Plaintiff's Response to Defendants' Motion to Transfer Venue

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                                                    IN THE SUPERIOR COURT FOR THE
                       COUNTY OF GWINNETT, STATE OF GEORGIA

DAVE H. KELLY,                )                       Civil Action File No. 22-A-10747-1
                              )
                Plaintiff,    )
                              )
v.                            )
                              )
LUIS ESPINOZA COBIAN;         )
ASSOCIATES ASSET RECOVERY,    )
LLC; and CLEAR BLUE INSURANCE )
COMPANY,                      )
                              )
                Defendants.   )


    PLAINTIFF’S RESPONSE TO DEFENDANTS LUIS ESPINOZA COBIAN AND
    ASSOCIATES ASSET RECOVERY, LLC’s MOTION TO TRANSFER VENUE


       COMES NOW, the Plaintiff, Dave H. Kelly, in the above-styled case, by and through

undersigned counsel and moves this Court for an Order denying the Motion to Transfer Venue of

Defendants Luis Espinoza Cobian and Associates Asset Recovery, LLC. Defendant Clear Blue

Insurance Company, the liability ins…