Sample Dog Bite Request for Admissions from Plaintiff

Below are plaintiffs' sample request for admission in a dog bite case. These are directed to the landlord but can be easily refitted to address the dog's owner.

IN THE CIRCUIT COURT FOR BALTIMORE COUNTY, MARYLAND
Civil Division

EMILY PICKUS :
Plaintiff, 
v.  Case No.: 22-C-17-006028 OT
MARGARET COLLINS, et al. 
Defendants. :

Below are sample requests for admission in a dog bite case from the plaintiff.

PLAINTIFF'S REQUEST FOR ADMISSIONS

TO: STEM PROPERTY COMPANY, LLC D/B/A VICTORY PARK AT TROY, Defendant

FROM: EMILY PICKUS, Plaintiff

Motion to StrikeNow comes Plaintiff Emily Pickus (hereinafter "Plaintiff"), by and through his attorneys, Miller & Zois, LLC, and hereby requests that the Defendant, STEM Property Company, LLC d/b/a Victory Park at Troy respond to the following requests for admission in accordance with the Maryland Rules. Unless otherwise stated the subject matter of these Interrogatories is a dog attack that occurred on April 1, 2017, at the Victory Park at Troy Meadows apartment complex located at 75 Victory Park Drive, Baltimore, Maryland 21230.

INSTRUCTIONS
  1. These Interrogatories are continuing in character so as to require you to file supplementary answers if you obtain further or different information before trial.

  2. Unless otherwise stated, these Interrogatories refer to the time, place, and circumstances of the occurrence mentioned or complained of in the Complaint.

  3. Where name and identity of a person is required, please state full name, home address and also business address, if known.

  4. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and unless privileged, his attorney's. When an answer is made by the corporate defendant, state the name, address, and title of persons supplying the information and making the affidavit, and announce the source of his or her information.

  5. The pronoun "you" refers to the party to whom the Interrogatories are addressed and the parties mentioned in clause (d).

  6. "Identify" when referring to an individual, corporation, or other entity shall mean to set forth the name and telephone number, and if a corporation or other entity, its principal place of business, or if an individual, the present or last known home address, his or her job title or titles, by whom employed and address of the place of employment.

  7. The "dog" mentioned in these interrogatories is the "dog" that attacked the Plaintiff on April 1, 2017, at the Victory Park at Troy Meadows apartment complex located at 875 Victory Park Drive, Salisbury, Maryland 21801.

  8. The term "occurrence" refers to the dog attack referenced in the Complaint that occurred on April 1, 2017, at the Victory Park at Troy Meadows apartment complex located at 875 Victory Park Drive, Salisbury, Maryland 21801.

  9. The term "attack" includes but is not limited to "jumping on the plaintiff."

  10. For purposes of these interrogatories, the terms "custody, dominion and control" and "ownership, maintenance, dominion or control" shall refer to the entity responsible for creating and/or enforcing rules and policies regarding whether a dog should be on a leash if it is taken outside an apartment at Victory Park at Troy Meadows.

    More Dog Bite Discovery
REQUESTS FOR ADMISSIONS
  1. Admit that the premises where the occurrence took place were under your ownership, maintenance, dominion, or control at the time of the occurrence.

  2. Admit that you were the owner of the premises at the time of the occurrence.

  3. Admit that Margaret Gruber was a tenant at Victory Park at Troy Meadows on April 1, 2017, at the time of the occurrence.

  4. Admit that at the time Margaret Gruber signed her lease agreement with Victory Park at Troy Meadows and/or with any of the other Defendants to this action she was not advised of the requirement to have renters insurance if she were to own and/or possess a dog on the premises at Victory Park at Troy Meadows.

  5. Admit that at the time Margaret Collision signed her lease agreement with Victory Park at Troy Meadows and/or with any of the other Defendants to this action she was not advised of a requirement to keep her dog on a leash if taking her dog outside her apartment.

  6. Admit that at the time of occurrence on April 1, 2017, the apartment complex known as Victory Park at Troy Meadows did not have a requirement that tenant shall keep their dog on a leash if taking their dog outside their apartment.

  7. Admit that at the time of the occurrence on April 1, 2017, the apartment complex known as Victory Park at Troy Meadows did not warn and/or caution tenants to keep their dog on a leash if taking their dog outside their apartment.

  8. Admit that at the time of the occurrence on April 1, 2017, the apartment complex known as Victory Park at Troy Meadows did not post any signs on their premises warning and/or cautioning tenants to keep their dog on a leash if taking their dog outside their apartment.

  9. Admit that at the time of the occurrence on April 1, 2017, you had previously received complaints regarding tenant Margaret Gruber taking her dog outside her apartment without a leash.

  10. Admit that on April 1, 2017, tenant Margaret Gruber did not have her dog on a leash at the time of the occurrence.

  11. Admit that on April 1, 2017, tenant Margaret Gruber' dog was outside her apartment at the time of the alleged occurrence.

  12. Admit that you do not have any videotape footage of the occurrence on April 1, 2017.

  13. Admit that attack caused Plaintiff pain.

  14. Admit that the dog in question bit Plaintiff.

  15. Admit that Plaintiff has a permanent scar on her face as a result of the attack that is the subject of this lawsuit.

  16. Admit that Plaintiff spent 9 days in the hospital after the attack that is the subject of this lawsuit.

  17. Admit that Plaintiff suffered nerve damage in her right arm that limits her ability to work as an accountant.

  18. Admit that you cautioned tenants to keep their dog on a leash when taking the dog outside their apartment

  19. Admit that on April 1, 2017, Ms. Collins did not have Ms. Collins' dog on a leash at the time of the occurrence.

  20. Admit that on April 1, 2017, Ms. Collins' dog was outside her apartment at the time of the alleged occurrence.

  21. Admit that you were aware that Ms. Collins' dog should have been on a leash at the time of the occurrence on April 1, 2017.

  22. Admit that you were aware that Ms. Collins' dog should be on a leash if outside your apartment on April 1, 2017

  23. Admit that on April 1, 2017, Ms. Collins' dog attacked the Plaintiff knocking her to the ground.

  24. dog bite law in Maryland
  25. Admit that on April 1, 2017, Ms. Collins' dog jumped on the Plaintiff knocking her to the ground.

  26. Admit that on April 1, 2017, your agent witnessed the Plaintiff laying on the ground after Ms. Collins' dog jumped on her.

  27. Admit that on April 1, 2017, your agent witnessed the Plaintiff lying on the ground outside your apartment.

  28. Admit that on April 1, 2017, at the time you saw the Plaintiff lying on the ground outside your apartment your agent saw Ms. Collins' dog standing nearby and/or in the vicinity of the Plaintiff.

Respectfully submitted,
MILLER & ZOIS, LLC

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