Memorandum in support of motion

[Name]

[Address]

[Phone number]

Attorney for [moving party]

UNITED STATES DISTRICT COURT

FOR THE ___________ DISTRICT OF __________

Civil Action, File Number _________

__________________________________________

) [PARTY’S]

[Name], ) MEMORANDUM IN

Plaintiff, ) SUPPORT OF

) MOTION TO CURE

v. ) DEFAULT FOR FAILING

) TO SERVE TIMELY

[Name], ) RESPONSES TO REQUESTS

Defendant. ) FOR ADMISSION

__________________________________________)

INTRODUCTION

[Moving party] submits this memorandum in support of its Motion to Cure Default for Failing to Serve Timely Responses to Requests for Admission. [Moving party] requests that the Court accept its tardy responses and withdraw any admissions resulting from the late responses pursuant to FRCP 36(b).

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