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Motion 7-Transfer Venue in Car Accident Case

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Motion to Transfer

___________________, Address, City, State Zip, Phone:________.

Atty. No. __________

NOW COMES defendant, ____________, by his attorney, ____________,, and for his Motion to Transfer because the instant lawsuit was filed in the wrong venue, states as follows:

1. The automobile accident as alleged in the plaintiff's complaint took place at 1045 South Waukegan Road, Lake Forest, Illinois, which location is in Lake County, Illinois, as evidenced by the police report, attached hereto as Exhibit A.

2. That the co-defendant herein, Pasquesi Home & Gardens, is likewise located in Lake County, Illinois at 1045 South Waukegan Road, at the approximate location of the accident alleged in the plaintiff's complaint.

3. Defendant, Steven H. Joseph, movant herein, resides at 20 Mayfair Lane, Lincolnshire, Illinois, which is in Lake County, and that he was served with summons in the above captioned matter by the Sheriff of Lake County, whose Affidavit of Service is attached hereto as Exhibit B.

4. That the proper venue for this action, pursuant to 735 ILCS 5/2-101 is consequently in Lake County, Illinois, not Cook County, and that pursuant to 735 ILCS 5/2-104, defendant objects to Cook County, Illinois as being the wrong venue and moves pursuant to 735 ILCS 5/2-1001.5 for a change of venue removing this case to its proper venue in Lake County, Illinois, and for such other relief as the Court may deem fit and proper.

WHEREFORE, defendant, Steven H. Joseph, prays for an Order removing this case from Cook County and transferring it to its proper venue in Lake County, Illinois, and for such other relief as the Court may deem fit and proper.



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