1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 UNITED STATES DISTRICT COURT

9 ___________ DISTRICT OF __________

10

11 Any Plaintiff, ) Case No.

)
12 Plaintiff, ) NOTICE OF MOTION AND MOTION TO DISMISS
) FOR IMPROPER VENUE; MEMORANDUM OF
13 vs. ) POINTS AND AUTHORITIES; DECLARATION OF
) _____________
14 Any Defendant, and DOES 1-5 )
) DATE:
15 Defendants. ) TIME:
) DEPT:
16 )
)
17 )
)
18 )

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NOTICE OF MOTION AND MOTION TO DISMISS FOR IMPROPER VENUE
 1 TO PLAINTIFF, _______________ AND HIS ATTORNEYS OF RECORD:
2 PLEASE TAKE NOTICE that on ________, at ______M. in Courtroom of the above-entitled
3
Court located at ___________________________, Defendant _________ will move this Court for an
4
Order dismissing the complaint.
5

6
This Motion will be made on the grounds of lack of improper venue under the provisions of

7 Federal Rule of Civil Procedure 12(b)(3) in that the venue chosen by Plaintiff is improper under 28

8 U.S.C. 1391 in that this judicial district is not (1) a judicial district in which any defendant resides,
9
if all defendants are residents of the State in which the district is located; (2) a judicial district in
10
which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial
11
part of property that is the subject of the action is situated; or (3) if there is no district in which an
12

13 action may otherwise be brought as provided in this section, any judicial district in which any

14 defendant is subject to the court's personal jurisdiction with respect to such action.
15
This Motion shall be based upon this Notice, the attached Memorandum of Points and
16
Authorities, the attached declaration of __________, the complete files and records of this action and
17
such other evidence as may be presented at the hearing on this Motion.
18

19

20 Dated_________________________ _______________________________________
ANY ATTORNEY OR PARTY
21

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28 states-district-court
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NOTICE OF MOTION AND MOTION TO DISMISS FOR IMPROPER VENUE