Ellen Pingaro (plaintiff) was employed as a meter reader for the New Jersey Natural Gas Company (NJNG). On June 27, 1996, she went to the home of Joseph Rossi (defendant) to read the meter. Pingaro had never been to Rossi’s residence before. When she got to the address, her hand-held computer beeped, providing the following notification: “[B]ad dog, knock.” Pingaro knocked on the door; there was no answer. She then rattled the gate to the backyard and called out “gas company.” Again, there was no answer. It seemed to Pingaro that the property was clear, without any animals. She opened the gate and proceeded to the meter. Two dogs immediately appeared. A German shepherd knocked Pingaro to the ground and bit her limbs and her head. She was able to get away but suffered numerous wounds that required stitching and caused scarring, psychological harm, and time off work. Pingaro sued Rossi pursuant to a New Jersey statute imposing liability upon dog owners for dog bites. A jury found in Pingaro’s favor. A new trial was granted as to liability.