Bill raises toy poodles. One evening he goes into his backyard to feed them. Since this only takes a few minutes, Bill decides not to latch the gate. While Bill is getting the dog food, one of the more vicious poodles escapes out the gate and attacks the ankle of a passerby on the sidewalk, Tom. While attempting to flee, Tom trips over his attacker and falls on the sidewalk, breaking his arm and completely destroying his Rolex watch. Tom's brother is a doctor and he treats Tom's arm and other injuries without charge.Tom sues Bill in Arkansas for personal injury and property damage. Assume liability is proved.

A) Tom should bring suit in [a chancery court] where any legal questions which are incidental to the equitable question can also be decided by the court under the clean-up doctrine.

B) Tom may recover for both physical pain and mental anguish that he may have suffered.

C) If the court follows the collateral source rule, Bill will be allowed to show that Tom's medical treatment cost him nothing.

D) The general damages for the watch will most likely be measured by the purchase price of the watch at the time Tom purchased it.

E) Because Bill intentionally left the gate open, Tom will be able as a matter of right to recover some amount of punitive damages.