Am. Bus. Fin. Servs., 2002 WL 433735, at *5-*6 (citing Kubik v. Letteri, 532 Pa. 10, 14, 614 A.2d 1110 (1992)). Once a defendant raises a personal jurisdiction defense, the burden of establishing the court’s jurisdiction rests with plaintiff. See Cinalli, 191 F.Supp.2d at 610. “Prior to trial, however, [ ] plaintiff[s] need only make a prima facie showing of jurisdiction.” Id. (citing Mellon Bank v. Farino, 960 F.2d 1217, 1223 (3d Cir.1992)). A plaintiff is generally entitled to a “fair opportunity” to conduct jurisdictional discovery. Fed. Ins. Co. v. Richard I. Rubin & Co., 12 F.3d 1270, 1283-85 & n. 11 (3d Cir.1993) (granting discovery on the issue of sovereign immunity) (quotation omitted). See also Rose v. Cont’l AG, No. 99 Civ. 3794, 2001 WL 236738, at *4 (E.D.Pa. Mar.2, 2001) (<HOLDING>). Such discovery must, however, be “limited to
holding that where petitioner testified that some of her cousins had been killed because they served in the military and that she had received two threatening notes she had demonstrated past persecution holding a 100 fine not dismissal with prejudice was the appropriate sanction for the eight plaintiffs failure to answer interrogatories even despite warnings from the trial court and prior sanctions because the requesting party had not been prejudiced by not receiving formal responses to the interrogatories holding that plaintiffs who had been served and received responses to interrogatories on personal jurisdiction had had such a fair opportunity holding that dismissal of some but not all of the defendants who had been served with complaint is not a final order holding that limitation of liability clause in construction contract that is not unconscionable or in violation of public policy is valid so long as parties had a fair opportunity to accept reject or modify limitation and affirming summary judgment on basis that plaintiff had presented no evidence that it had had no such opportunity