Beverage Marketing Corp. v. Emerald Coast Spring Water Co.
Plaintiff Beverage Marketing, an Ohio corporation, initiated an action in the Southern District of New York seeking a $100,000 finder's fee for an alleged breach of contract against defendants Emerald Coast Spring Water, a Florida corporation, and its former CEO, Gibson. The defendants moved to transfer the case to the Northern District of Florida under 28 U.S.C. § 1404, primarily arguing that crucial non-party witnesses were unavailable in New York but compellable in Florida. The court, presided over by Judge Edelstein, denied the motion, finding that the defendants failed to adequately demonstrate the necessity or unavailability of these witnesses in the chosen forum, and that the balance of convenience did not sufficiently outweigh the plaintiff's choice of forum.