When the motion is denied, Dana files an answer denying negligence, alleging affirmative defense of assumption of risk and asserting lack of personal jurisdiction. Dana files a motion for extension of time for answering which is granted. Later, before answering, Dana files motion to dismiss for lack of personal jurisdiction. Dana fails to file a motion for extension of time for answering. Dana files a motion to dismiss for lack of personal jurisdiction but does not include a motion to dismiss or quash for insufficiency of service of process.
Client thinks there is no personal jurisdiction.
Client was served pursuant to state long arm which permits service by mail. C Charlie Brown is sued in California state court. He appears specially to challenge personal jurisdiction. The court holds that it has personal jurisdiction. Charlie Brown is convinced the court is wrong and does not appear for the trial.