With no explanation, chose the best option from "A", "B", "C" or "D". J.S.’s pending motion for sanctions or otherwise indicate that the order was intended to be a final order. Accordingly, neither the nonsuit nor the trial court’s dismissal order disposed of J.S.’s motion for sanctions. See Tex. R. Civ. P. 162; Unifund CCR Partners v. Villa, 299 S.W.3d 92, 96-97 (Tex.2009) (per curiam); Crites v. Collins, 284 S.W.3d 839, 840-41 (Tex.2009) (per curiam). Likewise, the severance order did not address or affect J.S.’s sanctions motion. The order addressed only the severance of appellants’ causes of action for alleged tortious interference with contract and extortion asserted against J.S.; therefore, J.S.’s motion for sanctions remained pending before the trial court in this case. See Mantri v. Bergman, 153 S.W.3d 715, 718 (Tex.App.-Dallas 2005, pet. denied) (<HOLDING>). Finally, the Texas Supreme Court has

A: holding that the defendant did not waive his special appearanee by filing a motion for sanctions that was made subject to and in the alternative to his special appearance and where the motion for sanctions was not heard or ruled upon
B: holding that trial court must issue order to show cause which initiates a separate proceeding independent of the rule 8800 action before imposing sanctions
C: holding that motion for sanctions was not an independent cause of action and should be decided by trial court where frivolous pleading is pending
D: holding that a motion for rule 11 sanctions is dispositive
C.