What are the proper standards for (1) a trial court's ruling on a motion to transfer venue, and (2) an appellate court's review of that ruling?

The court must be satisfied that the movant has produced "admisible factual evidence demonstrating a strong possibility that an impartial trial cannot be obtained," according to the Second Department, in Behrins & Behrins v. Chan, which was decided on May 1, 2007. The court noted that ruling on the motion is left to the sound discretion of the trial court, pursuant to CPLR 510(2), and that its determination "will not be disturbed absent an improvident exercise of discretion."