In Woods v. Berry (1931) 111 Cal.App. 675, an action was filed in Shasta County. Three defendants, all San Francisco residents, separately moved to transfer venue to San Francisco. All defendants had demurred and two had filed answers; the third, Berry, had not. Plaintiff filed a countermotion to retain venue in Shasta County based on convenience of witnesses. (Id. at p. 681.) This court found Berry's motion for transfer should have been granted, despite his bankruptcy. (Id. at p. 680.) The Woods court declined to consider the transfer motions filed by the two answering defendants. (Woods, supra, 111 Cal.App. at p. 683.) Nor did it address the argument that the answers of these defendants were filed only to follow the then prevailing rule requiring an answer at the same time as the demurrer, so the answers should not open the door to a countermotion based on the convenience of witnesses. (Ibid.) In Woods, the Court held the motion to transfer by defendant Berry, who had not filed an answer, should have been granted, notwithstanding the countermotion by plaintiffs. (Woods, supra, 111 Cal.App. at p. 681.)