§ Form61 Motion to Determine Sufficiency of Answers to Request for Admissions and for Order That Facts Be Taken as Established

Codes > Alabama Rules of Civil Procedure > Appendix I > Form61 Motion

Form61. Motion to Determine Sufficiency of Answers to Request for Admissions and for Order That Facts Be
Taken as Established.

    Plaintiff shows to the court as follows:

    1. On ______, 19___, Plaintiff served on Defendant a request for admission of the following facts:

        (a) _________________________________________________________________________

    _________________________________________________________________________

        (b) _________________________________________________________________________

    _________________________________________________________________________

    [A copy of the request is attached hereto as Exhibit A.]

    2. On ______, 19___, Defendant served on Plaintiff his statement in reply, [and a copy of said statement is attached as Exhibit B]; said statement contains no specific denial of the matters of which an admission was requested of the Defendant nor does it fully admit or deny those matters.

    Wherefore, Plaintiff moves the court that the facts set forth in paragraph 1 be taken as established, or in the alternative, that an amended answer be served.

_______________________________________,

Attorney for Plaintiff

[Address of Attorney for Plaintiff]