With no explanation, chose the best option from "A", "B", "C" or "D". insufficiency of service of process because Curenton’s July 2009 notice of appearance in the action and Allen’s filing of his pro se claim for exemption from garnishment in 2011 each amounted to a general appearance by Allen and, thus, both filings waived Allen’s argument regarding insufficiency of service of process. See Kingvision Pay-Per-View, Ltd. v. Ayers, 886 So.2d 45, 53 (Ala.2003) (quoting Lonning v. Lonning, 199 N.W.2d 60, 62 (Iowa 1972)) (explaining that a general appearance waives objections regarding personal jurisdiction and insufficiency of service of process and that “‘[a] general appearance is a waiver of notice and if a party appears in person or by attorney he submits himself to the jurisdiction of the court’”); Simmons v. Simmons, 99 So.3d 316, 320 (Ala.Civ.App.2011) (<HOLDING>); Klaeser v. Milton, 47 So.3d 817, 821

A: holding an attorney is an agent of the client and therefore cannot conspire with the client
B: holding that an attorneys filing a notice of appearance on behalf of his or her client constitute a waiver of service of process by the client
C: holding trial court erred when it sanctioned client where the evidence showed that the attorney filed frivolous pleadings on behalf of the client but the client did nothing more than rely on her attorneys advice
D: holding that an attorney may only undertake to represent a new client against a former client  where there is no confidential information received from the former client that is in any way relevant to representation of the current client
B.