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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 Prices
(Price or Defendant) Motion to Dismiss for Lack of Personal Jurisdiction (the Motion), and
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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Price's Motion fifty days after the court granted it leave to conduct discovery and extends the
SkillPaths 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 SkillPaths Motion. The
deadline for responding to Prices 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
For the reasons set forth in this motion and SkillPaths 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 Prices Motion be extended
until fifty days after the court grants this motion, and for such other and further relief as this
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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:
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