Defendant, __________, makes the following statement in response to the requests for admissions served upon him by plaintiff on _______,19__.
Request No. 1: Defendant cannot truthfully admit or deny the matter set forth in Request No. 1 for the reason that [set forth reasons].
Request No. 2: Defendant admits [set forth admitted matter], as set forth in Request No. 2, but denies that [set forth matters denied].
Request No. 3: Defendant denies the truth of the matter set forth in Request No. 3.
_____________________,
Attorney for Defendant.
Address: ____________
Ala. R. Civ. P. Form 60