The filing of a notice of appearance in an action by a party's counsel serves as a waiver of any objection to personal jurisdiction in the absence of either the service of an answer which raises a jurisdictional objection, or a motion to dismiss, pursuant to CPLR 3211(a)(8), for lack of personal jurisdiction.
Wilmington Trust Co. v. Valdivieso, NY Slip Op 04757 (2d Dep't July 27, 2022)