Defendant moves the Court for an order that the genuineness of the documents and the truth of the matters of fact, admissions as to which are requested in the Request for Admission, marked Exhibit A and annexed hereto, shall be deemed admitted unless plaintiff files and serves his response to said request within ____ days after service of said request on him, on the ground that if defendant is required to prove the genuineness of such documents and the truth of such matters of fact, he will be put to considerable difficulty and expense in doing so, and such difficulty and expense will be even greater if he does not commence preparations to make such proof before ____, 19__, for the reasons that [set forth reasons], all as more fully appears in the affidavit of ____, marked Exhibit B and attached hereto.

______________________,

Attorney for Defendant,

Address: _____________.