In Wolfe v. Pickar, 2011 ONCA 347, 332 D.L.R. (4th) 157, Justice Goudge said, at para. 44: [W]hen a party to an action appears in court and goes beyond challenging the jurisdiction of the court based on jurisdiction simpliciter and forum non conveniens, the party will be regarded as appearing voluntarily, thus giving the court consent-based jurisdiction.
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