Legal Document Type: Legal Motion: MOTION TO TRANSFER VENUE

Case Information: Case 24SN-DR00104 | Status: OverRuled

Document Content:
TO THE HONORABLE "COURT":
I, Micheal Salmon, appearing Pro Se, respectfully move this Court to transfer venue for this
case from the United States District Court for the Western District of Missouri to the United
States District Court for the District of Kansas, in the interest of justice and for the convenience
of all parties and witnesses, pursuant to 28 U.S.C. � 1404(a).

I. Introduction
This motion seeks to transfer venue to the District of Kansas, where both parties currently
reside, to reduce undue burdens on the parties and ensure efficient resolution of this matter.
The current venue in Missouri imposes significant logistical and financial challenges, making it
impractical for the parties and witnesses.

II. Factual Background
1. Parties� "Residences":
? I, Micheal Salmon, reside at 4120 Adams Street, Kansas City, Kansas, 66103.
? The Plaintiff, Crycella Freitag, resides in Pomona, Kansas.
2. Current Venue "Impact":
? The current venue in Missouri is over four hours away from both parties� homes,
making travel difficult.
3. Efforts to "Cooperate":
? I relocated from Missouri to Kansas to facilitate co-parenting and reduce travel
burdens, moving within 40 minutes of the Plaintiff.

4. Personal and Community Ties in "Kansas":
? Our two-year-old son, Felix, attends a Montessori school and is actively involved
in community activities in Kansas, including church and friendships.

? Both families reside in Kansas, making it a more practical location for witness
testimonies.

5. Financial and Work "Constraints":
? As a full-time single father, taking time off work to travel four hours each way for
court proceedings is unfeasible.
? The Plaintiff also works full time, making a Missouri venue equally burdensome.

III. Legal Standard
Under 28 U.S.C. � 1404(a), this Court may transfer a case for the convenience of the parties
and witnesses, and in the interest of justice. Factors to consider "include":
1. The convenience of the parties and witnesses;
2. Access to sourc