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Case 2:05-cv-02257-KHV-JPO Document 12 Filed 09/27/05 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. )

MOTION TO STAY PROCEEDING PENDING DISPOSITION OF DEFENDANTS


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 Defendants Motion to Dismiss for Lack of Personal Jurisdiction (Defendants 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

Defendants 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 Defendants 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. In light of the fact that the Defendants Motion is pending, and that SkillPath has

been given additional time to conduct jurisdictional discovery related to Defendants 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 Defendants Motion.

7. 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.

8. Plaintiffs counsel has asked counsel for Defendant to express whether Defendant

will oppose or consent to this Motion, and Defendants counsel has not expressed that it intends

to oppose this Motion.

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

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

Court has ruled upon Defendants Motion, and for such other and further relief as this Court

deems just and proper.

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Case 2:05-cv-02257-KHV-JPO Document 12 Filed 09/27/05 Page 3 of 4

Dated: September 27, 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 12 Filed 09/27/05 Page 4 of 4

CERTIFICATE OF SERVICE

I hereby certify that on September 27, 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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