Case 2:05-cv-02257-KHV-JPO Document 36 Filed 01/30/06 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, )
BizSummits LLC, )
and Specialty Holdings LLC d/b/a VC South )
)
Defendants. )

UNOPPOSED MOTION TO EXTEND TIME TO RESPOND TO
DEFENDANTS’ MOTION TO DISMISS

Plaintiff Graceland College Center for Professional Development and Lifelong Learning,

Inc., d/b/a SkillPath (“SkillPath” or “Plaintiff") hereby moves this Court for its order extending the

time for Plaintiff to respond to Defendants’ Motion to Dismiss for Lack of Personal Jurisdiction. In

support of its Motion, Plaintiff states as follows:

1. SkillPath filed its Complaint on June 22, 2005, and Defendants responded by filing a

Motion to Dismiss for Lack of Personal Jurisdiction on September 1, 2005.

2. The parties agreed to, and this Court ordered, an extension of time for the Plaintiff to

respond to the Defendants’ Motion to Dismiss, and the parties agreed to and the Court granted leave

for the Plaintiff to conduct jurisdictional discovery.

3. Subsequently, the Plaintiff filed and served its Amended Complaint, and Defendants

re-filed their Motion to Dismiss on December 6, 2005 (Docket No. 31). Plaintiff sought and obtained

a further extension of time to respond to Defendants’ re-filed Motion to Dismiss. This is the second

such extension sought with respect to the Defendants’ re-filed Motion to Dismiss.

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4. The deadline for Plaintiff to respond to Defendants’ Motion to Dismiss is currently

set at January 30, 2006. The time for responding to that Motion to Dismiss has not passed.

5. The parties are very close to a dismissal of this case without prejudice. They have

negotiated concerning a dismissal and only have one issue to resolve. Nevertheless, the parties do

not believe they will be able to finalize that agreement by the end of the day on January 30, 2006, the

current deadline for the Plaintiff to respond to the Defendants’ Motion to Dismiss.

6. Plaintiff’s counsel has consulted with Defendants’ counsel, and Defendants’ counsel

has indicated that the Defendants do not oppose this extension.

7. Accordingly, SkillPath asks that the Court to extend the time for Plaintiff to respond

to Defendants’ Motion to Dismiss for thirty (30) days, making the Plaintiff’s response due on or

before March 1, 2006.

For the reasons set forth in this motion, SkillPath respectfully requests that this Court extend

the time for the Plaintiff to respond to Defendants’ Motion to Dismiss for thirty (30) days, so that the

parties may finalize the terms of their compromise, which they anticipate will result in dismissal of

this case without prejudice, and for such other and further relief as this Court deems just and proper.

Dated: January 30, 2006 Respectfully submitted,

SONNENSCHEIN NATH & ROSENTHAL LLP

By: /s/ Rebecca Stroder
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 36 Filed 01/30/06 Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on January 30, 2006, 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/ Rebecca Stroder_____________
Attorney for Plaintiff

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