Fill and Sign the Mississippi Motion Dismiss 497315356 Form

IN THE CIRCUIT COURT OF       COUNTY, MISSISSIPPI       AND       PLAINTIFFS VS. NO.             DEFENDANT MOTION TO DISMISS OR, IN THE ALTERNATIVE, TO TRANSFER Pursuant to Miss. R. Civ. P. 12(b)(3),       , files this Motion to Dismiss, Or, in the Alternative, to Transfer Venue on the basis that venue is improper in the Circuit 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       ,       , Mississippi. 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 Miss. Code Ann. Section 11 - 11 - 3 (Supp. 1992) venue is proper in       County, Mississippi. 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       ,       . Respectfully submitted,       BY:___________________________________________       , One of Its Attorneys CERTIFICATE OF SERVICE I,       , hereby certify that I have this day caused to be mailed by United States mail, postage prepaid, a true and correct copy of the above and foregoing MOTION TO DISMISS, OR, IN THE ALTERNATIVE TO TRANSFER to the following counsel of record: This the       day of       ,       . ____________________________