Florida law holds that in personam jurisdiction may be acquired in probate proceedings by consent, by voluntary general appearance of an interested person, or by an interested person asking the court for affirmative relief. One court has held that minimal actions by a beneficiary in an estate administration were deemed to be a waiver of objections to personal jurisdiction for the separate matter of determining the ownership of contested assets that were located with the estate beneficiary in the State of Ohio. Markowitz v. Merson, 869 So.2d 728 (Fla. 4th DCA 2004).