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Plaintiff’s Dog Bite Request for Production of Documents

Below are plaintiffs’ request for production of documents propounded to a dog owner in a dog bite case.

IN THE CIRCUIT COURT FOR BALTIMORE, MARYLAND
Civil Division
MARY ELIZABETH HAYMAN :
Plaintiff :
v. : CASE NO.: 24-C-17-001028 OT
MARGARET COLLINS, et al. :
Defendants :
PLAINTIFF’S RESPONSES TO DEFENDANT’S
REQUESTS FOR PRODUCTION OF DOCUMENTS
TO: AMERICA FOR YOU, Defendant

FROM: MARY HAYMAN, Plaintiff

Now comes the Plaintiff, Mary Elizabeth Hayman, by and through her attorneys,

Plaintiff Mary Hayman (“Plaintiff”), by and through his attorneys, Miller & Zois, LLC, requests that the Defendant, Margaret Collins, produce the following documents 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 875 Victory Park Drive, Baltimore, Maryland 21230.

INSTRUCTIONS
  1. ThIs discovery is continuing in character. Please remember you obligation to supplement your answers if you obtain further or different information before trial.
  2. Unless otherwise stated, these requests 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 answer is made by 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 defendant.
  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 principle 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, Baltimore, Maryland 21230.
  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, Baltimore, Maryland 21230.
  9. The term “your apartment” refers to the apartment you were leasing on April 1, 2017 at the Victory Park at Troy Meadows apartment complex located at 875 Victory Park Drive, Baltimore, Maryland 21230.
  10. The term “attack” includes but is not limited to “jumping on the plaintiff.”
DOCUMENTS TO BE PRODUCED

More Dog Bite Discovery

  1. All documents identified in your answers to Interrogatories.
  2. All written reports, and drafts, of each person whom you expect to call as an expert witness at trial.
  3. All documents upon which any expert witness you intend to call at trial reviewed to form any opinions.
  4. The most recent resume or curriculum vitae of each expert whom you expect to call as an expert witness at trial.
  5. All notes, bills, invoices, diagrams, photographs, x-rays, radiological films or other documents prepared or reviewed by each person whom you expect to call as an expert witness at trial.
  6. All invoices generated by all expert witnesses for performing expert witness services to the Defendant including, but not limited to, the fees for the medical examination, the records review, the pretrial preparation, any telephone conference, any trial testimony anticipated and any other fee paid by the defendants for expert fees.
  7. Any list of cases maintained by any expert witness identified in which the witness has testified as an expert at trial or by deposition.
  8. Any and all correspondence or e-mails and any documentation exchanged between the expert and the defendant’s counsel. This includes, of course, agents of defense counsel and any expert.
  9. All written, recorded and/or signed statements of any person, including the Plaintiff, Defendant, witnesses, investigators or any agent, representative or employee of the parties, concerning the subject matter of this action.
  10. All photographs, videotapes, audio tapes, x-rays, diagrams, medical records, surveys or other graphic representations of information concerning the subject matter of this action that you have in your possession.
  11. Any documents which afforded medical pay / liability / renter’s insurance / home owner’s insurance for the incident which is the subject matter of the Plaintiff’s Complaint.
  12. Any documents received pursuant to any subpoena request of any party.
  13. Any document prepared during the regular course of business as a result of the incident complained of in the Plaintiff’s Complaint.
  14. Copies of any treaties, standards in the industry, legal authority, rule, case, statute or code that will be relied upon in the defense of this case.
  15. Any expert identification filed in any court by the law offices representing you identifying any expert in this case as an expert in another case.
  16. Copies of transcribed testimony of any person deposed in this matter.
  17. Copies of all medical records reflecting medical treatment the subject dog received as a result of the collision.
  18. A copy of the animal control citation issued in this case.
  19. Copies of all 1099 forms and other forms/invoices reflecting payments made by the Defendant’s law firm over the last three years to the expert and his/her medical practice that the Defendant’s lawyers retained in this case.
  20. Documents, including licenses, for all dogs living at your residence from 2011 until 2013.
  21. A copy of each lease you have signed with Victory Park at Troy Meadows between 2005 and 2013. This includes any supporting documents that were attached to the lease.
  22. Any and all photographs and/or videotapes of the subject dog.
  23. A certified copy of any and all homeowner’s and/or rental insurance policies
    in effect at the time of the occurrence.
  24. Any and all documents in your possession regarding the care and keeping of the subject dog.
  25. Any and all documents pertaining to the licensing of the subject dog.
  26. Any and all citations or warnings issued by anyone or any legal entity, to you and/or the owner(s) of the subject dog preceding the occurrence, up until the date of these answers.
  27. Any and all documents pertaining to the registration of the subject dog for a period of five (5) years preceding the occurrence, up until the date of these answers.
  28. Any and all veterinarian records of the subject dog for a period of five (5) years preceding the subject occurrence, up until the date of these answers.
  29. Any and all documents regarding any training or the subject dog for a period of five (5) years preceding this occurrence.

Respectfully submitted,
Miller & Zois, LLC

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