Motion to Transfer Venue

MOTION TO TRANSFER VENUE

IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI

and

PLAINTIFFS

V.

DEFENDANT

CIVIL ACTION NO.:

Defendant, , by and through counsel of record, moves this Court pursuant to Miss. Code Ann. § 11-11-3 (1972), as amended, and Rule 82 of the Miss. R. Civ. Proc. for an Order transferring venue to the Circuit Court of County, Mississippi, and in support of this motion shows this Court as follows:

1. Venue is not proper before this Court in that the Defendant is a resident of County, Mississippi; the contracts made the basis of Plaintiffs' Complaint were executed, notarized and sealed in County, Mississippi; the real property which is a subject of Plaintiffs' Complaint is situated in County, Mississippi; and the recovery of alleged damages sought by Plaintiff accrued, if at all, in County, Mississippi. Nothing concerning County, Mississippi, is at issue in this proceeding.

2. Attached hereto as Exhibit "A" and incorporated herein by reference is the affidavit of , who states that the documents attached to Plaintiffs' Complaint were executed and notarized in his/her presence at the building located at , County, Mississippi.

3. The Circuit Court of County, Mississippi, is the appropriate venue for this proceeding.

4. Pursuant to Rule 82 of the Miss. R. Civ. Proc., all costs associated with the transfer of this proceeding are to be taxed to Plaintiffs.

WHEREFORE, PREMISES CONSIDERED, Defendant moves this Court for an Order transferring this case to the Circuit Court of County, Mississippi, with all costs taxed to Plaintiffs.

Respectfully Submitted,

OF COUNSEL:

P.O. Box

CERTIFICATE OF SERVICE

This is to certify that I have this day served the foregoing upon the following by placing a true and accurate copy of same in the United States Mail, properly addressed, and with adequate postage thereon:

This the day of , 20

OF COUNSEL