In the case of Friedetzky v. Hsia, a New York resident was alleged to be the father of a child in a custody action brought in Maryland, by the child’s mother. The New York resident requested a paternity test and engaged in financial discovery before admitting he was the child’s father. Thereafter, the mother amended her complaint and sought child support and, as a result, the father sought to dismiss the case. The Maryland Court of Special Appeals conceded that the father, as a non-resident, was entitled to limited immunity to participate in a child custody proceeding without submitting to personal jurisdiction for other matters. However, the court further held that the father’s actions in participating in discovery and requesting a paternity test constituted acts which personally availed the father of the jurisdiction of the Maryland Courts. As a result, the father could not dismiss the case.