Blueprint for the Investigation

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.
  • Maid.
  • 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:

a. Complaint;     
b. Each and every Amended Complaint;     
c. Agreement of settlement, by whatever name it was called;     
d. Release of claims or causes of action;     
e. Judgment;     
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.