With no explanation, chose the best option from "A", "B", "C" or "D". to disclose evidence in its possession favorable to the accused and material to guilt or punishment and stating that the trial court must inspect contested material to determine if it should be available to a defendant under a Brady request). 20 . See State v. Owens, 346 S.C. 637, 661, 552 S.E.2d 745, 758 (2001) ("The Sixth Amendment right to counsel attaches when adversarial judicial proceedings have been initiated and at all critical stages.”), overruled on other grounds by State v. Gentry, 363 S.C. 93, 610 S.E.2d 494 (2005); State v. Sprouse, 325 S.C. 275, 282, 478 S.E.2d 871, 875 (Ct.App.1996) (stating the focus of an investigation on a suspect who is not in custody does not trigger Miranda warnings). 21 . State v. Andrews, 324 S.C. 516, 519-21, 479 S.E.2d 808, 810-11 (Ct.App.1996) (<HOLDING>). 22 . See State v. Johnson, 334 S.C. 78, 93,

A: holding that called party in  227b1 means the person subscribing to the called number at the time the call is made and not the intended recipient of the call
B: holding that telephone call from debtors attorney did not constitute notice of bankruptcy filing because petition had not in fact been filed
C: holding statements on 911 tape admissible as present sense impression where call was made almost immediately after the defendant left the store after a shooting incident
D: holding a tape of a telephone call was admissible because one party to the call consented to the recording
D.