439. The motion must, in addition to the designation of the applicant and of his eventual opponent, contain:(a) a statement of the facts which make a legal proceeding seem likely, and its nature;
(b) the reasons for which the applicant fears that the evidence may be lost or become more difficult to present;
(c) the names and addresses of the witnesses to be heard, the facts upon which they will be questioned, the description and location of the thing to be examined, the purpose of the examination, and the names and address of the person who is to make it.