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Library

Library-Pleadings

LIBRARY OF BSL PLEADINGS

 

Tarquinio v. City of Lakewood, OH

Tarquino v. City of Lakewood - Complaint filed February 2011.

Criscuolo v. Grant County, WA

Criscuolo v. Grant County, Washington - Complaint filed 2011.

Plaintiff Discovery to Grant County 

Dias v. City of Denver, CO - Pleadings,
Transcripts & Orders

Dias v. City of Denver - Complaint - successfully survived Summary Judgment.

Dias v. City of Denver - Denver's Motion to Dismiss

Dias v. City of Denver - Dias Response to Denver Motion to Dismiss

Dias v. City of Denver - Order Granting Denver's Motion to Dismiss

Dias v. City of Denver - Dias Opening Brief on Appeal

The Brief contains the following exhibits:

AKC Standards American
Staffordshire Terrier Breed Standard;
AKC Information of Staffordhire Bull Terrier Puppies;
UKC Standards Staffordhire Bull Terrier;
UKC Standards American Pit Bull Terrier;
Report of Plaintiff Expert Arnold Arluke documenting the strength of the emotional bond between humans and dogs with extensive references;
Report of Plaintiff Expert On Statistics David L. Banks who examines the literature and passage of the Denver ban and concludes it does not have a rational basis;
Report of Plaintiff Expert Veterinarian and Behaviorist Bonnie Beaver who states that there is no scientific basis for a pit bull ban, no way to properly identify a pit bull visually, the impossiblity of giving an opinion about what breed of dog bites the most due to no accurate dog population statistics being available, and that most dog bites are better related to factors other than breed;
Report of Plaintiff Bite Expert Karen Delise who has documented flaws in the original study which reported that pit bulls were responsible for a high number of dog attacks.  She points out problems with proper idenfication of pit bulls in the data and media prejudice which overstates the problem of pit bull dog bites. She states that more important than the breed of the dog in determining bite propensity is the function of the dog, owner responsibility, and reproductive status;
Report of Plainitff Expert Veterinarian and Behaviorist Karen Overall who testifies that there is no scientific evidence supporting breed bans. She exhaustively goes over the lack of science to support breed bans.

Dias v. City of Denver - City of Denver Answer Brief

Dias v. City of Denver - Dias Reply Brief

Dias v. City of Denver - Amicus Brief of the Animal Legal Defense Fund

Dias v. City of Denver - Amicus Brief of the Humane Society of the United States

Dias v. City of Denver - Amicus Brief of the American Society for the Prevention of Cruelty to Animals

Dias v. City of Denver - Tenth Circuit's Opinion Reversing the Motion to Dismiss

Dias v. City of Denver - City of Denver Motion to Summary Judgment

Exhibit A1 - Affidavit of Alan M. Beck
Exhibit A2 - Report of Alan M. Beck
Exhibit A3 - Report of Alan M. Beck 2
Exhibit A4 - Deposition of Randall Lockwood
Exhibit A5 - Deposition of Plaintiff Engel
Exhibit A6 - Deposition of Plaintiff Dias
Exhibit A7 - Deposition of Alan M. Beck
Exhibit A9 - Colorado Dog Fanciers Court Opinion
Exhibit A10 - Denver Ordinance
Exhibit A11 - Egelhoff Court Opinion
Exhibit A12 - Egelhoff transcript of hearing
Exhibit A13 - American Canine v. City of Aurora Decision

Dias v. City of Denver - Dias Response to City of Denver Motion for  Summary Judgment

Exhibit 2 - Report Randall Lockwood
Exhibit 4 - Report Karen Overall, MA, VMD, PHD
Exhibit 6 - Report David L. Banks, PHD
Exhibit 8 - Deposition of Douglas Kelley
Exhibit 9 - Deposition of Randall Lockwood
Exhibit 10 - Deposition of Karen Overall, MA, VMD, PHD
Exhibit 11 - Deposition of David L. Banks
Exhibit 12 - Deposition of Bonnie Beaver
Exhibit 13 - Denver Ordinance Breed Standards
Exhibit 14 - Affidavit Plaintiff Dias
Exhibit 15 - Deposition of Alan M. Beck
Exhibit 16 - CDC Dog Bite Fact Sheet
Exhibit 17 - Deposition Plaintiff Dias
Exhibit 18 - Report Breed Ban Italy and the Netherlands
Exhibit 19 - Mars Insights DNA Testing Results
Exhibit 21 - Bahamas Report on Pit Bull Attacks
Exhibit 22 - Delta Society Statement
Exhibit 23 - Bonnie Beaver CV
Exhibit A3 - Report Alan M. Beck
Exhibit A5 - Deposition Plaintiff Engel

Dias v. City of Denver - Order Denying City of Denver Motion for Summary Judgment

 

City of Toledo v. Smith - Pleadings,
Transcripts & Orders

 

City of  Toledo v. Smith - Motion to Dismiss based on the definition of Pit Bull void for vagueness. Motion granted.

City of Toledo v. Smith - Motion to Dismiss Failure to Muzzle due to conflict with state law. Motion granted.

City of Toledo v. Smith - Brief of Appellee arguing the trial court properly dismissed the case. Appeal dismissed by City as City Commission passed new dangerous dog law without Breed Specific Legislation.

City of Toledo v. Smith - Transcript of Hearing on Motion to Dismiss