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Among the other Pahlavi factors that support dismissal is the presence of substantially, all the witnesses and evidence in India. Contrary to plaintiff's argument that the stock transfer agreement is unambiguous and there is no need for parol evidence, as the motion court found, issues of fact exist as to the authenticity of the agreement, which defendant claims is a forgery. There is also a potential for prejudice and hardship to defendant posed by the continuation of the New York action, most significantly, as indicated, the possibility of inconsistent judgments.