IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT,
IN AND FOR BROWARD, FLORIDA
CASE NO. 00xxxx (xx)
P.A.,
Plaintiff,
v.
J.D.,
Defendant.
____________________________/
COMPLAINT
The Plaintiff, P.A., sues the Defendant, J.D. (hereinafter “J.D.”) and alleges:
1. This is an action for damages in excess of $15,000.00, exclusive of costs, interest, and attorney’s fees.
2. As of [date], J.D. owned a dog in Broward County, Florida.
3. On [date], Plaintiff, P.A., was attacked and bitten by the dog owned by J.D.
4. Pursuant to F.S. §767.04, J.D. is strictly liable for any damages to P.A.
5. As a result of the dog bite, the Plaintiff, P.A., suffered permanent bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn money, and/or permanent aggravation of a pre-existing condition. As the injuries are permanent, Plaintiff will continue to suffer damages in the future.
WHEREFORE, Plaintiff, P.A., demands judgment for compensatory damages against the Defendant, J.D., and further demand a trial by jury of all issues so triable.
SACKRIN & TOLCHINSKY, P.A.
Attorney for Plaintiff(s)
2100 East Hallandale Beach Blvd.
Suite 200
Hallandale Beach, FL 33009
Telephone: (954) 455-0800
Facsimile: (954) 455-9649
By______________________________
ALAN D. SACKRIN
Florida Bar No. 349070
The above pleading is a sample of Alan Sackrin’s 30+ years of personal injury litigation experience. A dog bite lawyer who will make sure you are collecting all of the damages that you are entitled to for your claim. To learn more about Alan Sackrin and his qualifications, click on this link.
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The pleading above is a sample document related to a specific set of facts and circumstances and should not be used or relied upon for any personal injury matter. We recommend and urge you to consult with an experienced personal injury lawyer for professional advice as each case is unique.