Sacramento Woman Seriously Injured In Dog Attack, Part 4 of 8

(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this dog bite/personal injury case and its proceedings.)

A. Testimony from plaintiff White indicated that the dog that attacked her (twice) on the day of the incident not only came from the defendant Topp’ residence, but that the dog could not be controlled by the residents of Topp home who were home at the time of the attack.

B. White’s testimony was further supported by his deposition testimony wherein, White ‘ testimony remained consistent and truthful.


A. The testimony from defendant Topp was clearly perjurious and false as to the most basic and crucial of facts in this accident such as:

a. What type of dog it was that was at her property;
b. How many times she had seen the dog;
c. Who the dog had come to visit;
d. How many times had the dog been to her property;

e. What were the propensities of the dog:

B. The defendant clearly lied in her deposition as exposed during her trial testimony that was completely inconsistent with her deposition testimony.

C. The defendant fabricated declaration under penalty of perjury on two separate occasions (April 30, 2008 & October 28, 2008) in an effort to deceive the court and jury that contained the most material of inconsistencies (i.e., who did the dog owner come to visit & how many times had the dog been to the defendant Topp’ premises). Even when asked by this court directly: Why did you change your story from one declaration to another taken six months later….after a 3-minute silence the defendant responded, “I don’t know.” (See Part 5 of 8.)

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

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