§ Form35 Motion by Plaintiff to Add Defendant

Form35. Motion by Plaintiff to Add Defendant.

    Plaintiff moves the court for an order making __________ a party defendant herein and directing the issuance and service of process on him, 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 the proposed additional defendant is an indispensable, necessary or proper party defendant].

    3. The said ______ is a citizen and 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 Plaintiff.

Address: _____________________________________.