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Dog bite injury claims are common. Here is a sample complaint you can use for such a claim.

1. Plaintiff, Selma Smith is an adult individual who resides at the address indicated in the ca

According to USFDA, a combination product is one composed of any combination of a drug and device; biological product and device; drug and biological product

ption.

2. Defendant, Robert Jang is an adult individual with an address for service of process as indicated in the caption.

3. Defendant, Rosalind Jang is an adult individual wi

; or drug, device, and biological product and fixed dose combination would include two or more combinations of drug.

Examples of combination products may in

h an address for service of process as indicated in the caption.

4. On or about March 23, 2002 defendants owned, directed, supervised and controlled a certain German Shepherd which wa

lude drug-coated devices, drugs packaged with delivery devices in medical kits, and drugs and devices packaged separately but intended to be used together.

at all relevant times under their ownership, direction, supervision and control.

5. On the aforesaid date, plaintiff was walking in her neighborhood, walked slowly over to defendant

here is enormous increase in the number of combination products entering the market in the recent years. Combination products have proven advantages but fixe

Robert Jang, at which time she was set upon by the defendants' vicious German Shepherd which violently attacked and bit her, chewed on her leg, knocked her to the ground and causing her to

d dose combinations are still in the process of convincing regulatory authority on their advantages over the single ingredient formulations.

Combination pro

uffer severe and disfiguring injuries, as more particularly hereafter set forth.

6. The aforesaid attack was caused solely and exclusively by the negligence of the defendants and was due i

ucts have become life saving products for the pharmaceutical companies who doesn’t have many innovative molecules in their product pipeline and have been inc

no manner whatsoever to any act or failure to act on the part of the plaintiff.

7. The negligence, carelessness and recklessness of the defendants consisted of the following:

(a

easingly used in the product life cycle management. Even the companies having product patents are trying to extend their product life cycle through the combi

Maintaining a public nuisance;

(b) Failing to warn the plaintiff that the defendants' German Shepherd had vicious propensities;

(c) Failing to physically

nation products and maximize the revenues. But the companies involved in this practice are overlooking that they are burdening the patients both economically

restrain the German Shepherd;

(d) Failing to properly leash and/or chain the German Shepherd;

(e) Allowing the German Shepherd to break loose in a public place where a p

and physically. They need to rightly judge the benefits of the combination products and they have to even look at the risks involved when combining the produ

destrian could be expected to be;

(f) Failing to remove the German Shepherd after notice of the German Shepherd's vicious propensities;

(g) Failing to

ts. Some of the combination products were well accepted by physicians while others suffered. Companies involved in development of combination products are fi

give notice to plaintiff of the German Shepherd's vicious propensities particularly where defendant, Robert Jang knew that plaintiff was close by;

(h) Violation of th

ding difficulty in defining their combination products and facing various challenges from selecting a combination to marketing it.

Following aspects would a

e applicable statutes relating to German Shepherds and other dogs;

(i) Negligence as a matter of law;

8. At all times material hereto and at the time and place aforesa

dd to the challenges in developing combination products:

Which markets to tap where the combination products can do fairly well?
Which combination prod

d, plaintiff was tending to her own affairs on a public walkway and she in no way enticed or otherwise harassed the said German Shepherd.

9. As a result of the defendants' negligence,

cts are meaningful and rational?
Which therapeutic categories to select?
Which Combinations can address unmet needs of the patients?
Do combin

the plaintiff sustained serious injuries to her head, body and limbs, more specifically, she suffered: severe dog bite puncture wounds, swollen and infected right leg, a general feeling of

tions increase the patient compliance?
What would be the developing cost?
How to tackle the risks encountered during combination product developmen

alaise, and she was otherwise injured.

10. As a further result of the defendants' negligence, plaintiff has been obliged to expend various sums of money or incur various expenses for me

t?

As combination products don't fit into the traditional categories of drugs, medical devices, or biological products, the USFDA is in the process of devel

icine, medical care and treatment in an effort to cure herself of the injuries she has suffered, and she will be obliged to continue to do so for an indefinite time in the future all of whic

ping new procedures for reviewing their safety, efficacy and quality.

Professional from academic institutions, pharmaceutical industries, health care indust

is to her great financial detriment and loss.

11. As a result of the defendants' negligence, the plaintiff has been unable to attend to her usual duties and occupations and will be un

y and representatives from various regulatory agencies are working out to design the regulatory requirements for manufacture and sale of combination products

ble to do so for an indefinite time in the future all of which is to her great financial detriment and loss.

12. As a further result of the defendants' negligence, the plaintiff has un

.

As there is an increasing trend of the combination products companies manufacturing such products should be able to tackle the problems involved in the de

ergone great physical pain and mental anguish, and will continue to endure the same for an indefinite time in the future, all of which is to her great financial detriment and loss.

WHER

elopment. They need to be wiser in analyzing the market trends and the regulatory requirements.

Companies that provide selfless information through particip

FORE, plaintiff, Selma Smith demands judgment in her favor and against the defendants, Robert and Rosalind Jang in an amount not in excess of $50,000.00, together with the costs of this suit

tion in industry events and feedback to regulatory authorities would be able to face the challenges and will be successful in developing combination products

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