The defendant, ________, requests the plaintiff to admit the following facts:

1. That the Complaint attached hereto and marked as Exhibit A is a true copy of the Complaint which was filed in a proceeding styled “__________ v. _________ in the Circuit Court, State of Alabama, __________ Judicial Circuit, Case No. _______” on or about _______, 19__.

2. That the Judgment attached hereto and marked as Exhibit B is a true copy of the Judgment entered in the proceeding entitled “_________ v. _________, in the Circuit Court, State of Alabama, Judicial Circuit, Case No. _______” on or about , 19__.

3. That _______ who was the plaintiff in the civil action referred to in Requests 1 and 2 above is one and the same person as , the plaintiff herein.

_____________________,

Attorneys for Defendant

[Address]