Plaintiff moves the court for an order compelling defendant to answer Interrogatories Nos.____, _____, and ________ heretofore served on defendant by plaintiff on the ____ day of ____, 19__, which defendant has failed to answer. [A copy of the interrogatories propounded and of defendant's answers and failures to answer thereto is attached as Exhibit A.]
____________________,
Attorney for Plaintiff
Office and P. O. Address,
Ala. R. Civ. P. Form 49
Committee Comments
The bracketed material may be utilized at the pleader's option. It is not necessary to make such an attachment since the material is already on file. However, it may facilitate court review of the motion.