With no explanation, chose the best option from "A", "B", "C" or "D". Many other courts have required a PRP-plaintiff to show a § 107(b) defense in order to maintain a cost recovery action but have done so without specifically rejecting Rumpke. See, e.g., New Castle, 111 F.3d at 1124 (acknowledging, without adopting, that a party entitled to a defense under § 107(b) may bring a § 107(a) action against other PRPs); Advanced Technology Corp. v. Eliskim, Inc., 87 F.Supp.2d 780, 784 (N.D.Ohio 2000); M & M Realty Co. v. Eberton Terminal Corp., 977 F.Supp. 683, 686 (M.D.Pa.1997) (“We conclude that, under the circumstances alleged in this case, if M & M can establish that it is an innocent landowner under Section 107(b)(3), it will be entitled to bring a cost recovery action.”); Sinclair Oil Corp. v. Dymon, Inc., 988 F.Supp. 1394, 1396 n. 1 (D.Kan.1997) (<HOLDING>). In urging the court to recognize an exception

A: recognizing a prpplaintiffs right to cost recovery if a  107b3 defense is available
B: recognizing a criminal defendants right to present a complete defense
C: holding that the avoidance powers provide for recovery only if the recovery is for the benefit of the estate
D: holding that there is no right of recovery against individual defendants under the ada
A.