This sample motion for withdrawal of deemed admissions under Rule 36(b) in United States District Court is filed on the grounds that the failure to serve timely responses to the requests for admission was excusable, that granting the motion will promote the presentation of the merits of the action and will not unreasonably prejudice the opposing party. The sample on which this preview is based is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail.