DEMAND FOR SETTLEMENT - DOG BITE / ANIMAL ATTACK

STATE OF CONNECTICUT

[FIRM NAME]
Attorneys at Law
[Street Address]
[City, Connecticut ZIP]
Telephone: [Phone]
Facsimile: [Fax]
Email: [Email]
Licensed in the State of Connecticut

DATE: [Date]

VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED
AND FIRST-CLASS MAIL

[Adjuster Name / Dog Owner Name]
[Insurance Company Name / Address]
[Street Address]
[City, State ZIP]

RE: DOG BITE CLAIM - SETTLEMENT DEMAND
Our Client: [Client Full Name]
Date of Attack: [Date of Attack]
Location of Attack: [Address where attack occurred]
Dog Owner: [Dog Owner Name]
Dog Breed/Description: [Breed, Size, Color]
Claim Number: [If assigned]
Homeowner's Policy Number: [If known]

Dear [Recipient Name]:

This firm represents [Client Name] ("Claimant") for the serious and permanent injuries sustained as a result of a vicious dog attack that occurred on [Date of Attack]. The attack was perpetrated by a [Breed] dog owned by [Dog Owner Name]. This letter constitutes our formal demand for settlement.

I. CONNECTICUT DOG BITE LAW - STRICT LIABILITY

A. Connecticut's Strict Liability Statute

Connecticut is a STRICT LIABILITY state for dog bite injuries. Under Connecticut General Statutes § 22-357, a dog owner or keeper is liable for damages caused by their dog without the need to prove negligence or prior knowledge of viciousness.

Conn. Gen. Stat. § 22-357 provides:

"If any dog does any damage to either the body or property of any person, the owner or keeper... shall be liable for such damage, except when such damage has been occasioned to the body or property of a person who, at the time such damage was sustained, was committing a trespass or other tort, or was teasing, tormenting or abusing such dog."

Key Connecticut Cases:

• Auster v. Norwalk United Methodist Church, 286 Conn. 152 (2008) - Strict liability applies to owners and keepers
• Giacalone v. Housing Authority of Wallingford, 306 Conn. 399 (2012) - Defined "keeper" for liability purposes
• Verrilli v. Damilowski, 140 Conn. 358 (1953) - Established scope of strict liability statute

B. Advantages of Strict Liability

Under Connecticut's strict liability framework:

☐ No Scienter Required: Plaintiff need NOT prove owner knew of dog's dangerous propensities
☐ No Prior Bite Needed: Liability attaches even for first-time incidents
☐ Automatic Liability: If dog caused damage, owner is liable (absent statutory defenses)
☐ Keeper Liability: Both owners AND keepers may be held liable

C. Limited Defenses Under Connecticut Law

The defendant's only defenses under § 22-357 are:

☐ Victim was committing trespass at the time of the attack
☐ Victim was committing another tort
☐ Victim was teasing, tormenting, or abusing the dog

II. PRESERVATION OF EVIDENCE NOTICE

YOU ARE HEREBY DIRECTED TO PRESERVE ALL EVIDENCE relating to this attack and the subject animal, including but not limited to:

☐ The animal itself (do not destroy, euthanize, or transfer without notice)
☐ All veterinary records for the animal
☐ Vaccination records, including rabies vaccination
☐ Animal licensing and registration documents
☐ Prior bite reports or complaints
☐ Any "dangerous dog" or "vicious dog" designations
☐ Communications with animal control
☐ Homeowner's or renter's insurance policies
☐ Training records for the animal
☐ Proof of confinement measures

Spoliation of evidence under Connecticut law may result in adverse inferences and sanctions. Beers v. Bayliner Marine Corp., 236 Conn. 769 (1996).

III. STATEMENT OF FACTS

A. The Attack

On [Date of Attack], at approximately [Time], our client was [describe activity - e.g., "walking on the public sidewalk in front of [Address]," "visiting the dog owner's residence as an invited guest," etc.].

At that time, [Dog Owner Name]'s [Breed] dog [describe how attack occurred - e.g., "escaped from the owner's property," "was off-leash in violation of local ordinance," etc.].

The dog attacked our client viciously and without provocation. [Describe the attack in detail].

B. No Statutory Defense Applies

[Client Name] was NOT:

☐ Trespassing - [He/She] was lawfully present at the location
☐ Committing any tort
☐ Teasing, tormenting, or abusing the dog

The statutory defenses under Conn. Gen. Stat. § 22-357 do not apply.

IV. CONNECTICUT'S COMPARATIVE NEGLIGENCE RULE

A. Modified Comparative Negligence Standard

Connecticut follows modified comparative negligence under Conn. Gen. Stat. § 52-572h. A plaintiff's recovery is reduced by their percentage of fault, but if the plaintiff is more than 50% at fault, they are barred from recovery entirely.

B. No Comparative Fault Here

[Client Name] bears no fault for this attack:

☐ [He/She] was lawfully present at the location
☐ [He/She] did not provoke, tease, or torment the dog
☐ [He/She] did not approach or interact with the dog
☐ [He/She] exercised all reasonable care
☐ The attack was entirely unprovoked

Any assertion of comparative negligence would be without merit.

V. INJURIES AND MEDICAL TREATMENT

A. Description of Injuries

The attack caused severe injuries to our client, including:

Bite Wounds:
☐ [Location] - [Description]
☐ [Location] - [Description]

Secondary Injuries:
☐ Soft tissue damage
☐ Nerve damage
☐ Infection risk
☐ Scarring and disfigurement

Psychological Injuries:
☐ Post-Traumatic Stress Disorder (PTSD)
☐ Cynophobia (fear of dogs)
☐ Anxiety and panic attacks

B. Medical Treatment

[Detail emergency treatment, follow-up care, surgeries, mental health treatment]

C. Prognosis

[Detail permanent conditions, ongoing treatment needs, future care requirements]

VI. DAMAGES

A. Medical Expenses

B. Future Medical Expenses

C. Lost Wages

D. Pain and Suffering

Connecticut allows full recovery for:
- Physical pain and suffering
- Mental anguish
- Emotional distress
- Permanent scarring and disfigurement
- Loss of enjoyment of life

E. No Damage Caps in Connecticut

Connecticut does not impose statutory caps on compensatory damages in personal injury cases.

F. Summary of Damages

VII. SETTLEMENT DEMAND

A. Demand Amount

Based upon Connecticut's strict liability statute, the clear liability of the dog owner, the severity of injuries, and the substantial damages, we hereby demand:

$[DEMAND AMOUNT]

B. Time for Response

This demand will remain open for thirty (30) days from the date of this letter, through and including [Expiration Date].

VIII. STATUTE OF LIMITATIONS

Under Connecticut General Statutes § 52-584, the statute of limitations for personal injury claims is two (2) years from the date of injury.

Date of Attack: [Date]
Limitations Period Expires: [Date + 2 years]

IX. DOCUMENTATION ENCLOSED

☐ Medical records and bills
☐ Photographs of injuries
☐ Police/Animal Control report
☐ Witness statements
☐ Employment records
☐ Prior incident documentation
☐ HIPAA authorizations

X. CONCLUSION

Under Connecticut's strict liability statute, the dog owner is liable for all damages caused by this unprovoked attack. There is no viable defense, and the damages are substantial and well-documented.

We are prepared to try this case before a Connecticut jury if necessary. Given Connecticut's favorable strict liability framework, liability is not in dispute.

We urge you to resolve this matter promptly.

Respectfully submitted,

[FIRM NAME]

By: _________________________________
[Attorney Name]
Connecticut Bar Number [Number]
Attorney for [Client Name]

ENCLOSURES: [List]

cc: [Client Name]
[File]

CONNECTICUT-SPECIFIC PRACTICE NOTES

• Strict Liability State: Connecticut's § 22-357 imposes strict liability - no need to prove scienter or prior knowledge of viciousness.
• Owner AND Keeper Liability: Both owners and "keepers" (those with custody/control) may be liable.
• Limited Defenses: Only trespass, other torts, or teasing/tormenting/abusing the dog are valid defenses.
• Modified Comparative Negligence: 51% bar rule applies - plaintiff barred if more than 50% at fault.
• 2-Year SOL: Personal injury claims must be filed within 2 years under Conn. Gen. Stat. § 52-584.
• No Damage Caps: Connecticut does not cap compensatory damages.
• Local Ordinances: Research applicable municipal dangerous dog ordinances for additional claims.

This template must be reviewed and customized by a Connecticut-licensed attorney before use.