On the second night of the stay at Broad Ripple Hotel, James Sullivan receives a few emails from his law office about a pressing legal matter. While he works on some legal research, he tells his wife and daughter to go down to the hotel pool for a few hours of "fun" before dinner. After an hour, James Sullivan receives a call from his wife who is yelling about how a horrible accident happened at the pool, and he needs to come down to the pool immediately and hangs up the phone. Thinking the worst and in a state of panic, James Sullivan throws on a pair of shoes but does not tie his shoelaces. On his way down the stairs, James Sullivan trips down a flight of stairs, strains his ankle and rips his suit pants. When he gets to the pool, he confronts a horrible sight. His daughter's face is full of blood, and his wife is in tears.

Unsure of what happened, James Sullivan starts yelling, "What happened to my daughter?" His wife tells him that his daughter got bitten in the face by a dog. According to James Sullivan's wife, an elderly couple (Mr. Edward Kettles and Mrs. Jackie Kettles) were sitting at the poolside bar with a Greyhound dog named Baby Killer wearing a red vest with white lettering that indicated that the dog was a "service dog." James Sullivan's wife stated that Lucy approached the couple after exiting the pool and asked if she could pet their dog. The couple agreed but warned Lucy not to pet the dog on his back. Unfortunately, Lucy did not listen, and the dog nipped herface and caused three large lacerations on Lucy's face. At the time of the dog bite, James Sullivan's wife was drinking a beer, while chatting up the beefy lifeguard on duty at the time. After the dog bites Lucy, James Sullivan's wife passes out at the sight of blood. However, she quickly regains her senses and then calledJames Sullivan.

Rather than calling an ambulance or the police, one of the employees of the hotel (Harry Sanchez) tells James Sullivan that he is willing to drive the family to the local hospital, Good Samaritan Hospital Medical Center in West Islip, New York. Unable to think straight, James Sullivan agrees to allow the hotel employee to drive him to the hospital.

After waiting three hours for service, the doctors atGood Samaritan Hospital Medical Centertold James Sullivanthat they are unable to repair Lucy's face because the hospital does not have a pediatric plastic surgeon on staff. During the three hours of waiting, the doctors atGood Samaritan Hospital Medical Center wouldonly clean her wounds and put bandages on her three wounds. The doctors atGood Samaritan Hospital Medical Centerthen tell James Sullivan that he should never have brought his daughter to the hospital and instead should have taken his daughter to theChildren's Hospital at Stony Brook. After that, James Sullivan, who is now limping due to his sprained ankle, calls a taxi to take him and his daughter to the Children's Hospital at Stony Brook.

After thirty minutes, a taxi owned by a company called RottenApple Taxi Companydriven by Charles Norwood, a retired naval officer who is eighty-five years old, arrives. While driving to the Children's Hospital at Stony Brook, Charles Norwood, who has epilepsy, suffers a seizure. Because of the seizure, Charles Norwoodloses control over the car. The taxi crashes into another car and causes serious injuries to the driver of the car hit. James Sullivan suffers minor injuries, his wife suffers major injuries, and his daughter miraculously suffers no further injuries. The ambulance that arrives at the scene of the accident takes Lucy to the Children's Hospital at Stony Brookwhere skilled plastic surgeons repair Lucy's facial lacerations caused by the dog bite incident that occurred earlier in the day.

At present, doctors are unable to determine whether her facial scars are permanent. However, she is terrified of dogs, suffers from nightmares, and her classmates at school have started to call her names. In addition to her facial scars that are currently healing, Lucy has suffered from nightmares since the dog bite. James Sullivan's ankle sprainhas healed, but he has trouble sleeping. James Sullivan's wife is still in the hospital with multiple injuries. But, James Sullivan has not visited his wife since returning home as blames her for the incident.

After returning home, James Sullivan conducted some independent research online, and he discovers that the Big Service Dog Company, i.e., the company that issued the service dog vest and registration papers to the Kettles family, issues thousands of "service dog registration papers" per year. Located in Denver, Colorado, Big Service Dog Company does not conduct any dog training. Instead, the company asks its customers to attest to a series of facts. The customers are required to state that they have a disability, that they possess a "legitimate need" for the dog to assist them, that they will comply with all state laws, and that they agree to train their dog as a service dog. According to James Sullivan's research, Jackie Kettles has ananxiety disorder. However, their dog named Baby Killer, a retired Greyhound race doghad no service dog training. James Sullivan also discovers that the no employee of the Broad Ripple Hotel asked the Kettles to produce any evidence that Killer received any service dog training because they believed that such an inquiry would violate the Americans With Disabilities Act.

What actions can James take in terms of Damages? Is there any liabitity against the cab company?