accused has testified and which tend to the conviction or acquittal of the defendant or accused.” 9 In Lotches, the court noted that, in addition to the federal constitution, Article I, section 11, of the Oregon Constitution gives criminal defendants a right to testify in their own behalf. 331 Or at 483 n 10. But see Rogers, 330 Or at 298-99 (<HOLDING>). 10 State v. Mai, 294 Or 269, 656 P2d 315

A: recognizing that criminal defendants right to testify is subject to crossexamination
B: holding violation of right to testify could not be harmless
C: holding that right to be heard in article i section 11 incorporates framers contemporaneous understanding which did not recognize criminal defendants right to testify
D: recognizing that a defendants right to be heard in criminal proceedings prior to sentencing is constitutionally protected
C.