IN THE COUNTY COURT OF THE NINTH JUDICIAL CIRCUIT OF FLORIDA ORANGE COUNTY, FLORIDA

Case Number: 2009-SC-006200-O

LAHTI, KIMBERLY

123 Orange Trail

Orlando, FL, 32810

(407) 457 -2343

Plaintiff(s)

VS

PRATHER, CHRIS & PADILLA, LORUHAMA

547 Orange Trail

Orlando, FL, 32810

(407) 457 - 8822

Defendant(s)

STATEMENT OF CLAIM

The above named Plaintiff(s) sue(s) the above named Defendant(s) for:

1. This is a statutory action against a dog owner under the Dog Bite Statute, § 767.01, Fla. Stat., and an action for negligence against the dog owner.

2. This Court has jurisdiction over this dispute because this complaint seeks damages that do not exceed five thousand ($5,000.00) dollars, exclusive of interest and attorney’s fees.

3. Defendants reside in Orlando, located in Orange County, Florida.4. Ve n u e i s p r o p e r i n O r a n g e C o u n t y, F l o r i d a b e c a u s e t h e d o g

b i t e i n j u r y f r o m w h i c h t h i s c ause of action arises took place in O r a n g e C o u n t y Florida.

5. On March 22, 2009 the defendants two pit bull dogs were loose and came into the plaintiffs front yard, then attacking both of the plaintiff’s dogs.

6. The plaintiff’s dogs used an electronic collar and could not leave the yard without being shocked.

7. The defendants dogs caused wounds to both of the plaintiff’s dogs, to the extremity that the plaintiff’s Weimeraner’s front leg had to be amputated and her Great Dane suffered chest and neck wounds that required stiches.

8. The defendant’s pit bulls frequently got out of their yard and the defendants did not take any action to stop the dogs from getting loose or attacking.

9. One of the defendants pit bulls had been picked up by animal services before for other similar attacks

10. The defendants were aware that one of there pit bulls is considered a “Dangerous Dog” by § 767.11, Fla. Stat.

11. Plaintiff re-alleges the allegations set forth above in paragraphs one (1) through ten (ten)

12. Under § 767.01, Fla. Stat, the defendant’s dog owners are liable for damages caused by their dog’s bites to other animals such as the plaintiff’s dogs.

13. As a proximate result of the Dog’s bites, Plaintiff incurred medical expenses in the sum of $2398.56

WHEREFORE, Plaintiff demands judgment for damages against Defendant Dog Owner in the total sum of $2398.56.

And Plaintiff(s) claim(s) $2398.56 damages not to exceed $5,000.00 exclusive of interest, court costs and attorney fees.

(Dollar amount is without court costs)

Respectfully submitted by,

Angel Perez

Attorney(s)

Kimberly Lahti

Plaintiff(s)