Pennsylvania Injury Lawyer Talks About Dog Bite Injuries

Dog bite injury claims are common. Here is a sample complaint you can use for such a claim.

1. Plaintiff, Selma Smith is an adult individual who resides at the address indicated in the caption.

2. Defendant, Robert Jang is an adult individual with an address for service of process as indicated in the caption.

3. Defendant, Rosalind Jang is an adult individual with an address for service of process as indicated in the caption.

4. On or about March 23, 2002 defendants owned, directed, supervised and controlled a certain German Shepherd which was at all relevant times under their ownership, direction, supervision and control.

5. On the aforesaid date, plaintiff was walking in her neighborhood, walked slowly over to defendant, Robert Jang, at which time she was set upon by the defendants' vicious German Shepherd which violently attacked and bit her, chewed on her leg, knocked her to the ground and causing her to suffer severe and disfiguring injuries, as more particularly hereafter set forth.

6. The aforesaid attack was caused solely and exclusively by the negligence of the defendants and was due in no manner whatsoever to any act or failure to act on the part of the plaintiff.

7. The negligence, carelessness and recklessness of the defendants consisted of the following:

(a) Maintaining a public nuisance;

(b) Failing to warn the plaintiff that the defendants' German Shepherd had vicious propensities;

(c) Failing to physically restrain the German Shepherd;

(d) Failing to properly leash and/or chain the German Shepherd;

(e) Allowing the German Shepherd to break loose in a public place where a pedestrian could be expected to be;

(f) Failing to remove the German Shepherd after notice of the German Shepherd's vicious propensities;

(g) Failing to give notice to plaintiff of the German Shepherd's vicious propensities particularly where defendant, Robert Jang knew that plaintiff was close by;

(h) Violation of the applicable statutes relating to German Shepherds and other dogs;

(i) Negligence as a matter of law;

8. At all times material hereto and at the time and place aforesaid, plaintiff was tending to her own affairs on a public walkway and she in no way enticed or otherwise harassed the said German Shepherd.

9. As a result of the defendants' negligence, the plaintiff sustained serious injuries to her head, body and limbs, more specifically, she suffered: severe dog bite puncture wounds, swollen and infected right leg, a general feeling of malaise, and she was otherwise injured.

10. As a further result of the defendants' negligence, plaintiff has been obliged to expend various sums of money or incur various expenses for medicine, medical care and treatment in an effort to cure herself of the injuries she has suffered, and she will be obliged to continue to do so for an indefinite time in the future all of which is to her great financial detriment and loss.

11. As a result of the defendants' negligence, the plaintiff has been unable to attend to her usual duties and occupations and will be unable to do so for an indefinite time in the future all of which is to her great financial detriment and loss.

12. As a further result of the defendants' negligence, the plaintiff has undergone great physical pain and mental anguish, and will continue to endure the same for an indefinite time in the future, all of which is to her great financial detriment and loss.

WHEREFORE, plaintiff, Selma Smith demands judgment in her favor and against the defendants, Robert and Rosalind Jang in an amount not in excess of $50,000.00, together with the costs of this suit.