of garnishment. As one court has observed, a garnishment proceeding “is not an action in personam, nor is it, strictly speaking, a proceeding in rem. Partaking of the nature of both, it is frequently classified as a proceeding quasi in rem.” U.S. Rubber Co. v. Poage, 297 F.2d 670, 673 (5th Cir.1962) (citations omitted). Because of the dual nature of a garnishment proceeding, courts sitting in this state have held that a court presiding over a writ of garnishment must not only have personal jurisdiction over the garnishee, but also jurisdiction over the property or “res”. that is the subject of the -writ of garnishment. See APR Energy, LLC v. Pakistan Power Resources, LLC, 2009 WL 425975, at * 2 (M.D.Fla.2009); see also, Harris v. City of Sarasota, 132 Fla. 568, 181 So. 366, 369 (1938) (<HOLDING>); Dewind v. JP Morgan Chase & Co., 2011 WL
holding that the basis of in rem jurisdiction is the presence of the subject property within the territorial jurisdiction of the forum state 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 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 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