Defendant moves the court for an order making _______ a party defendant herein; directing that process be issued and served upon defendant _______ and requiring plaintiff to serve and file an amended complaint, and for grounds therefor shows:

1. This is an action for [state briefly the nature of the claim for relief.]

2. [State facts showing that a person needed for just adjudication has not been joined as a defendant.]

3. The said __________ is a citizen and a resident of , is subject to the jurisdiction of this court as to both service of process and venue, and can be made a party defendant herein without depriving the court of jurisdiction.

____________________,

Attorney for Defendant.

Address: ____________