Case 2:05-cv-02257-KHV-JPO Document 9 Filed 09/26/05 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF KANSAS

GRACELAND COLLEGE CENTER FOR )
PROFESSIONAL DEVELOPMENT AND )
LIFELONG LEARNING, INC., )
d/b/a SKILLPATH )
)
Plaintiff, ) Case No. 05-2257-KHV
)
v. )
)
MICHAEL F. PRICE, d/b/a )
BizSummits, SkillSummit, )
and VC South )
)
Defendant. )

UNOPPOSED MOTION FOR LEAVE TO CONDUCT LIMITED DISCOVERY
RELATED TO JURISDICTIONAL ISSUES AND TO EXTEND THE TIME TO
RESPOND TO DEFENDANT’S MOTION TO DISMISS FOR LACK OF PERSONAL
JURISDICTION

Plaintiff Graceland College Center for Professional Development and Lifelong Learning,

Inc., d/b/a SkillPath (“SkillPath” or “Plaintiff”), by and through its attorneys, hereby moves the

Court for its order allowing Plaintiff to take discovery related to Defendant Michael Price’s

(“Price” or Defendant”) Motion to Dismiss for Lack of Personal Jurisdiction (the “Motion”), and

for an extension of the deadline to respond to the Motion.

SkillPath currently anticipates serving a request for production on Price and then taking

a telephone deposition from him. SkillPath intends to serve the request for production shortly

after the granting of this motion. It hopes to depose Price soon after it receives his production.

Assuming Price timely produces documents in thirty days as provided in Rule 34, Fed. R. Civ.

P., and the deposition occurs soon thereafter, SkillPath believes it could file its response to

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Case 2:05-cv-02257-KHV-JPO Document 9 Filed 09/26/05 Page 2 of 3

Price's Motion fifty days after the court granted it leave to conduct discovery and extends the

time for SkillPath to respond to Price's motion.

SkillPath’s counsel has contacted counsel for Price to request such an extension and to

conduct discovery, and counsel for Price stated that he will not oppose SkillPath’s Motion. The

deadline for responding to Price’s Motion is currently Monday, September 26, so the deadline

has not yet passed, and SkillPath has not previously sought any extension of the deadline to

respond to Price’s Motion.

For the reasons set forth in this motion and SkillPath’s concurrently-filed Memorandum

in Support of this motion, SkillPath respectfully requests that this Court grant SkillPath leave to

conduct jurisdictional discovery, and that the time for responding to Price’s Motion be extended

until fifty days after the court grants this motion, and for such other and further relief as this

Court deems just and proper.

Dated: September 26, 2005 Respectfully submitted,

SONNENSCHEIN NATH & ROSENTHAL LLP

By: /s/ Robert Lesley
Robert O. Lesley KS #11545
Rebecca S. Stroder KS #20648
4520 Main Street, Suite 1100
Kansas City, Missouri 64111
Phone: (816) 460-2400
Fax: (816) 531-7545
rlesley@sonnenschein.com
rstroder@sonnenschein.com

Attorneys for Defendant Graceland College Center for
Professional Development and Lifelong Learning, Inc.,
d/b/a/ SkillPath, Inc.

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Case 2:05-cv-02257-KHV-JPO Document 9 Filed 09/26/05 Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on September 26, 2005, I filed the foregoing document with the
Clerk of the Court, using the ECF system, which delivered copies via email to the following:

Jan P. Helder, Jr., Esq.
Helder Law Firm
2300 Main St., 9th Floor
Kansas City, MO 64108
jph@helderlaw.com

__/s/ Robert Lesley ______________
Attorney for Plaintiff

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