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The Supreme Court of the United States (SCOTUS) has never provided a ubiquitous one-line definition for what constitutes a critical stage during a prosecution necessitating

The Supreme Court of the United States (SCOTUS) has never provided a ubiquitous one-line definition for what constitutes a "critical stage" during a prosecution necessitating the presence of counsel. However, it has described a "critical stage" in numerous ways depending on the circumstances of a case. Which of the following descriptions has not been used by SCOTUS to describe a "critical stage."

A) Counsel's assistance is guaranteed "whenever necessary to mount a meaningful defense."

B) A critical stage presents a moment when "available defenses may be irretrievably lost, if not then and there asserted."

C) "A critical stage holds significant consequences for the accused."

D) A critical stage "is any pre-trial hearing that presents minimal risk that counsel's absence might derogate from a defendant's right to a fair trial." 

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