over her. On the other hand, consent to jurisdiction sometimes occurs unwillingly or even inadvertently. As the Court wrote in Insurance Corp. of Ireland, “[a] variety of legal arrangements have been taken to represent e e as they may appear. We have held that a party who files a compulsory counterclaim under Rule 13(a) does not thereby waive any jurisdictional defenses he has previously or concurrently asserted, Dragor Shipping Corp. v. Union Tank Car Co., 378 F.2d 241, 244 (9th Cir.1967), nor has a party who files a permissive counterclaim under Rule 13(b) when objection to “personal jurisdiction ... [is] asserted in the same pleading.” Gates Learjet Corp. v. Jensen, 743 F.2d 1325, 1330 n. 1 (9th Cir.1984); cf. Teyseer Cement Co. v. Halla Mar. Corp., 794 F.2d 472 (9th Cir.1986) (<HOLDING>). In general, we have held that a party has
holding that in a quasi in rem action a district court does not have jurisdiction over the res when that property is not physically within the same state as the court holding there was no consent to in personam jurisdiction where the defendants counterclaim followed a restricted appearance in a quasi in rem admiralty proceeding holding that an action quasi in rem requires a seizure of property within the jurisdiction of the court or its equivalent holding that a party cannot waive in rem jurisdiction under florida law and a court proceeding pursuant to in rem jurisdiction must actually possess in rem jurisdiction over the property that is the subject of the matter holding that where prior state court had in rem jurisdiction district court could maintain in personam jurisdiction and simply deny requests for conflicting in rem relief because district court is fully capable of preventing inappropriate conversion of the suit to a proceeding truly in rem