Pursuant to CPLR 504(1), the place of trial of all actions against a county shall be in that county, and, pursuant to CPLR 504(2), the place of trial of all actions against a town shall be in the county in which that town is situated. Venue may be placed in a county other than the county mandated by CPLR 504 upon a showing of special or compelling countervailing circumstances, but, here, the plaintiffs failed to demonstrate any such circumstances.
N.C. v. Ifezulumbria, NY Slip Op 05515 (2d Dep't October 5, 2022)