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defendant the said commissions in this instance, but that this payment was to set no future precedent. The attorneys requested that a document to this effect be signed — which was done. A copy of the said letter and instrument is annexed hereto, made a part hereof, and marked Exhibit "B" and Exhibit "C" respectively. 

17. Defendant received a check in the amount of $8,305.00 (which included, among other sums, $4,796.67, the sum which plaintiff would have received upon the sale of the paintings, and $2,398.33, the sum which defendant would have received as its commissions). 

18. On June 8th, 1948, (Exhibit "D" annexed hereto and made a part hereof) the defendant advised the plaintiff of the receipt of the check, and asked the plaintiff to sign a receipt for $4,796.67. Plaintiff refused to accept this sum and demanded, in addition thereto, the commissions which defendant had received from the insurance company. 

THE GROUNDS FOR THE MOTION
19. Unless a change of venue be directed herein, defendant will not merely be greatly inconvenienced, but its business and affairs will be paralyzed for the period of the trial. Defendant's business is highly competitive. The presence of Mr. Germain Seligman, Mr. O.A. Liechti and your deponent is constantly required. Artists and prospective purchasers are always visiting the galleries, and there is no one but Mr. Seligman and deponent to take charge. Absence from the gallery and office for even one day may well prove to be a serious matter, perhaps causing the defendant a loss in thousands of dollars in commissions or the irreparable loss of an opportunity to represent a promising artist. 

20. These facts are mentioned because defendant's policies and actions are shaped by three individuals, the same

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