Arizona General Appearance In Court
In-state service on a party who has not made a general appearance is governed by Ariz. R. Civ. P. 4.1 or ARFLP 41, depending on the date of service.
This is true even when personal jurisdiction has already been established by service of the original petition or complaint and summons. See 4B Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure 1146 (3d ed. 2002) ("The service of papers provisions of federal civil Rule 5 apply only to parties who have appeared. Thus it is clear that amended or supplemental pleadings must be served on parties who have not yet appeared in the federal court action in conformity with federal civil Rule 4.").
The rules governing service differ significantly depending on whether a party to be served has made an "appearance." Compare Ariz. R. Civ. P. 4 and ARFLP 41 with Ariz. R. Civ. P. 5(c) and ARFLP 43(C).
In Arizona, an "appearance" for purposes of the rules is synonymous with a "general appearance." See Burton, 205 Ariz. at 29, P 8, 66 P.3d at 72 (using the terms interchangeably).
A party has made a general appearance when he has taken any action, other than objecting to personal jurisdiction, that recognizes the case is pending in court. Id.; Tarr, 142 Ariz. at 351, 690 P.2d at 70; Austin, 10 Ariz. App. at 477, 459 P.2d at 756.
See also Skates, 140 Ariz. at 507, 683 P.2d at 306 (finding that the defendant's informal letter requesting a stay was a general appearance because it requested affirmative relief).