Draft an answer to the following complaint for damages, including admissions and denials of factual allegations defenses and affirmative defenses.

Complaint for Damages:

Plaintiff, by and through her attorneys, complains of the Defendant as follows:

1.

Plaintiff is, and all times hereafter was, a citizen and resident of the City of Macon, County of Bibb, State of Georgia.

2.

Plaintiff alleges upon information and belief that the Defendant is a citizen and resident of the City of Daytona Beach, County of Volusia, State of Florida.

3.

Jurisdiction and venue are proper in this Court because the Defendant's actions occurred in the State of Georgia, more specifically at Buc-ee's gas station located at 7001 Russell Parkway, Fort Valley, Georgia.

4.

Plaintiff repeats and realleges the allegations set forth in Paragraphs 1-3 as if fully set forth herein.

5.

On August 21, 2023, Plaintiff, her husband, and their two minor children were en route to Savannah, Georgia, when they stopped at Buc-ee's gas station in Fort Valley, Georgia.

6.

While Plaintiff was filling her vehicle with gasoline, two large and aggressive dogs jumped out of the truck next to hers and began attacking her.

7.

Plaintiff's husband and another witness attempted to stop the attack, but the dogs continued to maul Plaintiff.

8.

Defendant eventually exited his vehicle and restrained the dogs.

9.

Defendant is the owner of the two dogs involved in the incident.

10.

The Plaintiff was then transported by ambulance to the emergency room at Macon Community Hospital due to the severity of her injuries.

11.

Plaintiff suffered from severe dog bites to her stomach, right leg, right arm, and right hand due to the attack.

12.

Plaintiff's two minor children have since been undergoing counseling due to the trauma caused by witnessing this incident.

13.

Plaintiff has been unable to return to work due to her injuries.

14.

Plaintiff continues to require physical therapy for her injuries.

FIRST CAUSE OF ACTION

NEGLIGENCE

15.

Plaintiff repeats and realleges the allegations set forth in Paragraphs 1-14 as if fully set forth herein.

16.

Defendant had a duty to use reasonable caution when managing his dogs in public in order to keep other people safe.

17.

The Defendant breached this duty by allowing his vicious dogs to run loose and attack Plaintiff.

18.

The Plaintiff's injuries to her stomach, right leg, right arm, and right hand were directly caused by the breach of this duty.

19.

The dog bites from the attack caused the Plaintiff severe injuries and damages, including pain and suffering, mental distress, and financial hardship from medical expenses and lost wages.

20.

Plaintiff repeats and realleges the allegations set forth in Paragraphs 1-19 as if fully set forth herein.

21.

The Defendant acted recklessly when he failed to properly tame and manage the dogs to prevent aggressive behavior.

22.

The Defendant engaged in severe and outrageous behavior when he allowed his vicious dogs to run loose, which led to an attack on the Plaintiff.

23.

As a result of this incident and the aftermath, Plaintiff has suffered from severe emotional distress, including trauma and emotional suffering.

24.

The Plaintiff's severe emotional distress was a direct result of the Defendant's actions.

25.

The Plaintiff is seeking compensation for her severe emotional distress and mental agony caused by this incident.

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS (PLAINTIFF)

26.

Plaintiff repeats and realleges the allegations set forth in Paragraphs 1-25 as if fully set forth herein.

27.

The Defendant acted recklessly when he failed to properly tame and manage the dogs to prevent aggressive behavior.

28.

The Defendant engaged in severe and outrageous behavior when he allowed his vicious dogs to run loose and attack Plaintiff, which the minor children witnessed.

29.

The Plaintiff's minor children have suffered from severe emotional trauma as a result of this attack, which resulted in counseling for both children.

30.

The minor children's severe emotional distress was a direct result of the Defendant's actions.

31.

The Plaintiff is seeking damages to compensate for the children's emotional suffering and to cover the children's past and future medical expenses from counseling.

LOST WAGES

32.

Plaintiff repeats and realleges the allegations set forth in Paragraphs 1-31 as if fully set forth herein.

33.

The Plaintiff's physical injuries from the attack have prevented her from going back to her job as an accountant, which has resulted in lost wages.

34.

The Plaintiff's capacity to work in the future has been diminished because of the severity of her injuries and the ongoing need for rehabilitation.

35.

The Plaintiff is seeking damages for both past and future lost wages.

MEDICAL EXPENSES (PAST AND FUTURE)

36.

Plaintiff repeats and realleges the allegations set forth in Paragraphs 1-35 as if fully set forth herein.

37.

The Plaintiff incurred a large amount of medical expenses for emergency care, surgeries, physical therapy, and continuing medical care as a result of this incident.

38.

The Plaintiff will continue incurring medical expenses for physical therapy.

39.

The Plaintiff is seeking compensation for both past-due medical bills and future medical expenses.

WHEREFORE, Plaintiff respectfully requests:

1. An award of damages to the Plaintiff for her physical and emotional injuries;
2. Compensatory damages for past and future lost wages;
3. Compensatory damages for past and future medical expenses;
4. That the Plaintiff have and recover the costs of this action; and
5. Any other relief the Court deems just and proper.