Here is a blueprint for the investigation of attacking dogs:
People who should be interviewed:
- Breeder of the dogs.Trainer of the dogs (obedience, agility, protection, service and aggression).
- Behaviorist consulted in connection with the dogs.
- Former owners of the dogs.
- Mail carriers who deliver mail to the residence of the dogs, including the supervisors.
- UPS deliverymen who pick up and deliver packages to the residence of the dogs.
- Gas company workers who provided services at the residence of the dogs.
- Water company workers who provided services at the residence of the dogs.
- Electrical company workers who provided services at the residence of the dogs.
- Telephone company workers who provided services at the residence of the dogs.
- Heating and plumbing company workers who provided services at the residence of the dogs.
- Gardeners who provided services at the residence of the dogs and each adjacent residence north, west, east and south.
- Tree trimmers who provided services at the residence of the dogs and each adjacent residence north, west, east and south.
- Neighbors on each side of the residence of the dogs, behind the residence (on the next block), and across the street.
- Baby sitter.
- Pet sitter or dog sitter.
- Dog walker.
- Kennel where the dogs were boarded.
- Homeowners association. There may be numerous complaints on record about these dogs.
- Police officers, especially patrol officers.
- Private patrol officers, security guards and employees of security company, including supervisors.
- Veterinarian and staff.
- Animal hospital and staff.
- Animal emergency facility and staff.
- Dog groomer.
- Other people who walk dogs in the same neighborhood or the local park or dog park.
Here are the documents that should be obtained:
- Animal control department records.Police department records.
- Post office notices that the dogs (or any of them) are dangerous and mail will not be delivered.
- Complaints to homeowners association.
- Complaints to private patrol company or security company.
- Records of veterinarians and staff.
- Lawsuits pertaining to injuries inflicted by the dogs (or any of them).
- Records of action taken to obtain a court determination, or administrative determination, that the dogs (or any of them) were dangerous, vicious, or overly aggressive toward people.
- Insurance company communications pertaining to prior claims against dog owner based on dog-inflicted injuries.
- Kennel records where dogs (or any of them) were boarded.
- Registration with the American Kennel Club.
- Receipts and credit card statements for payment for food, shelter, toys, cages, veterinary care, boarding, registration, licensing, training, consultation with behaviorist.
- If at any time any third party filed a "Petition To Determine If Dog Is Potentially Dangerous Or Vicious (Menacing Dog)," with respect to the dogs, the following documents in connection with that proceeding:
a. "Petition To Determine If Dog Is Potentially Dangerous Or Vicious (Menacing Dog)"
b. "Notice of Hearing (Menacing Dog)"
c. "Order After Hearing (Menacing Dog)"
- If at any time any third party filed a lawsuit in which it was alleged that the dogs (or any of them) injured any person in any manner, whether by biting that person, negligence, or a dangerous propensity, the following documents in connection with that lawsuit:
b. Each and every Amended Complaint;
c. Agreement of settlement, by whatever name it was called;
d. Release of claims or causes of action;
f. Each and every transcript of testimony given under oath in connection with that lawsuit.
- Each and every written letter, note, memo or other writing, or copy thereof, in which any party or third person described or alleged any occurrence of:
a. An injury to person or property purportedly caused by the dogs;
b. Any purported behavior or misbehavior of the dogs;
c. The incident complained of in this lawsuit;
d. Statements made by the victim or parents of the victim;
e. Statements made by any defendant;
f. Statements made by any person claiming to have knowledge about the incident or any issue in the lawsuit.