With no explanation, chose the best option from "A", "B", "C" or "D". 592 (1976), rev’g United States v. Fink, 502 F.2d 1 (5th Cir. 1974). In Geders the Court held that a criminal defendant’s Sixth Amendment right to counsel was denied by a district court order barring consultation between the defendant and his attorney during an overnight recess that fell between the direct examination and the cross-examination of the defendant. The Court, however, expressly noted that it was not considering an order that merely barred a defendant from consulting his attorney during a brief routine recess during the trial day. Geders, supra, 425 U.S. at 89 n. 2, 96 S.Ct. at 1336 n. 2. Nevertheless, a number of Circuits have either adopted or expressed approval of the extension of Geders to short, mid-day recesses. United States v. Bryant, 545 F.2d 1035 (6th Cir. 1976) (<HOLDING>); United States v. Allen, 542 F.2d 630 (4th

A: holding that a criminal defendant has a sixth amendment right to counsel at trial
B: holding an order directing defendant not to converse with anyone during an hour lunch break violative of the sixth amendment right to counsel
C: holding that the fourteenth amendment incorporated the sixth amendment right to counsel
D: holding that the sixth amendment right to counsel embodies the right to effective assistance of counsel
B.