lawsuit in the same manner as those two cases were distinguishable from the Myers lawsuit. See supra Part III. B.2.a. Macatawa contends that the escrow agreements and the ensuing obligations are insufficient to establish purposeful availment and cites Far West Capital v. Towne, 46 F.3d 1071 (10th Cir.1995), in support of this contention. In Far West Capital the party that created the escrow account was attempting to use the situs of the escrow account as evidence of purposeful availment. Id. at 1075-76. This would be equivalent to Macatawa contending that the Adamson plaintiffs are subject to specific personal jurisdiction in Michigan because the situs of the escrow accounts was in Michigan. On this basis Far West Capital is clearly distinguishable. Cf. Serras, 875 F.2d at 1215, 1218 (<HOLDING>). Macatawa purposefully availed itself of the
holding that the district court retained jurisdiction to resolve a dispute over an injunction bond even where the underlying dispute had itself been dismissed for lack of subjectmatter jurisdiction holding in dispute involving two insurers the federal action against only one insurer should be stayed in favor of state action involving both holding that where the minimal requirements of due process have been met an inmate must show prejudice when a particular regulation is not complied with before a federal court will intervene holding that treatment as a child is not a constitutional right but a right granted by the legislature and statute met basic due process requirements holding that the due process requirements of jurisdiction in michigan had been met for a dispute involving property in tennessee