(.27 ) 

IN THE UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF PENNSYLVANIA 

GORDON ROY PARKER, a.k.a. Ray Gordon, d/b/a 

Snodgrass Publishing Group, 

4247 Locust Street, #806 

Philadelphia, PA 19104 

Plaintiff, 

: 

: 

: 

: 

.. 

: CASE NO.: 05-cv-2752 

v. 

Learn The Skills Corp., et al. 

: 

: 

: Hon. Harvey Bartle, III 

Defendants. 

: 

: 

ORDER 

AND NOW, this _ day of -', 2006, in consideration ofPlaintiWs 

Motion To Conduct Jurisdictional Discovery, the motion is granted. A memorandum opinion 

is attached. 

Plaintiff shall be given sixty (60) days from the date ofthis order to complete discovery 

relating to the conduct of Defendants Ross, Geiger, and LTSC insofar as such conduct is relevant 

to the issue ofjurisdiction ofthis court over those Defendants. 

SO ORDERED. 

J 

Case 2:05-cv-02752-HB Document 27 Filed 12/01/05 Page 1 of 5
IN THE UNITED STATES DISTRICT COURT
 

EASTERN DISTRICT OF PENNSYLVANIA
 

GORDON ROY PARKER, a.k.a. Ray Gordon, d/b/a 

Snodgrass Publishing Group, F I LED 

4247 Locust Street, #806 

Philadelphia, PA 19104 

DEC 0 1Z005 

MIC~t...!~UNZ, ae&laintiff, 

v. By. Pep. aerk 

Learn The Skills Corp., et al. 

Defendants. 

: 

: 

: 

: 

: 

· · 

: 

· · 

: 

· · 

: 

CASE NO.: 05-cv-2752 

Hon. Harvey Bartle, III 

PLAINTIFF'S MOTION TO CONDUCT JURISDICTIONAL DISCOVERY 

Plaintiff Gordon Roy Parker, in the above-styled action, moves this Court for leave to 

conduct jurisdictional discovery as to Defendants Ross, Geiger, and LTSC, and in support thereof, 

submits the following: 

1. Defendants Ross, Geiger, and LTSC have filed motions to dismiss this action 

for lack ofjurisdiction. 

2. Without the ability to conduct discovery regarding each Defendant's contacts 

with the forum state, Plaintiff s case will be prejudiced. 

RELIEF SOUGHT 

WHEREFORE, Plaintiff seeks leave ofthe court for sixty (60) days to conduct 

discovery by interrogatory of Defendants Ross, Geiger, and LTSe. 

This the 1

st day of December, 2005. 

~f1_f4);v__ Gordon Roy Parker 

4247 Locust Street, #806 

Philadelphia, PA 19104 

(215) 386-7366 

GordonRoyParker@aol.com 

Plaintiff, Pro Se 

Case 2:05-cv-02752-HB Document 27 Filed 12/01/05 Page 2 of 5
IN THE UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF PENNSYLVANIA FILED

nl:'t" n .. ~nnt

ur..v U I ,"UU" GORDON ROY PARKER, a.k.a. Ray Gordon, d/b/a · · 

Snodgrass Publishing Group, : MICPM> E. KUNZ, PIerk 

4247 Locust Street, #806 By, <z Dep Clerk · · 

Philadelphia, PA 19104 :

: 

Plaintiff, : CASE NO.: 05-cv-2752 

: 

: 

v. 

Learn The Skills Corp., et al. : Hon. Harvey Bartle, III

: 

Defendants. : 

MEMORANDUM IN SUPPORT OF PLAINTIFF'S 

MOTION TO CONDUCT JURISDICTIONAL DISCOVERY 

Plaintiff Gordon Roy Parker, in the above-styled action, submits this Memorandum In 

Support of the above-referenced motion. 

INTRODUCTION 

Defendants Ross, Geiger, and LTSC have filed motions to dismiss this case for lack of 

jurisdiction. 

LEGALSTANDARD~RGUMENT

This Court should not entertain a dismissal for lack ofjurisdiction in this case without 

first allowing the discovery sought in this motion. In Toys "R" US, Inc., v. Step Two, S.A., 318 

F.3d 446 (3d Cir. 2003), the Third Circuit remanded the case back to the District Court to allow 

for exactly this type of discovery when jurisdiction was in controversy, refusing to allow a motion 

to dismiss for lack ofjurisdiction without the Plaintiff having the benefit ofsuch discovery. 

In Defendant Ross's Memorandum in Support of his Motion To Dismiss, the need for 

jurisdictional discovery is explained: 

Once a jurisdictional challenge has been raised it is the plaintiffs burden to establish that 

the defendant has "minimum contacts with the forum" such that the defendant could 

"reasonably anticipate being haled into court there." Pennzoil Prods. Co. v. Colelli & 

Assocs., 149 F.3d 197,201 (3d Cir. 1998) (quoting World-Wide Volkswagen Corp. v. 

Case 2:05-cv-02752-HB Document 27 Filed 12/01/05 Page 3 of 5
Woodson. 444 U.S. 286,297 (1980», see also. Mellon Bank (East) PSFS. N.A. v. Farino, 

960 F.2d 1217, 1223 (3d Cif. 1992). The required "minimum contacts must have a basis in 

'some act by which the defendant purposefully avails itself of the privilege of conducting 

activities within the forum State, thus invoking the benefits and protections of its laws." 

Asahi Metal Indus. Co. v. Superior Court, 480 U.S. 102, 109 (1987) (O'Connor, 1., 

plurality opinion) (quoting Burger King Corp. v. Rudzewicz, 471 U.S. 462, 475 (1985». 

A plaintiff can not just rely on bald assertions regarding the defendant's contact with the 

forum state. Carteret Sav. Bank v. Shushan, 954 F.2d 141, 146 (3d Cif. 1992). Rather, a 

plaintiff is required to present evidence sufficient to establish a prima facie case for the 

exercise of personal jurisdiction. Mellon Bank v. Farino, 960 F.2d 1217, 1223 (3d Cif. 

1992), Carteret Sav. Bank, 954 F.2d at 146?4 

Any claim that Plaintiff lacks evidence ofjurisdiction would demand, as a matter of due 

process, that Plaintiff be afforded the opportunity to fully explore all evidence relating to the 

Defendants' claims. Alternatively, Plaintiff should be granted a hearing on the motions to dismiss 

so as to be afforded cross-examination ofthe evidence in support, including but not limited to 

Defendant Ross's Affidavit. 

CONCLUSION 

For the reasons set forth hereinabove, the instant motion should be granted. An 

appropriate form of order is attached. 

This the 1

st day of December, 2005. 

Gordon Roy Parker 

4247 Locust Street, #806 

Philadelphia, PA 19104 

(215) 386-7366 

GordonRoyParker@ao1.com 

Plaintiff, Pro Se 

24 Id., III(A)(2), p. 5. 

2 

Case 2:05-cv-02752-HB Document 27 Filed 12/01/05 Page 4 of 5
IN THE UNITED STATES DISTRICT COURT F I LED 

EASTERN DISTRICT OF PENNSYLVANIA 

GORDON ROY PARKER, a.k.a. Ray GordQn, d/b/a 

Snodgrass Publishing Group, 

4247 Locust Street, #806 

Philadelphia, PA 19104 

v. 

Learn The Skills Corp., et a1. 

, Plaintiff, 

Defendants. 

CASE NO.: 05-cv-2752 

Hon. Harvey Bartle, In 

CERTIFICATE OF SERVICE 

I, Gordon Roy Parker, hereby certify that I have served the foregoing Brief In Opposition 

To Defendant Ross's Motion To Dismiss and Motion To Conduct Jurisdictional Discovery on 

the following Defendants, by the following means: 

Trustees ofthe Univ. ofPA Mary Kay Brown, Esq. Matthew S. Wolf, Esq. 

Dennis G. Young (Counsel) Buchanan Ingersoll 241 Kings Highway East 

Montgomery, McCracken, 1835 Market Street, 14th Floor Haddonfield, NJ 08033 

Walker & Rhoads 

123 South Broad Street, 28th FI. 

Philadelphia, PA 19103 

Hand Delivery 

Attorney For LTSC And 

Defendant 

Philadelphia PA 19109 Regular Mail 

Hand Delivery 

Fonnhandle@fastseduction.com 

Thorn E. Geiger Learn The Skills Corp. 

817 North McCrary Road 955 Massachusetts Ave, #350 

Columbus, MS 39702-4320 . Cambridge, MA 02139 

Regular Mail Regular Mail 

This the 1

st day ofDecember, 2005. 

4247 Locust Street, #806 

Philadelphia, PA 19104 

(215) 386-7366 

GordonRoyParker@ao1.com 

Plaintiff, Pro Se 

Case 2:05-cv-02752-HB Document 27 Filed 12/01/05 Page 5 of 5