Case 2:05-cv-02257-KHV-JPO Document 17 Filed 10/27/05 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 )
6900 Squibb Road )
Shawnee Mission, Kansas 66201-2768, )
)
Plaintiff, ) Case No. 05-2257-KHV
)
v. )
)
MICHAEL F. PRICE, d/b/a )
BizSummits, SkillSummit, )
and VC South )
66 Perimeter Center, 6th Floor )
Atlanta, Georgia, 30346, )
)
Defendant. )

MOTION FOR LEAVE TO AMEND COMPLAINT

Plaintiff Graceland College Center for Professional Development and Lifelong Learning,

Inc., d/b/a SkillPath. (SkillPath) hereby moves this Court for leave to amend its Complaint,

originally filed on June 23, 2005, pursuant to Rule 15 of the Federal Rules of Civil Procedure. In

support of its Motion, SkillPath states as follows:

1. SkillPath filed its Complaint on June 22 2005, and served Defendant Michael

Price (Price) on June 28, 2005.

2. In its original Complaint, SkillPath named Price as the sole defendant,

individually and in his capacity as the proprietor of what SkillPath believed to be various

unincorporated business going by the fictitious names VC South, BizSummits, and

SkillSummits.

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3. On September 1, 2005, Defendant Price, through counsel, responded to the

Complaint by filing a Motion to Dismiss for Lack of Personal Jurisdiction, and supporting

memorandum.

4. In support of his Motion, Price submitted an affidavit in which he describes the

true organizational structure of the various entities with which he is affiliated. In particular,

Price states that he is the President of Specialty Holdings LLC d/b/a VC South (VC South) and

BizSummits LLC (BizSummits), both of which are Georgia limited liability companies.

5. Prior to filing its Complaint, SkillPath had not been aware of this corporate

structure. SkillPath now desires to amend its Complaint to bring its claims against these entities

as well as Price.

6. No discovery on substantive issues has taken place in this case (although

SkillPath has begun limited jurisdictional discovery), no trial date has been set, and the parties

have not yet set a date for a scheduling conference; thus, no prejudice will result from SkillPaths

proposed amendment.

7. In light of the above, and for the reasons set forth in the accompanying

Memorandum in Support of SkillPaths Motion for Leave to Amend its Complaint, SkillPath

respectfully requests that this Court grant it leave to file the proposed amended complaint

attached hereto as Exhibit A.1

WHEREFORE, plaintiff SkillPath moves this Court for leave to file its proposed

Amended Complaint, and for such other and further relief as this Court deems just and proper.

1
The Complaint contained several exhibits, which will remain the same in the Amended
Complaint.
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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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CERTIFICATE OF SERVICE

I hereby certify that on October 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/ Rebecca Stroder
Attorney for Plaintiff

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