Randerson v. White Star Towing Co.

The defendant moves upon the affidavit of its vice-president to change the place of trial. The affidavit contains the usual affidavit of merits, the statement “ that deponent has fully and fairly stated to defendant’s counsel the facts which he expects to prove by each and every one of the following witnesses, and that each and every one of them is a material and necessary witness for defendant’s defense on the trial of this case, as deponent is advised by his said counsel, and verily believes.” Then follow the names and places of residence of the witnesses and a statement of facts which…