1. What is your full name as well as your current address; date of birth; marital status; driverâ€™s license number and issuing state; and the last four digits of your social security number? 2. What is the name of your homeownerâ€™s liability insurance carrier, including the policy number and the policy limits for an occurrence such as the one alleged in the complaint? 3. How long have you resided at and owned your current residence; if you are not the owner of said residence, please state the name and address of the owner of said property? 4. What is your current employment and please state the name, address, and telephone number of your employer; dates of employment; job title and brief description of job duties; starting and current salary; all benefits received, including health, life, and disability insurance, pension, or profit sharing plans? 5. What, if any, financial assets do you own, including but not limited to 401Kâ€™s, HSA accounts, IRA accounts, stocks, mutual funds, certificates of deposit, bonds, real estate, motor vehicles, interest accruing accounts, and trusts?
6. What is the name; breed; color; age; and any other characteristic features of the dog in question? 7. What is the name and contact information of any veterinarians that have treated or with records pertaining to the dog described in the complaint and when was the last time the dog wasÂ vaccinated? 8. Has another animal ever bitten the dog in question and if so, did the dog receive veterinarian treatment for the bite? 9. Has the dog in question bitten any other persons during the animalâ€™s lifetime and 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? 10. Have you previously been sued for any bites/ attacks involving the named dog other than the incident alleged in this complaint and 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?
11. How is the dog in question escaping from a fenced in yard and why is the dog not properly leashed or restrained while outside? 12. Has the dog in question received professional training or instruction from yourself or anyone else to specifically pursue the PLAINTIFF? 13. Were you given any warnings about the dog in questionâ€™s behavior, whether verbal or written by the PLAINTIFF, before the attack that resulted in injuries to the PLAINTIFF, which could have prevented the attack from occurring? 14. At the time of the attack, which resulted in injuries to the PLAINTIFF, where were you in relation to the incident? 15. Do you know of any person who is skilled in any particular field or science, including the field of medicine, whom you may call as a witness upon the trial of this action and who has expressed an opinion upon any issue of this action?