Plaintiff shows the courts 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 as Exhibit A.]

2. On ____, 19__, the Plaintiff moved for determination of the sufficiency of Defendant’s answers of _____, 19__, and on _____, 19__, this court entered an order requiring Defendant to amend his answers of _____,19__.

3. On _____, 19__, the Defendant served on Plaintiff his amended answers, [a copy of which is attached as Exhibit B]. Said amended answer also contains no specific denial of the matters of which an admission was requested of the Defendant nor does it set forth the reasons why Defendant cannot truthfully admit or deny these matters.

Wherefore, Plaintiff moves the Court for an order establishing as admitted the said facts set forth in Paragraph 1 above.