In Peterson v. Spartan Industries, 33 NY2d 463, 466, 310 N.E.2d 513, 354 NYS2d 905 [1974] the Court of Appeals considered the challenges faced by Plaintiffs opposing 3211(a)(B) motions. Acknowledging that in these cases the facts necessary to defeat such a motion are likely to be controlled by the party opposing jurisdiction, the Court of Appeals ruled that where the opposing party can "demonstrate that facts 'may exist' whereby to defeat the motion," the court should order a continuance pursuant to 3211(d) and allow the opposing party to conduct discovery. The Court found discovery appropriate where the "plaintiffs [had] made a sufficient start and shown their position not to be frivolous." The Second Department continues to apply the Peterson rule holding that "in opposing a motion to dismiss pursuant to CPRL 3211 (a) (8) on the ground that discovery on the issue of personal jurisdiction is necessary... The plaintiffs need only demonstrate that facts may exist to exercise personal jurisdiction over the defendant" (Castillo v. Star Leasing Co., 69 A.D.3d 551, 893 N.Y.S.2d 123, 2010 NY Slip Op 90. See, also, Ying Jun Chen v. Lei Shi, 19 AD3d 407, 796 NYS2d 126 [2nd Dept., 2005]).