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STATE OF NEW YORK
SUPREME COURT  :  COUNTY OF MONROE


ESTHER G. ROLICK, 
Plaintiff, 

-vs-

THE JACQUES SELIGMANN & COMPANY
Defendant.



STATE OF NEW YORK   )
COUNTY OF NeW YORK  )  SS.:

T.D. PARKER, being duly sworn, deposes and says:

I. She is the Assistant Treasurer of Jacques Seligmann & Co., Inc., sued herein as The Jacques Seligmann & Company, and is thoroughly familiar with the facts of this case and the facts hereinafter set forth. This affidavit is made in support of defendant's motion to change the venue of this action from Monroe County to New York County. On the matters of law set forth herein, I have been advised by Melvin C. Robbins, Esq., who is a member of the firm of Benjamin, Galton & Robbins, defendant's attorneys, and by Irving Choban, Esq., who is associated with the said attorneys for the defendant corporation. 

2. As more fully appears from the complaint, a copy of which is annexed hereto and marker Exhibit "A", this action is brought to recover the sum of $7,195.00, which plaintiff claims is due her as the result of the destruction by the fire of her paintings which were stored in a warehouse, as hereinafter discussed at length. 

3. This motion is made upon the following grounds:-
(a) Convenience of witnesses and end of justice:-

As will hereinafter be shown, all of defendant's witnesses reside in New York County, and the defendant's place of business is located In New York County. The defendant

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