Venue, again.

If you're looking to change venue, don't bother pleading convenience of the parties, since it is irrelevant, according the Second Department, in Frankel v. Stavsky, which was decided on May 22, 2007. Instead, the movant must plead (1) the convenience of the nonparty witness who is willing to testify, and (2) the nature and materiality of that witness's anticipated testimony. Failing that, said the court, we're staying put.