MOTION TO CHANGE VENUE

IN THE CIRCUIT COUT FOR THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR XXX COUNTY,
FLORIDA
CASE NO: CACE -XXX Division 3
XXX,
a XXX professional association,
Plaintiff,
v.
XXX and
XXX Defendant(s)

MOTION TO CHANGE VENUE

Now Comes the Defendants ,XXX and XXX, and request
that this Court enter an Order changing the venue from XXX County to the XXX County,
XXX Beach County, XXX, and as grounds thereof states:

  1. Pursuant to Fla. Stat. §47.011, “[a]ctions shall be brought only in the county where the defendant
    resides, where the cause of action accrued, or where the property in litigation is located. This
    section shall not apply to actions against nonresidents.”(Emphasis added).
  2. The Villa Bankruptcy case involved the Villas of Windmill Point II Property Owners Association,
    Inc., which is located in Port XXX, and was litigated before the XXX Bankruptcy
    Court for the Southern District of XXX, XXX Division. Besides, one defendant lives
    in XXX County and both the properties owned by the Defendants herein are in Port St.
    XXX County.
  3. For the foregoing reasons, this matter should have been filed in XXX County, XXX
    or Palm Beach County, XXX

WHEREFORE, these premises considered, Defendants move this court to enter an order
transferring the entire court file in Broward County to either the XXX County, XXX or
Palm Beach County, XXX.

Dated: __

Respectfully submitted,

XXX

XXX

XXX

XXX

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via
the indicated method on this __ day of January, XXX on the following parties:

XXX

XXX

XXX

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