Russell co-owns a house with three of his friends.They have structured their ownership of the property as a joint tenancy. Over time, Russell grows tired of the fact that his friends make a lot of noise late into the night, because he works construction and has to get up at 4 AM. Which of the following isnota way that Russell could sever the joint tenancy?

A.By Russell's creditors bringing an application to sever the joint tenancy so that Russell's shareof the property can be sold to pay his outstanding debts.

B.By obtaining a court order forthe partition and sale of the land.

C.By ending theunity of tenancy.

D.By deciding to sell his interest in the property to another friend.