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It is well established that once a court obtains personal jurisdiction over a party in an action, jurisdiction over the party continues for subsequent proceedings that arise out of that action. (See, e.g., Rest.2d Conf. of Laws (Rev. May 19, 1988) § 26 ['If a state obtains judicial jurisdiction over a party to an action, the jurisdiction continues throughout all subsequent proceedings which arise out of the original claim.']; Michigan Trust Co. v. Perry (1913) 228 U.S. 346, 353 [33 S. Ct. 550, 552, 57 L. Ed. 867] ['if a judicial proceeding is begun with jurisdiction over the person of the party concerned it is within the power of a State to bind him by every subsequent order in the cause'].) As the comments to section 26 of the Restatement Second of Conflict of Laws explain, '[t]he continuance of a state's judicial jurisdiction, once such jurisdiction has been obtained, is not dependent upon the constant existence of some jurisdictional basis. Such a basis must exist at the initiation of the proceeding; it need not continuously do so thereafter.' (Rest.2d Conf. of Laws, supra, § 26, com. a, p. 24.)


Once a court obtains jurisdiction over the parties ...

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