________ moves the court for leave to take the deposition of , who is confined in the _______ at _______.
The ground of this motion is that said _______ has knowledge of relevant and material facts and that his testimony is necessary to _______in preparing for trial, as more particularly appears from the affidavit of_______ attached hereto as Exhibit A.
Attorney.
Ala. R. Civ. P. Form 45