Motion 7-Transfer Venue in Car Accident Case

Download PDF Version


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.

__________________,

<<signature>>

Client Reviews
Jonathan Rosenfeld was professionally objective, timely, and knowledgeable. Also, his advice was extremely effective regarding my case. In addition, Jonathan was understanding and patient pertaining to any of my questions or concerns. I was very happy with the end result and I highly recommend Jonathan Rosenfeld.
★★★★★
Extremely impressed with this law firm. They took control of a bad motorcycle crash that left my uncle seriously injured. Without any guarantee of a financial recovery, they went out and hired accident investigators and engineers to help prove how the accident happened. I am grateful that they worked on a contingency fee basis as there was no way we could have paid for these services on our own. Ethan Armstrong, Google User
★★★★★
This lawyer really helped me get compensation for my motorcycle accident case. I know there is no way that I could have gotten anywhere near the amount that Mr. Rosenfeld was able to get to settle my case. Thank you. Daniel Kaim, Avvo User
★★★★★
Jonathan helped my family heal and get compensation after our child was suffered a life threatening injury at daycare. He was sympathetic and in constant contact with us letting us know all he knew every step of the way. We were so blessed to find Jonathan! Giulia, Avvo User
★★★★★
Jonathan did a great job helping my family navigate through a lengthy lawsuit involving my grandmother's death in a nursing home. Through every step of the case, Jonathan kept my family informed of the progression of the case. Although our case eventually settled at a mediation, I really was impressed at how well prepared Jonathan was to take the case to trial. Lisa, Avvo User
★★★★★
Contact Us for a Free Consultation (888) 424-5757
Chicago Office Map