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Sample Dog Bite Interrogatories


Sample Dog Bite Interrogatories

In California, the victim of a dog bite may take legal action based on dog bite law as well as common law negligence but will need to prepare a case proving liability and damages. Dog bite interrogatories are used in trial preparation. In this article, a California dog bite lawyer provides sample dog bite interrogatories.



What Are Dog Bite Interrogatories?

Under California Civil Code section 3342, dog owners are declared “liable for the damages suffered by any person who is bitten by the dog while in a public place or lawfully in a private place, including the property of the owner of the dog, regardless of the former viciousness of the dog or the owner's knowledge of such viciousness.”  Essentially, this means that the owner of a dog is always responsible for any and all injuries that are caused by that dog regardless of whether the owner knew the dog was dangerous. 



Victims of a dog bite incident or a dog attack can take legal action against the dog’s owner based on the provisions of the law in section 3342.  Dog bite victims may also take legal action based on the negligence of the dog’s owner in knowingly harboring a vicious or dangerous dog. 



Regardless of how a dog bite victim seeks to pursue a claim against the dog’s owner, the dog bite victim will be responsible for proving his or her case and right to obtain damages. This can involve gathering evidence and questioning witnesses. 



One tool that is used in preparing a case that helps both plaintiffs and defendants to obtain more information is called an interrogatory.  An interrogatory is a set of written questions that is prepared by an attorney. The interrogatory is submitted to someone, such as a witness or the defendant or plaintiff in the case, and the interrogatory must be answered under oath.  



Interrogatories are a written alternative to depositions (oral interviews asking questions under oath of those involved in a case). Interrogatories can be a less expensive way than depositions to obtain necessary information and to get someone on the record about his or her story. While the downside of interrogatories is that no follow-up questions can be asked immediately in regard to the written responses, interrogatories are an important investigative tool in obtaining basic information necessary for preparing any type of legal case.  



Sample Dog Bite Interrogatories

Dog bite interrogatories ask questions that are designed to help uncover information about the events that occurred surrounding the bite incident; the actions of the victim; and the knowledge and actions of the dog’s owner.  Some of the different types of questions that may be asked in an interrogatory include the following:


  • Is the defendant the owner of the dog that bit the complainant? If not, please state the name and contact information of the dog’s owner. 
  • Please state the name of the dog. 
  • Please describe the breed, color, age and any other characteristic features of the dog in question. 
  • Please state the name and contact information of any veterinarians with records pertaining to the dog described in the complaint. 
  • Has the dog that is the subject of this interrogatory bitten any other persons during the animal’s lifetime? If the answer to this question is in the affirmative, please provide the date of the incident; the name and address of the victim; and the place and circumstances of the bite or attack. 
  • Has any person, including the defendant, been sued for any bites/ attacks involving the named dog other than the incident alleged in this complaint. If so, please provide the date of filing of each past lawsuit; the name and contact information of the plaintiff and defendant; the case number; and the disposition of the case including the amount of any verdict or settlement. 
  • Does the defendant own the residence or location where the alleged bite incident occurred? If not, please provide the name and contact information of the owner of the property. 
  • Please state the name of the defendant’s homeowner’s liability insurance company. Please provide the policy number and policy limits related to occurrences such as the dog bite incident alleged in the complaint


These questions would be appropriate on an interrogatory intended for the defendant in the lawsuit or for a witness with information about the defendant and dog. 


Different interrogatories have different questions depending upon the type of information sought. For example, an interrogatory containing questions for a veterinarian or trainer familiar with the dog would differ from an interrogatory seeking information from a neighbor who witnessed the dog attack. The attorney representing you in your California dog bite case will draft interrogatory questions that can be used to interview specific witnesses with information relevant to your claim.  


Additional information on the civil claims process following a dog bite is available to the public free of charge through our office’s Preferred Friends and Clients Program.


If you would like to request a free article, or to discuss a specific legal matter with a California dog bite lawyer, feel free to call 866-981-5596. 


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