IN THE CIRCUIT COURT OF THE
CASE NO. 00xxxx (xx)
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.
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