Notice Of Motion To Take Deposition In Another Jurisdiction

___________________ COURT _____________________ COUNTY OF ____________________________________ -----------------------------------------------------------------------x NOTICE OF MOTION TO TAKE DEPOSITION IN ANOTHER JURISDICTION Plaintiff(s), Against Index No. _____________ _____________________ Defendant(s). -----------------------------------------------------------------------x PLEASE TAKE NOTICE that upon the attached and upon all prior pleadings and proceedings, the undersigned will move this Court, at the Courthouse _____________________________, on __________________, at ___________, or as soon thereafter as counsel may be heard, for an order pursuant to CPLR 3101 and 3108 directing the issuance of a commission to ___________________ _______________ as Commissioner, to take the deposition of ___________________________ as a witness in connection with the above captioned action, upon _________________________ _________________________________, on the ground that _____________________________ cannot be conveniently examined before trial other than by such means because _____________________________ is not resident in or otherwise available for examination in New York State, ___________________________________ and granting such other and further relief as the Court deems proper. Pursuant to 22 NYCRR § 202.7, an Attorney's Affirmation that a good faith effort has been made to resolve the issues raised in this motion is attached. PLEASE TAKE FURTHER NOTICE, that opposition papers, if any, must be served upon the undersigned [complete or choose from menu] Dated: _________________, New York _______________, 20___ By: To: Attorneys for _____________________ American LegalNet, Inc. www.FormsWorkFlow.com