Defendant moves the Court for an order extending to the ____ day of ________, 19__, the time within which defendant may reply to the request for admission of facts and of genuineness of documents served upon him by plaintiff on ________, 19__, on the grounds that [here, state particular facts giving rise to the need for more time.]
________________________,
Attorney for Defendant,
Address: _______________
Ala. R. Civ. P. Form 59