United States v. Estrada, 2012 WL 3083477

Indictment in SDNY charges Franklin Estrada and Igor Royzman in a three-count case: conspiracy to commit mail and wire fraud (Count One) and substantive mail and wire fraud (Counts Two and Three).
Scheme alleged: California-based defendants distributed pills titled as natural erectile dysfunction remedies that contained sildenafil analogues (a Viagra active ingredient).
Estrada moved to transfer venue to the Central District of California under Rule 21(b), arguing convenience and witness location; the government opposed.
Defendants are based in Los Angeles; events and defense witnesses/documents largely California-based; the government maintains witnesses and documents are located in New York.
Court conducted a Platt v. Minnesota Mining & Manufacturing Co. factor balancing and denied transfer, keeping the case in New York; trial anticipated to last 1–2 weeks.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the interests of justice require transfer under Rule 21(b).	Estrada argues transfer is warranted due to witnesses, defense counsel, and events largely in California.	Royzman/Estrada contend California as the nerve center; convenience favors transfer.	Transfer denied; original district retained.

United States v. Maldonado-Rivera, 922 F.2d 934 (2d Cir.1990) (balancing factors in transfer determinations; no single factor controlling)
Posner, 549 F.Supp. 475 (S.D.N.Y.1982) (general rule favoring retention; transfer appropriate in limited circumstances)
U.S. Steel Corp., 233 F.Supp. 154 (S.D.N.Y.1964) (district court guidance on burdens of transfer decisions)
Spy Factory, Inc., 951 F.Supp. 450 (S.D.N.Y.1997) (nationwide scheme factor; some factors mitigate transfer tendency)
Datta, 797 F.Supp.2d 448 (S.D.N.Y.2011) (burden on defendant to show interests of justice require transfer)
Stephenson, 895 F.2d 867 (2d Cir.1990) (court upheld denial of transfer when burdens favored the district of indictment)