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Smith v. CMS West, Inc., 2023 Pa. Super. LEXIS 507 (October 30, 2023) (Stabile, J.) Distance alone can be a factor. This case was transferred from Philadelphia to Butler County, where the incident occurred. There were many witnesses, and the court found that the distance from Philadelphia to Butler County was just too far, given all the people involved and the location of the incident. Further, the court said that enough discovery had been conducted. The plaintiffs wanted to do more discovery on venue and the court said that reasonable limits had been set on that and no more discovery was necessary and failure to provide more discovery was not an abuse of discretion.