Cardello-Smith v. Combs

The court transferred the action to the United States District Court for the Eastern District of Michigan under 28 U.S.C. § 1404(a) for the convenience of parties and witnesses, and in the interest of justice. The court found the plaintiff's attempt to style the action as a 'Notice of Removal' improper, as removal is only available to defendants and applies to state court actions, not federal ones. The transfer was deemed appropriate due to a substantially similar action already pending in the Eastern District of Michigan, the plaintiff's residence outside the Southern District of New York, and operative events occurring at least partly in Michigan.