Affirmation in Support of Motion to Change Venue

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__________ [Name], an attorney duly admitted to practice law in the courts of the State of New York, affirms the following to be true, except for those matters stated to be upon information and belief, under the penalties of perjury:

1. I am an associate at the law offices of __________ [Name], the attorneys of record for the Defendant, and as such am fully familiar with all of the prior proceedings in this action.

2. I make this Affirmation in support of Defendant’s Motion to Change Venue in the instant matter.

   BACKGROUND FACTS

3. On __________ [Date], at approximately __________ [Time], Plaintiff’s automobile collided with Defendant’s automobile at the intersection of __________ [Street name] and __________ [Street name] in __________ [City, County, and State]. Plaintiff alleges that [he/she] has suffered personal injuries and property damages arising from that collision and that the collision was the result of Defendant’s negligence.

4. Plaintiff commenced the instant action by filing a summons and verified complaint in the Supreme Court of the County of __________ [Name] on __________ [Date]. Annexed hereto as Exhibit "__" and made a part hereof is a copy...