February 4, 2022

An untimely motion to change venue.

It is a proper exercise of discretion to grant the motion when the defendant's delay can be attributed to plaintiff's willful omissions or misleading statements and the defendant moves promptly after ascertaining the truth about plaintiff's residence.

Montgomery v. ELRAC, Enter. Holdings, Inc., NY Slip Op 00508 (1st Dep't January 27, 2022)

Here is the decision.