Sample Dog Bite Complaint

{LAW FIRM NAME}
{Address}
{City}, {State} {ZIP}
{Telephone:}
{Facsimile: }

{Lawyer Name (Bar No.)}
Email: {}

Attorney for Plaintiff

In the Superior Court of the state of Arizona
In and for the County of Maricopa

Plaintiff, by and through counsel undersigned, and for [his/her] Complaint against Defendants, alleges as follows:

PARTIES, JURISDICTION AND VENUE

1. Plaintiff __________ is and was a resident of Maricopa County, Arizona at all relevant times.
2. Defendants __________ and [John/Jane] Doe __________ are now and were residents of Maricopa County, Arizona, and married to each other as husband and wife. All acts, errors and/or omissions complained of and material were for and on behalf of the marital community.
3. Defendants John Does and Jane Does 1-10, ABC Corporations 1-10, Limited Liability Companies and/or partnerships 1-10 are persons and entities whose true identities are unknown to Plaintiff, who together with named Defendants contributed to causing Plaintiff’s injuries and damages. Plaintiff will amend [his/her] Complaint when the true names of those Defendants become known.
4. Jurisdiction and venue are proper as the events giving rise to Plaintiff’s Complaint occurred in Maricopa County, Arizona and the amount in controversy exceeds the minimal jurisdictional requirements of this Court.
5. The amount of Plaintiff’s damages qualifies this matter as a Tier [1, 2 or 3] case in accordance with Rule 8(b)(2) of the Arizona Rules of Civil Procedure. 

GENERAL ALLEGATIONS

6. Plaintiff incorporates by reference all prior allegations contained in this Complaint.
7. On or about _____________, at approximately _____, Plaintiff, who was in the course and scope of his employment as a mail carrier with the United States Post Office, was delivering a package to the Defendant’s residence located at ______________________ in, __________, Arizona. Plaintiff rang the doorbell to Defendant’s home and as Defendant opened the door, Defendant’s dog viciously attacked and bit the Plaintiff.
8. On or about _____________, at approximately _____, Plaintiff, who was walking on the public sidewalk in front of Defendant’s residence located at ______________________ in, __________, Arizona, was viciously attacked and bit, without warning, by Defendant’s dog who was under the ownership and control of Defendant.]
9. On or about _____________, at approximately _____, Plaintiff, who was walking in a public park located at ______________________ in, __________, Arizona, was viciously attacked and bit, without warning, by Defendant’s dog who was under the ownership and control of Defendant.]
10. On or about _____________, at approximately _____, Plaintiff, a social guest, who was visiting the Defendant’s residence located at ______________________ in, __________, Arizona, was viciously attacked and bit, without warning, by Defendant’s dog who was under the ownership and control of Defendant.]

COUNT ONE – NEGLIGENCE

11. Plaintiff incorporates by reference all prior allegations contained in this Complaint.
12. Defendant owed Plaintiff a duty of care to control and/or supervise their dog.
13. Defendant breached [his/her] duty of care owed to Plaintiff when [he/she] failed control and/or supervise their dog, which resulted in it attacking and biting Plaintiff.
14. Plaintiff’s injuries from the dog attack were caused solely by the negligence of Defendant without any negligence or contribution on the part of the Plaintiff.
15. As a direct and proximate result of Defendant’s negligence, Plaintiff suffered serious bodily injuries, scarring, disfigurement, pain and suffering, anxiety, emotional anguish, loss of enjoyment of life and other damages.

COUNT TWO – NEGLIGENCE PER SE

16. Plaintiff incorporates by reference all prior allegations contained in this Complaint.
17. At all relevant times, Defendant owed a duty to comply with applicable statutes, regulations and rules related to dog bites in the State of Arizona.
18. Defendant breached this duty when [he/she] failed to comply with such statutes, regulations and rules regarding dog bites, as required by A.R.S. § 11-1025(A).
19. Plaintiff was, at the time of the attack, within the class of persons whom the above-referenced statutes were meant to protect.
20. Defendant’s failure to comply with the above-referenced statute created the type of attack against which the law was designed to protect.
21. Defendant’s failure to comply with the above-referenced statutes was the direct and proximate cause of Plaintiff’s injuries and damages and thus constitutes negligence per se.

DEMAND FOR JURY TRIAL

22. Plaintiff demands a trial by jury on all issues so triable.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff requests that the Court enter judgment against Defendant as follows:

1. For Plaintiff’s general and special damages;
2. For Plaintiff’s costs incurred in pursuing these claims;
3. For pre- and post-judgment interest to the extent provided by law;
4. For such further relief as the Court deems just and fair.

DATED this ____ day of _____________, _____.