Professional Documents
Culture Documents
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
1. SkillPath filed its Complaint on June 22, 2005, and Defendants responded by filing a
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
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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Case 2:05-cv-02257-KHV-JPO Document 36 Filed 01/30/06 Page 2 of 3
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. Plaintiffs counsel has consulted with Defendants counsel, and Defendants counsel
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 Plaintiffs response due on or
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.
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:
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