With no explanation, chose the best option from "A", "B", "C" or "D". So.3d at 1114-15. On March 21, 2012, the mother’s appointed counsel filed a notice of appearance. In Simmons v. Simmons, 99 So.3d 316, 320 (Ala.Civ.App.2011), this court held that “[an attorney’s] filing a notice of appearance on behalf of [his or her client] constitute[s] a waiver of service of process by [the client].” On March 28, 2012, the mother’s counsel attempted to “amend” the notice of appearance to disavow any waiver of service of process, but a notice of appearance is not a “pleading,” see Rule 7(a), Ala. R. Civ. P., to which the exception to waiver of the defense of insufficiency of service of process outlined in Rule 12(h)(1), Ala. R. Civ. P., for “amended pleadings” is applicable. Cf. D.M.T.J.W.D. v. Lee Cnty. Dep’t of Human Res., 109 So.3d 1133, 1140 (Ala.Civ.App.2012) (<HOLDING>). Finally, even assuming that counsel’s notice

A: holding that plaintiffs motion to amend her complaint to add her husband as a defendant did not relate back because her failure to sue her husband was not due to misnomer or mistake involving the identity of the proper party but because the law at the time of the complaint did not allow one spouse to sue another in tort
B: holding that mother did not waive the defense of lack of personal jurisdiction by failing to raise it in her first responsive pleading ie her answer to dhrs  petition to terminate her parental rights because the mother sought leave to amend her answer to include the defense of lack of personal jurisdiction  dhr did not object to that motion and  the juvenile court allowed the mother to amend her answer
C: holding mothers due process rights were not violated when her appointed counsel was allowed to withdraw and hearing was held without mother because the record showed mother did not inform counsel of her whereabouts after moving thereby frustrating counsels efforts to contact her and because mother was properly served with notice of the termination hearing
D: holding a mother on appeal must successfully challenge a trial courts finding that there was no substantial and continuing change of circumstances of the children or mother before she can succeed on her claim that the trial court erred in overruling her motion to modify custody
B.