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Date: 01-25-2016

Case Style: Larry A. Birch v. Ryan Young

Case Number: CJ-2014-3187

Judge: Jefferson D. Sellers

Court: District Court, Tulsa County, Oklahoma

Plaintiff's Attorney: George Miles

Defendant's Attorney: Tom Baker and Jim Daniel

Description: Tulsa, OK - Larry A. Birch sued Ryan Young on a negligence theory claiming:

COUNT ONE

That at all times material herein, the Plaintiffs Larry A. Birch and Hannah F. Birch are the natural parents and guardian of their child, Ava Birch.

That the facts which give rise to this cause of action occurred in Tulsa County,
State of Oklahoma.

That this Court has jurisdiction of the parties and the subject matter of this action.
That on or about the 2nd day of June, 2013, the Plaintiffs' child, Ava Birch, was an
invitee on the property owned by the Defendant Ryan Young in Tulsa County
Oklahoma. That at that time and place Ryan Young was harboring a vicious animal, to-
wit a pit bull dog, and that the pit bull dog owned and controlled by the Defendant Ryan
Young did attack, bite, maul, injure and scar Ava Birch.

At the time of the attack on Ava Birch by the Defendant's vicious animal Ava Birch was 6 years of age with a normal life expectancy of 75.8 years according to the United States Life Tables.

That as a result of the attacks by the Defendant's pit bull dog the Plaintiff Larry A. Birch and Hannah Birch have been forced to expend a large sum of money to effect a cure to the injuries inflicted on Ava Birch, which injuries are serious, painful and permanent in their nature.

COUNT TWO

COMES NOW the Plaintiffs and adopt all allegations heretofore made in Count One hereof as if fully set forth herein.

That as a result of the vicious attack by the Defendant's pit bull dog the Plaintiff Ava Birch has suffered severe personal injuries which are both temporary and permanent in their nature.

WHEREFORE, premises considered, the Plaintiffs, do claim damages against the Defendant in a sum in excess of $10,000, as and for actual damage, and a sum in excess of $I 0,000, as and for punitive or exemplary damages, together with interest there, all costs of this action, and for such other relief to which they may be entitled.

Defendant offered to allow judgment to be taken against him pursuant to 12 O.S. 1101.1 in the amount of $65,000.00.

Outcome: Settled and dismissed with prejudice.

Plaintiff's Experts:

Defendant's Experts:

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