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45(c)( 1 )(A). The fourth factorlocus of personnel factsalso weighs versus transfer, as the central facts took place in Alabama. Ms. Clackum transacted with Goldco while residing in Alabama, the very first in a chain of events that ultimately provided increase to this case. Mr. Wilson apparently impersonated an Alabama native, utilized a phone number with an Alabama location code, and claimed to have actually called the Alabama Attorney general of the United States's Workplace.

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Wilson's actions caused the best reputational injury in Alabama due to the fact that Mr. Wilson particularly accused Goldco of violating Alabama law to defraud a senior Alabama citizen. Lastly, the 8th factorplaintiff's option of venueweighs against transfer due to the fact that Goldco selected the Northern District of Alabama by filing its lawsuit here. Even after finding out the expected identity of "Bruce Clackum" to be a homeowner of California, Goldco preserves that the Northern District of Alabama is its preferred venue.

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While aspects 2 and threelocation of relevant documents and benefit of partiesweigh in favor of transfer, other courts have marked down the worth of these aspects. For example, the Southern District of Florida has actually held that "producing documents and other declare lawsuits. is not usually a challenging experience due to technological advancements, such as electronic document-imaging and retrieval." Video Game Controller Tech., LLC v.

Supp. 2d 1268, 1274 (S.D. Fla. 2014) (internal quotation marks and modifications left out). And the Middle District of Alabama has kept in mind that the "benefit of non-party witnesses gets substantially more weight than the convenience of parties or party-witnesses." ASD Specialized Healthcare, Inc. v. Letzer, No. 2:10-CV-388-WKW, 2010 WL 2952573, at * 4 (M.D.