Plaintiff moves the Court to enter, pursuant to Rule 56 of the Alabama Rules of Civil Procedure, a summary judgment in Plaintiff’s favor for the relief demanded in his complaint (or count one, etc. of the complaint) and for grounds of his motion says that there is no genuine issue as to any material fact and that the Plaintiff is entitled to a judgment as a matter of law.

This motion is based upon the [pleadings] [deposition of ______] [request for admissions and response thereto] [answer to interrogatories] [the affidavits of J.K. and L.M.].

________________________,

Attorney for Defendant.

Address: ______________________.