This article discusses those situations where a defendant in an originally and properly venued case seeks to implead a public entity as a third-party defendant and how such a public entity may seek to change such venue.
Section 504(1) of CPLR provides that the venue of an action against a county shall be in that county. “The purpose of the venue requirement is to protect governmental entities from inconvenience.” Powers v. East Hudson Parkway Auth., 428 N.Y.S.2d 233 (1st Dept. 1980). To that end, §504(1) creates a “strong presumption of venue” once invoked by a municipality. Ruiz v. City of New York, 599 N.Y.S.2d 822 (1st Dept. 1993).
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