Can a Letter to the Court Be Treated As An Answer If It Does Not Object to Its Jurisdiction ?

In New York, under CPLR 320 (b) a party may submit a defense on the merits together with an objection to jurisdiction. Under it a party may appear by the service of an answer "but that appearance does not confer personal jurisdiction if the answer raises an objection on that ground". Katz v. Katz, supra. In Katz, the Court held that it was unnecessary to decide if a letter to the Court was an "answer" for, assuming that it was, the letter also stated an objection to jurisdiction and thus the Court did not acquire personal jurisdiction over the party. Katz v. Katz, supra. Similarly, in the Florida case of Moore v. Moore, 583 So. 2d 808 (4th District Court of Appeals, 1991), the Court held that a letter from the husband to the Court which described various aspects of the litigation was properly treated as an answer and appearance giving the Court personal jurisdiction because, inter alia, it did not object to the Court's jurisdiction.