of the New York courthouse, and he would, in most cases be forced to prove his defenses through depositions.


33
Recognizing inconvenience of trial in New York courts as a vulnerable point in its argument, the majority seeks to offset it by the following a fortiori argument:


34
'But the Justice's final consideration-- the plaintiff's difficulty in bringing the defendant before the forum-- applies with even greater force to the state of plaintiff's residence than to that of injury in light of the development of long-arm statutes that will generally allow the state of injury to obtain personal jurisdiction of the insured and so avoid the need for a direct action against the insurer.'


35
Every plaintiff, however, is not entitled to a legal remedy in the form of a device to bring thestate, who had never resided elsewhere and who had never entered the State of New York or had any business there, suddenly to discover that he is under the jurisdiction of the State of New York and must go there to defend himself is quite a different matter.  It is apparent from the Supreme Court's opinion in Watson, that 'plaintiff's difficulty in bringing the defendant before the forum' is manifestly unjust only because the forum in question is 'the most convenient forum.'  To repeat the passage under discussion:


36
'Moreover, Louisiana courts in most instances provide the most convenient forum for the trial of these cases.  But modern transportation and business methods have made it more difficult to serve process on wrongdoers who live or do business