Case 2:05-cv-02257-KHV-JPO Document 13 Filed 09/28/05 Page 1 of 4

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. )

AMENDED UNOPPOSED MOTION TO STAY PROCEEDING PENDING
DISPOSITION OF DEFENDANT’S MOTION TO DISMISS FOR LACK OF PERSONAL
JURISDICTION

COMES NOW Plaintiff Graceland College Center for Professional Development and

Lifelong Learning, Inc., d/b/a SkillPath (“SkillPath” or “Plaintiff”), by and through its attorneys,

and hereby moves this Court for its Order staying activity in the instant case pending disposition

of the Defendant’s Motion to Dismiss for Lack of Personal Jurisdiction (“Defendant’s Motion”).

In support of this Motion, SkillPath states as follows:

1. SkillPath filed its Complaint on June 23, 2005, and served Defendant on July 6,

2005.

2. On September 1, 2005, in response to the Complaint, Price filed and served the

Defendant’s Motion and Supporting Memorandum.

3. On September 9, 2005, the Court issued its Order setting a Scheduling Conference

for October 18, 2005, and setting the deadline for the parties to submit a report of their planning

conference for October 11, 2005.

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4. On September 26, 2005, SkillPath filed its Unopposed Motion for Leave to

Conduct Jurisdictional Discovery and to Extend the Time for Responding to Defendant’s Motion

to Dismiss (the “Jurisdictional Discovery Motion”) and memorandum in support thereof.

5. On September 27, 2005, the Court granted the Jurisdictional Discovery Motion.

6. On September 28, 2005, SkillPath filed its Motion to Stay Proceeding Pending

Disposition of Defendant’s Motion to Dismiss. This Amended Motion is the first amendment to

that pleading.

7. In light of the fact that the Defendant’s Motion is pending, and that SkillPath has

been given additional time to conduct jurisdictional discovery related to Defendant’s Motion,

SkillPath requests that the Court stay the requirement that the parties hold a planning conference,

submit a report of their planning conference, and participate in a Scheduling Conference, until

after the Court has ruled on the Defendant’s Motion.

8. This motion is not made for purposes of delay; rather, SkillPath believes that

judicial economy will best be served by postponing scheduling matters until after the Court has

determined whether this case will be dismissed.

9. Plaintiff’s counsel has consulted with counsel for Defendant, and counsel for

Defendant stated that the Defendant would not oppose this Motion.

WHEREFORE, SkillPath hereby respectfully requests that this Court stay all deadlines

set forth in the Court’s September 9, 2005 Order related to scheduling, until such time as the

Court has ruled upon Defendant’s Motion, and for such other and further relief as this Court

deems just and proper.

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Dated: September 28, 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 Plaintiff 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 13 Filed 09/28/05 Page 4 of 4

CERTIFICATE OF SERVICE

I hereby certify that on September 28, 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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