In a personal injury lawsuit filed on May 17, 2024, in the Ventura Superior Court, William Mills accuses Nicole Sullivan, Gayle Klein, and Kenneth Klein of negligence and other violations following a dog bite incident. The complaint, submitted by attorney Murray S. Berns on behalf of Mills, details multiple causes of action including liability based on the dog bite statute, general negligence, and intentional tort.
According to the court documents, the incident occurred on May 3, 2024. Mills was walking on a public sidewalk at the intersection of South Martha Morrison Drive and Twin Peaks Ave in Simi Valley when he was bitten by a dog owned by Sullivan and the Kleins. The attack resulted in serious injuries to Mills' left leg, requiring emergency medical treatment. "To this date his left leg appears scarred and disfigured," the complaint states. Additionally, Mills claims to have suffered from pain, anxiety, and loss of quality of life due to the attack.
The plaintiff asserts that under California Civil Code section 3342, dog owners are strictly liable for damages caused by their pets if they bite someone in a public place or lawfully on private property. Furthermore, Mills alleges that Sullivan and the Kleins failed to adhere to local leash laws as outlined in Ordinance No. 1337 Article 5-4461 of the Simi Valley Municipal Code. "At the time of this incident, the dog was not securely leashed," reads the complaint.
Mills also accuses Sullivan and the Kleins of failing to provide necessary information about their dog's rabies vaccination status within 48 hours after the incident—a requirement under subdivision (a) of section 398 of the California Penal Code. This omission allegedly exacerbated Mills' suffering due to concerns about potential rabies infection.
In addition to these allegations, Mills claims that Gayle Klein engaged in an act of vandalism on May 13, 2024. According to Mills' account, Klein intentionally threw a hard object at him and his vehicle without provocation. This act caused damage to his vehicle and further distress.
Mills is seeking compensatory damages exceeding $35,000 for medical expenses, psychological treatment costs, loss of income both past and future, pain and suffering, physical disfigurement, loss of future earning capacity as well as punitive damages for Klein's alleged act of vandalism. The plaintiff also demands prejudgment and post-judgment interest along with other relief deemed appropriate by the court.
The case is being overseen by Judge Ward Cog under Case ID: 2024CUPP024823.