Defendant moves the court for an order making _______ a party defendant herein; directing that process be issued and served upon defendant _______ and requiring plaintiff to serve and file an amended complaint, and for grounds therefor shows:
1. This is an action for [state briefly the nature of the claim for relief.]
2. [State facts showing that a person needed for just adjudication has not been joined as a defendant.]
3. The said __________ is a citizen and a resident of , is subject to the jurisdiction of this court as to both service of process and venue, and can be made a party defendant herein without depriving the court of jurisdiction.
____________________,
Attorney for Defendant.
Address: ____________
Ala. R. Civ. P. Form 36