I am filing a notice of motion for change of venue in a traffic trial

[bigbadjohn]

I recently set a trial for a speeding citation that I received and I am filing a notice of motion for change of venue based on the grounds of "Convenience of Witness and the Ends of Justice". I live 150 miles from the city where I received the speeding citation. I understand that both conditions in this statute and in the motion must be met before a motion can be granted. Thus the moving party (me) has the burden of proving that both the convenience of witness(s) (me) and the ends of justice will be promoted by a change of venue.

The first part of my declaration of motion, that of convenience is based on the fact that it would be extremely inconvenient for the witness/defendant (me) to appear and give his testimony in the current appointed court due to costs of travel, loss of time at work and family obligations.

As far as the "Ends of Justice being Promoted" part, I seem to be having some difficulty coming up with a legitimate sounding reason as to why my motion for change of venue would serve the ends of justice.

I was considering stating that the ends of justice would be served because the witness for the prosecution (the citing police officer) works and lives in the same town that the trial will be held. Thus the potential exists that the officer may have a casual association with the prosecution/Asst. D.A. which may allow for the possibility of an impartial and/or biased hearing and that a trial heard in a neutral city within the SAME county (in this case the county seat) would promote a more fair and impartial trial.

What do you think of this strategy, and/or do you have any better ideas or reasons why a transfer would promote the ends of justice?

Also is it appropriate to request a change of venue within the same county?

P.S. The clerk at the court house told me that "they don't do this for traffic trials" but I told her that it was my constitutional right, so she stepped away and asked her supervisor, came back and said I could file a change of venue if I wanted to but that "they never do this". Do you think I am wasting my time?
In my favor if the transfer is granted it is very possible that the cop may not show for a trial in another town.

[annjd]

I am not sure you will prevail on this? Where are you trying to move it to?

if this request for change of venue was not made during the answer or any other responsive pleadings it may be cosidered waived. If you can prove that the witness is your only defense and anything else that would arise from not having the trial in your venue then include information accordingly. I am not an attorney and you should consult an attorney for any legal advice.