Professional Documents
Culture Documents
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).
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
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
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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
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 Defendants Motion to Dismiss. This Amended Motion is the first amendment to
that pleading.
7. 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
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
9. Plaintiffs 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 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
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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:
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