With no explanation, chose the best option from "A", "B", "C" or "D". City maintains that each transfer is exempt from the preference rule under § 547(c)(8). Hailes argues that the transfer in this case was the writ of garnishment; therefore, the aggregate value of the transfer should be measured by the sum of all of the payments. Under Hailes’ theory, the aggregate value of the transfer exceeded $600, and § 547(e)(8) would not exempt the garnished proceeds from the preference rule. Therefore, the sole issue on appeal is whether, under § 547(c)(8), a court may aggregate all transfers to a single creditor to determine whether the creditor received $600 in value in the pre-filing period or whether each transfer must be evaluated individually. The issue has divided the few courts that have considered it. Compare In re Djerf, 188 B.R. 586, 588 (D.Minn.1995) (<HOLDING>); In re Alarcon, 186 B.R. 135 (D.N.M.1995)

A: recognizing need to balance interests of debt or and creditor in determining nature of protection to be afforded creditor
B: holding that as a general rule  affirmative action by the creditor must be taken to make it known to the debtor that the creditor has exercised his option to accelerate
C: holding that debtor can aggregate multiple transfers to a single creditor in ninetyday prefiling period to meet  547c8s 600 requirement
D: holding that a bankruptcy court can order rejection retroactive to an earlier date to avoid penalizing the debtor for an unnecessary delay caused by the creditor
C.