Fill and Sign the Montgomery County Circuit Court of Alabama State of Form

IN THE CIRCUIT COURT OF _______ COUNTY, ALABAMA__________________, **Plaintiff,**vs. *CIVIL ACTION NO.:*_________________________, * CV-______et al., **Defendants.*PLAINTIFF=S MOTION TO COMPEL ISSUANCE OF HER NON-PARTY SUBPOENA TO ____________________________________ COMES NOW Plaintiff, by and through counsel, and moves this Court to allow issuance of Plaintiff=s non-party subpoena to _______________________________, and in support hereof, Plaintiff does say as follows: 1.Plaintiff=s undersigned counsel filed a notice of intent on April 13th to serve ________________________________, a non-party in these matters, with a subpoena fifteen (15) days after the notice, if not objected to by the Defendants OR _____________.2.Plaintiffs did not serve a subpoena on _____________ it contends, asPlaintiffs did not have the power to do that; only the Court can ready the subpoena for issuance.3.Plaintiffs merely served a copy of the notice on the non-party to give it anopportunity to object, because it is Plaintiffs= position that Ala.R.Civ.P. 45 (a)(3)(B) requires Plaintiffs to do so. This section provides as follows: AAny person or party may serve an objection to the issuance of a subpoena for production.... @4.As to _____________=s general objections to the information being supplied to the Plaintiffs, this Court has not held the information non-discoverable, but alternatively held that the Defendant _______ was to give Plaintiffs similar information as a Defendant. 5. Plaintiff seeks documents from _____________ as to the agents involved in this case because they were/are agents in Alabama for that company as well. A pattern of the same type of alleged misrepresentations by the agents when selling the same or similar type of policies for _____________ is relevant and discoverable.WHEREFORE, Plaintiffs respectfully request that this Court grant this their Motion to Compel, and Order the issuance of the non-party subpoena to _______________________________ for the documents Plaintiff has requested. JOHN DOE & ASSOCIATES, P.C Attorneys for PlaintiffPost Office Drawer ____Mobile, Alabama _____(334__________BY:______________________________________Plaintiff=s counselcounsel=s numberRichard F. PatePAT020 CERTIFICATE OF SERVICE I hereby certify that I have on this _____ day of April, 1999, forwarded a copy of the foregoing by United States Mail, first class postage prepaid, and properly addressed to the following:Defense counsel listed here __________________________________ Plaintiff=s counsel