With no explanation, chose the best option from "A", "B", "C" or "D". requirements of-Daubert, see Williams v. Mast Biosurgery USA, Inc., 644 F.3d 1312, 1317-18 (11th Cir.2011), or to expert, disclosure requirements under rules of court. See Tampa Bay Shipbuilding & Repair Co., 320 F.3d at 1217-23; United States v. Tinoco, 304 F.3d 1088, 1119 (11th Cir.2002). .This is so because “[l]ay opinion testimony is admissible only to help the jury or the court to understand the facts about which the witness is testifying and not to provide specialized explanations or interpretations that an untrained layman could not make if perceiving the same acts or events.” United States v. Conn, 297 F.3d 548, 554 (7th Cir.2002) (quoting United States v. Peoples, 250 F.3d 630, 641 (8th Cir.2001)); see also Fed. R. Evid. 701, Advisory Committee Note to 2000 Amendments (<HOLDING>). However, courts must be vigilant to ensure

A: recognizing that independent analysis is  the only means by which the defendant can defend against expert testimony by the state 
B: recognizing that rule 701 as amended incorporates the distinction set forth in state v brown 836 sw2d 530 549 tenn1992 in which the court stated that lay testimony results from a process of reasoning familiar in everyday life whereas expert testimony results from a process of reasoning which can be mastered only by specialists in the field
C: holding that expert testimony is unnecessary where the case is not a case in which lay jurors would be unable to grasp the issues without expert assistance
D: holding that in a statutory fee case the results obtained factor was already subsumed in the lodestar and that results multipliers should be awarded only in some cases of exceptional success
B.