Motion to Permit Withdrawal of Deemed Admission

UNITED STATES DISTRICT COURT

FOR A SAMPLE DISTRICT

________________________________

) Case No.:

Peter Plaintiff, )

Plaintiff, )

)

v. )

)

Donald Defendant, )

Defendant )

________________________________ )

Moving Party: ____________

Respondent: _____________

MOTION TO PERMIT WITHDRAWAL OF DEEMED ADMISSION

The Moving Party hereby requests that this honorable court issue its order permitting it to withdrawal and expunge from the record in this cause a deemed admission entered on behalf of the Moving Party for the following reasons:

1. On or about the ______ day of ______________, 20____, the Proponent in this action did submit a set of Requests for Admissions to your Movant, which the Movant acknowledges receiving.

2. In conjunction with the applicable court rules, the responses to the Requests were due ______ days thereafter.

3. Due to excusable inadvertence, the Moving Party failed to provide a timely response to the Requests for Admissions.

4. Of the Requests for Admissions submitted by the Proponent, the following requests would certainly have been denied had...