Samuel Penurio was president of a community bank in a small town. He was well thought of in the community, but he was known to drink to excess occasionally.

One June evening his bank hosted a cocktail party. About 10:00 P.M., after the party was over, Penurio offered to drive his secretary home. Each had drunk several cocktails. En route to her home, Penurio drove through an intersection controlled by a signal light. His car crashed into a car of four students who had just left their high school football game. One student, the popular head female cheerleader, died as a result of the injuries she received from the accident. Penurio’s blood-alcohol level was 1.0. He was charged with vehicular homicide, which carries a maximum punishment of life imprisonment. Penurio and his secretary claim that he drove through the intersection just as the light was changing and that the car occupied by the students drove through the intersection at an excessive rate of speed. The driver of the students’ car had not been drinking, and the surviving students all say Penurio drove through the red light. The local newspaper ran a front-page story with pictures of the students holding a school-wide memorial service for the deceased cheerleader, describing the students’ version of the accident, and pointing out that Penurio had been convicted of DWI just a year earlier. Over the next several days, the newspaper and the local radio station carried adverse comments from their readers and listeners about Penurio’s conduct. Penurio’s counsel has filed a motion for a change of venue. Do you think it likely the court will grant the motion? What, if any, additional information should be sought to support the motion?