Download - Motion for Verification
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IN THE IOWA DISTRICT COURT FOR POTTAWATTAMIE COUNTY
SERVICE DOGS BY WARREN RETRIEVERS, INC., F/K/A Case No. LACV111413 Guardian Angel Service Dogs, Inc.
Plaintiff,
vs.
MICHAEL SPIZZIRRI AND JEANA SPIZZIRRI,
Defendants.
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DEFENDANTS MOTION FOR VERIFICATION OF IDENTIFICATION
COMES NOW, Defendants, Michael and Jeana Spizzirri, (hereinafter Defendants), and files
this Motion for Verification of Identification and states as follows:
1. A Petition (Replevin) was filed on May 28, 2014 by the Plaintiff, Service Dogs by
Warren Retrievers.
2. In that Petition, it identified a black Labrador retriever whose ID# is 074*315*364.
3. While gathering documents together for the upcoming trial, the Defendants came across
documents with a similar ID# but some of the numbers were different.
4. The Defendants are concerned that the dog in the Petition may not be the same dog that
was removed from the Defendants and given to the Plaintiffs.
5. The Defendants are requesting that the Plaintiff take the dog to an independent veterinary
clinic or to the local ASPCA and have the dogs micro-chip scanned and submit to the
courts and the Defendants proof of identification for the dog in question.
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WHERFORE, the Defendants request this Honorable Court to enter an order demanding the
Plaintiff, within 24 hours, to take the dog to an independent facility to be scanned and that
proof of the scan and the identification #, be submitted to the courts and to the Defendants,
immediately.
DATED this 17th day of June, 2014.
Respectfully submitted,
/s/ Michael Spizzirri /s/ Jeana Spizzirri Michael Spizzirri Jeana Spizzirri
199 E. Orchard Ave Council Bluffs, IA 51503
402-990-3641 [email protected]
DEFENDANTS