In American Home Products v. Adriatic Ins. Co., 286 N.J. Super. 24, 668 A.2d 67 (App. Div. 1995), the Court placed the initial burden on the moving party to establish that: (1) there is a first-filed action in another state; (2) both cases involve the same parties, the same claims and the same legal issues; (3) the plaintiff will have the opportunity for adequate relief in the prior jurisdiction. Id. at 37, 668 A.2d 67. Once these requisites have been established, the moving party enjoys a "clear entitlement to comity-stay relief" and the burden falls upon the plaintiff to demonstrate that "special equities" exist that are sufficiently compelling to permit the action to proceed. Ibid.