at *6. However, the main source of the court’s concern was that an “unsuspecting claimant,” appearing in court solely to adjudicate his or her rights to property, would be subjected to personal jurisdiction and accordingly a personal judgment. Id. at *7. Alsdorf was clearly on notice of the claims against her when she appeared in the in rem action. The court is not concluding that merely appearing in the in rem action is sufficient to establish personal jurisdiction. Purposeful availment and relatedness are still necessary. See All Right, title and Interest, 1996 WL 695671, at *16 (“[CJross-claimants must properly obtain personal jurisdiction in order to lodge their cross-claims”); see also United States v. 51 Pieces of Real Property, Rosivell, New Mexico, 17 F.3d 1306 (10th Cir.1994) (<HOLDING>). But see United States v. Contents of Accounts
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 holding that a claimant submits to personal jurisdiction by appearing in an in rem civil forfeiture action holding the claimant does not consent to personal jurisdiction by appearing in in rem action 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 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