Defendant moves the Court to enter, pursuant to Rule 56 of the Alabama Rules of Civil Procedure, a summary judgment in the Defendant’s favor dismissing the action (or count; paragraph of complaint) on the ground that there is no genuine issue as to any material fact and that the Defendant 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: _____________________.