Fill and Sign the Form to Dismiss Attorney in Nm

- 1 - IN THE ______________ COURT OF ______________ COUNTY STATE OF ________________ ) ) ) Petitioner/Plaintiff, ) ) ) NO. Vs. ) ) ) Respondent/Defendant ) ) MOTION TO DISMISS OR, IN THE ALTERNATIVE, TO TRANSFER Pursuant to _____. R. Civ. P. ___, _______________, files this Motion to Dismiss, Or, in the Alternative, to Transfer Venue on the basis that venue is improper in the Circui t Court of ____________ County. I. The Complaint identifies the Plaintiffs as adult resident citizens of ___________ County. Further, the Complaint represents that _______________ is located, with its principal place of business, at _______________________, _____________. This is correct. Thus, _______________ is domiciled in __________ County. The cause of action involves the alleged wrongful denial of benefits, which denial would have occurred in ___________ County at the domicile of _______________. Accordingly, pursuant to _______. Code Ann. Section ________, venue is proper in _________ County, _____________. - 2 - WHEREFORE, _______________ requests this Court to dismiss this action, or, in the alternative, to transfer this action to the Circuit Court of ___________ County on the basis of improper venue. _______________ further requests all additional relief the Court may deem proper. DATED, this the ______ day of ______________, 20____. Respectfully submitted, Dated: Name: Title: Address: Address: City, State, Zip: Phone: Fax: E-Mail: Attorney No.: CERTIFICATE OF SERVICE I, ______________________________, do hereby certify that I have this day mailed, U.S. Mail, postage prepaid, a true and correct copy of the above and foregoing to __________________________________, at the following address; ___________________________________________________________________ THIS the ____ day of _____________, 20____.