Civil Remedy Notice of Insurer Violations
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Filing Number:     651000
Filing Accepted:  10/12/2022
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Complainant
Last/Business Name *  
EVANS   First Name   LASHAWN
Street Address * 2748 NW 56TH STREET
City, State Zip * MIAMI, FL 33142
Email Address * SHAWNEVANS1575@YAHOO.COM
Complainant Type: * Insured
Insured
Last/Business Name*   EVANS   First Name   LASHAWN
Policy # * MLR870594604 Claim #* 00201496641
Attorney
Attorney is Applicable
Last Name* KRAPF First Name * GRANT Initial
Street Address* 2790 SUNSET POINT ROAD
City, State Zip* CLEARWATER , FLORIDA 33759
Email Address * GRANT@KRAPFLEGAL.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   AMERICAN SECURITY INSURANCE COMPANY
NAIC Company Code 42978
 
Name of individual responsible for violation (if any):* GEOFFREY STEPHENS AND ANY INDIVIDUAL FROM, OR AGENT OF, AMERICAN SECURITY INSURANCE COMPANY WHO WAS INVOLVED IN THE CLAIM.
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Unfair Trade Practice
Claim Denial
Claim Delay
Other : Not treating the policyholder with good faith claims conduct
Other : Looking for ways to deny full recovery to the Insureds
Other : Looking for ways to delay full recovery to the Insureds
Other : Not training, supervising, or managing adjusters properly so that prompt and full payments are made,
Other : Failing to provide the Insureds with the full benefits awarded to him under the contract of insuranc
* Statutory provision(s) which the insurer allegedly violated.
 
624.155(1)(b)(1) Not attempting in good faith to settle claims when, under all the circumstances, it could and should have done so, had it acted fairly and honestly toward its insured and with due regard for her or his interests.
626.9541(1)(i)(2) A material misrepresentation made to an insured or any other person having an interest in the proceeds payable under such contract or policy, for the purpose and with the intent of effecting settlement of such claims, loss, or damage under such contract or policy on less favorable terms than those provided in, and contemplated by, such contract or policy.
626.9541(1)(i)(3)(a) Failing to adopt and implement standards for the proper investigation of claims.
626.9541(1)(i)(3)(b) Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue.
626.9541(1)(i)(3)(d) Denying claims without conducting reasonable investigations based upon available information.
626.9541(1)(i)(3)(g) Failing to promptly notify the insured of any additional information necessary for the processing of a claim.
626.9541(1)(i)(3)(h) Failing to clearly explain the nature of the requested information and the reasons why such information is necessary.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

Reference to specific policy language: The violations alleged are statutorily based and do not rely on any specific policy language.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

American Security Insurance Company (the “Insurer”) has committed the following in handling the Insureds’ claim: 1) failure to act in due diligence and good faith to resolve claims; 2) placing the financial interest of Insurer before that of the Policy Holder and Claimant; 3) not adjusting the claims promptly and fairly; 4) not attempting in good faith to settle claims; 5) looking for ways to delay benefit payments; 6) shifting the burden of investigating the loss onto the Insureds; 7) conducting inadequate investigations; and 8) making material misrepresentations of the coverages afforded under the insurance policy. The Claimant timely submitted a claim to the Insurer on May 18, 2022, for damage sustained to the above-referenced insured property as a result of a water loss, which occurred on May 3, 2022. Given the scope and nature of the damage the Insured retained a public adjuster who produced an estimate of the covered damage dated June 8, 2022 detailing $12,827.46 in required repairs to the dwelling. On July 22, 2022, the Insurer sent a claims determination letter, which denied the Claimant’s claim. The letter merely advises, “[o]ur investigation indicates lack of documentation. Pending the plumber’s report with the cause of loss and description of rate and flow of water release. Denied for mold.” The claims determination letter fails to explain which documentation is lacking and copied and pasted boilerpoint language from the insurance policy. Furthermore, the Insurer never explains why the documentation is necessary for its investigation. The claims determination letter references a plumber’s report. The letter is unclear as to why the Insurer is awaiting a plumber’s report from the Claimant or from one it retained. The Claimant is not required to investigate its own claim and prove a cause of loss. The Insurer is capable of retaining its own plumber if it required a description of rate and flow of water release. The Insurer is shifting the burden and cost. Here, the Insurer shifted the burden and cost of investigating and insuring the loss onto the Claimant. The Insurer upon the Claimant’s loss had the duty to provide the full benefits under the policy. This includes providing the Claimant with the proper investigation and the funds necessary to return their home to its pre-loss condition. The Insurer here knows or should know that when independent perils converge and no single cause can be considered the sole or proximate cause, it is appropriate to apply the concurring cause doctrine. Sebo v. Am. Home Assurance Co., 208 So. 3d 694, 697 (Fla. 2016). The concurring cause doctrine states that coverage may exist where an insured risk constitutes a concurrent cause of the loss even when it is not the prime or efficient cause. Id. at 698. A covered peril that meets with an uncovered peril may still provide for coverage under a policy when the covered peril triggered the events that eventually led to the loss. Id. at 697. The Insurer intentionally ignored covered damage to deny the reported loss and wrongfully fail to pay the Claimant. This is an underhanded attempt to place the financial interests of the Insurer over those of the Claimant and to delay and frustrate the Claimant’s ability to have his claim adjusted promptly to begin restoring his property. Additionally, although there was interior water damage the adjuster did not use a water meter. A water meter can be purchased online from Amazon for around $40 before tax. The Insurer could purchase a water meter and assess thousands of properties with one meter. Instead, the Insurer would rather place its financial interests over those of the Claimant by failing to provide the adjuster with the necessary tools to correctly inspect the loss. As a result of the inadequate investigation and surrounding circumstances it is apparent that Insurer significantly underestimated the scope of the loss to the Claimant’s property. Insurer and its adjuster have colluded to misrepresent the true scope of damages to the insured property and the true replacement costs of the damages. This is an underhanded attempt to place the financial interest of Insurer over those of the Claimant, to delay the Claimant’s claim, and to delay the Claimant in restoring his property to its pre-loss condition. In short, Insurer is not acting with due regard for the Insureds’ interests or safety. In Florida the work of adjusting insurance claims engages the public trust. Insurers have a duty to treat all Claimants equally and the Insurer has breached this duty. The Insurer has conducted poor and inadequate investigations and has significantly underestimated the replacement costs of the Claimant’s property to further frustrate and delay the Claimant’s claim. The Insurer is placing their financial interests over those of the Claimant and the Claimant’s safety. The foregoing has only delayed the Claimant’s ability to begin restoring her home to its pre-loss condition. The Insurer’s actions amount to but are not limited to the following: 1. Claim delay 2. Not treating the policyholder with good faith claims conduct 3. Looking for ways to reduce recovery to the Claimant 4. Looking for ways to deny recovery to the Claimant 5. Not adjusting claims and evaluating loss properly, promptly and fairly to provide full and prompt indemnity to the Claimant 6. Not training, supervising or managing adjusters properly so that prompt and full payments are made, but rather placing the company’s interests before the policyholder’s interests 7. Placing the financial interest of the Insurer over that of the Claimant 8. Conducting inadequate investigations 9. Making material misrepresentations of the coverages afforded under the insurance policy. 10. Shifting the burden of investigating onto the Claimant Therefore, to cure the defects outlined in this Civil Remedy Notice, the Insurer must: (1) Admit full coverage for the Insureds’ loss. (2) Tender full benefits owed to the Insureds under the insurance contract. (3) Pay all attorney’s fees, costs, and interest. A copy of this form submitted to the FDFS has been sent via electronic mail to the following parties providing them notice of the filing of the civil remedy notice. Please e-mail any response to this civil remedy notice to badfaith@krapflegal.com. Via Electronic Mail: American Security Insurance Company d/b/a Assurant 260 Interstate North Cir., SE Atlanta, GA 30339-2210 myclaiminfo@assurant.com
Comments
User Id Date Added Comment
grant@krapflegal.com 12-27-2022 The details herein have been amicably resolved between the parties; therefore, we withdraw this Civil Remedy Notice. This Civil Remedy Notice is hereby withdrawn.
dcastiov@gmail.com 10-31-2022 Re: American Security Insurance Company’s Response to Civil Remedy Notice Filed by Borrower LaShawn Evans Dear Sir/Madam, This matter relates to a claim (claim number 00201496641 “the Claim”) made under a lender-placed policy (MLR870594604 “the Policy”) pursuant to LaShawn Evans’ lender’s Mortgage Service Program, in which the lender, Wells Fargo Bank, N.A. is the “Named Insured” and LaShawn Evans is the “Borrower”. This correspondence is American Security Insurance Company’s (“ASIC”) response to the Civil Remedy Notice (No. 651000) (the “Notice” or “CRN”), filed on October 12, 2022 by Grant Krapf, as counsel for LaShawn Evans (“Claimant”). ASIC objects to the validity of the Notice filed, as it is deficient on its face. The Notice lacks the specificity required by Florida Statutes Section 624.155(3)(a). The Notice does not identify any factual support for any section of the Statutes claimed to have been violated. The Notice provides nothing more than vague, ambiguous, and conclusory allegations of what Claimant believes to be ASIC’s motivations, positions, and business practices—none of which are supported by any facts or examples. Florida jurisprudence is clear that a claimant is required to state with specificity the “facts and circumstances giving rise to the violation,” to allow ASIC to understand and cure any purported violation. Longpoint Condo. Assn. v. Allstate Ins. Co., 2005 WL 1315810 (N.D. Fla. 2005). A written CRN which is vague and “shotgun” in nature or is written in general terms fails the specificity requirement of the statute. See Heritage Corp. of South Fla. v. National Union Fire Ins. Co. of Pittsburgh, P.A., 580 F. Supp. 2d 1294, 1300 (S.D. Fla. 2008); Rousso v. Liberty Surplus Ins. Corp., 2010 WL 7367059 (S.D. Fla. 2010); Valenti v. Unum Life Ins. Co. of America, 2006 WL 1627276 (M.D. Fla. 2006). The very purpose of the civil remedy notice, pursuant to Chapter 624, is to inform the insurer of alleged violations with specific information to encourage settlement of the subject claim. “The sixty-day window [as provided for in F.S. §624.155] is designed to be a cure period that will encourage payment of the underlying claim, and avoid unnecessary bad faith litigation.” Talat Enters., Inc. v. Aetna Cas. & Sur. Co., 753 So.2d 1278 (Fla. 2000). Notice sent to the Department of Insurance concerning settlement violation(s) is intended to serve as a basis for the Department to assist in the settling of claims and to monitor the insurance industry. Id. However, when an insured or Borrower provides little in the way of adequate notice, the statutory intent is frustrated. Without any specificity alleged whatsoever, ASIC is in the untenable position of defending multiple allegations of improper conduct without any precise information. It is for these reasons ASIC requests the Department find the Notice deficient. In further response to the Notice, ASIC categorically denies all of the allegations contained in the Notice and specifically denies that it has violated the Florida Statutes cited in the Notice in its handling of the subject claim. The Notice goes on to complain of actions taken by ASIC in connection with a lawsuit filed by LaShawn Evans, all of which are protected by the litigation privilege: A. 624.155(1)(b)(1) - Not attempting in good faith to settle claims when, under all the circumstances, it could and should have done so, had it acted fairly and honestly toward its insured and with due regard for her or his interests. RESPONSE: At all times, ASIC acted in good faith, fairly and honestly towards the Claimant, with due regard for his interests. ASIC’s records show that ASIC received notice of the subject loss on May 18, 2022, with a reported date of loss of May 3, 2022. ASIC sent a letter acknowledging the claim on the day after it received notice, May 19, 2022. ASIC then engaged an independent adjuster to inspect the property. ASIC issued a letter to Claimant’s public adjuster requesting a letter of representation, plumber’s report, estimate and photographs on May 31, 2022. The independent adjuster inspected the subject property on June 7, 2022. After the initial inspection, ASIC, once again, requested the LOR and plumber’s report with photographs via letter dated July 11, 2022. Thereafter, ASIC issued its coverage determination letter on July 22, 2022, providing an explanation for policy benefits. ASIC’s coverage letter indicated lack of documentation – referencing its prior request for a plumbers report with the cause of loss and description of rate and flow of water release. Per the terms of the Policy, Claimant is required to cooperate with ASIC in its investigation. Nevertheless, Claimant failed to respond to ASIC’s request for documentation prior to filing suit. ASIC further denied any mold associated with the subject Claim and cited to relevant policy exclusions in support of its denial. Claimant filed suit on or about September 16, 2022. Although the Notice alleges that ASIC violated Florida Statutes Section 624.155(1)(b)(1) by failing to “settle claims in good faith,” ASIC has at all times acted in good faith, fairly and honestly towards the Claimant, with due regard for his interests. ASIC caused the Property to be inspected and issued a determination based on the findings from such inspection. Because the Claim was rightfully denied, ASIC does not owe a duty settle the subject claim. B. 626.9541(1)(i)(2) – A material misrepresentation made to an insured or any other person having an interest in the proceeds payable under such contract or policy, for the purpose and with the intent of effecting settlement of such claims, loss, or damage under such contract or policy on less favorable terms than those provided in, and contemplated by, such contract or policy. RESPONSE: ASIC denies that it has violated Florida Statutes Section 626.9541(1)(i)(2), as alleged in the Notice. By its terms, Florida Statutes Section 626.9541(1)(i)(2) contemplates a situation where the insurer made a material msirepresentation to a person having interest in the proceeds under a policy. ASIC has at all times requested documents and provided a thorough explanation of Claimant’s benefits when it provided a coverage determination letter advising that the policy does not cover damage due to constant or repeated seepage or leakage of water or steam over a period of weeks, months or years; damage due to wear and tear, damge related to smog, rust or corrosion, fungi, mold; and/or damage related to settling, shrinking, bulging or expansion. The coverage determination further explains that damage due to neglect and/or faulty, inadequate, or defective design specifications, workmanship, repair, constructon; materials used in repair and/or lack of maintenance is excluded under the Policy. Lastly, under the Policy the following damage is excluded: water damage, meaning (1) flood, surface water, waves, tidal, overflow of water; (2) water or water borne material; and (3) water or water borne material below the surface of the ground. While the CNR alleges that ASIC and its adjuster “colluded to misrepresent the true scope of damages to the insured property and the true replacement costs of the damages,” ASIC denied the subject claim and therefore did not scope out the damages for the Claimant. ASIC denies it has made any misrepresentations relating to the subject claim. Florida Statutes Section 626.9541(1)(i)(2) is wholly inapplicable to this claim. Furthermore, the Claimant has provided nothing but broad, shotgun-style, conclusory statements with no specificity as to how the section has been purportedly violated. C. 626.9541(1)(i)(3)(a) - Failing to adopt and implement standards for the proper investigation of claims. RESPONSE: ASIC denies that it has violated Florida Statutes Section 626.9541(1)(i)(3)(a), as alleged in the Notice. The Claimant merely cites to the statute, without providing any factual support for this allegation. Furthermore, the Claimant fails to identify what standards for the proper investigation of claims ASIC has failed to adopt. This allegation is defective as it does nothing but state an insufficient and conclusory shotgun-style statement with no specificity as to how the section was purportedly violated. ASIC’s records show that ASIC received notice of the subject loss on May 18, 2022, with a reported date of loss of May 3, 2022. ASIC sent a letter acknowledging the claim on the day after it received notice, May 19, 2022. ASIC then engaged an independent adjuster to inspect the property. ASIC issued a letter to Claimant’s public adjuster requesting a letter of representation, plumber’s report, estimate and photographs on May 31, 2022. The independent adjuster then inspected the subject property on June 7, 2022. After the initial inspection, ASIC, once again, requested the LOR and plumber’s report with photographs via letter dated July 11, 2022. Thereafter, ASIC issued its coverage determination letter on July 22, 2022, providing an explanation for policy benefits. ASIC’s coverage letter indicated lack of documentation – referencing its prior request for a plumbers report with the cause of loss and description of rate and flow of water release. Per the terms of the Policy, Claimant is required to cooperate with ASIC in its investigation. Nevertheless, Claimant failed to respond to ASIC’s request for documentation prior to filing suit. ASIC further denied any mold associated with the subject Claim and cited to relevant policy exclusions in support of its denial. Claimant filed suit on or about September 16, 2022. Although the Notice alleges that ASIC violated Florida Statutes Section 626.9541(1)(i)(3)(a) by failing to “properly investigate the claim,” Claimant does not specify how ASIC failed to “properly” investigate the claim and has failed to provide any additional details on which actions he views as improper. Without any supplement from Claimant, ASIC is unable to further evaluate this alleged violation. D. 626.9541(1)(i)(3)(b) – Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue RESPONSE: ASIC denies that it has violated Florida Statutes Section 626.9541(1)(i)(3)(b), as alleged in the Notice. The Claimant merely cites to the statute, without providing any factual support for this allegation. Furthermore, the Claimant fails to identify what standards for the proper investigation of claims ASIC has failed to adopt. This allegation is defective as it does nothing but state an insufficient and conclusory shotgun-style statement with no specificity as to how the section was purportedly violated. ASIC has followed its standards for the proper investigation of claims when dealing with the subject claim. ASIC’s records show that ASIC received notice of the subject loss on May 18, 2022, with a reported date of loss of May 3, 2022. ASIC sent a letter acknowledging the claim on the day after it received notice, May 19, 2022. ASIC then engaged an independent adjuster to inspect the property. ASIC issued a letter to Claimant’s public adjuster requesting a letter of representation, plumber’s report, estimate and photographs on May 31, 2022. The independent adjuster then inspected the subject property on June 7, 2022. After the initial inspection, ASIC, once again, requested the LOR and plumber’s report with photographs via letter dated July 11, 2022. Thereafter, ASIC issued its coverage determination letter on July 22, 2022, providing an explanation for policy benefits. ASIC’s coverage letter indicated lack of documentation – referencing its prior request for a plumbers report with the cause of loss and description of rate and flow of water release. Per the terms of the Policy, Claimant is required to cooperate with ASIC in its investigation. Nevertheless, Claimant failed to respond to ASIC’s request for documentation prior to filing suit. ASIC further denied any mold associated with the subject Claim and cited to relevant policy exclusions in support of its denial. Claimant filed suit on or about September 16, 2022. Although the Notice alleges that ASIC violated Florida Statutes Section 626.9541(1)(i)(3)(b), by “misrepresenting the facts or insurance policy provisions relating to coverage,” ASIC has at all times acted in good faith, fairly and honestly towards the Claimant, with due regard for his interests. ASIC explained all the benefits under the policy in its multiple letters to the homeowner as it related to the claim reported to ASIC. F. 626.9541(1)(i)(3)(d) – Denying claims without conducting reasonable investigations based upon available information. RESPONSE: ASIC denies that it has violated Florida Statutes Section 626.9541(1)(i)(3)(d), as alleged in the Notice. Claimant merely cites to the statute, without providing any factual support for this allegation. Claimant fails to state what how ASIC failed to conduct a reasonable investigation of the claim. ASIC received the loss notice, requested documents on several occasions, inspected the property and issued a coverage determination letter explaining applicable policy provisions. ASIC’s records show that ASIC received notice of the subject loss on May 18, 2022, with a reported date of loss of May 3, 2022. ASIC sent a letter acknowledging the claim on the day after it received notice, May 19, 2022. ASIC then engaged an independent adjuster to inspect the property. ASIC issued a letter to Claimant’s public adjuster requesting a letter of representation, plumber’s report, estimate and photographs on May 31, 2022. The independent adjuster then inspected the subject property on June 7, 2022. After the initial inspection, ASIC, once again, requested the LOR and plumber’s report with photographs via letter dated July 11, 2022. Thereafter, ASIC issued its coverage determination letter on July 22, 2022, providing an explanation for policy benefits. ASIC’s coverage letter indicated lack of documentation – referencing its prior request for a plumbers report with the cause of loss and description of rate and flow of water release. Per the terms of the Policy, Claimant is required to cooperate with ASIC in its investigation. Nevertheless, Claimant failed to respond to ASIC’s request for documentation prior to filing suit. ASIC further denied any mold associated with the subject Claim and cited to relevant policy exclusions in support of its denial. Claimant filed suit on or about September 16, 2022. Although the Notice alleges that ASIC violated Florida Statutes Section 626.9541(1)(i)(3)(d) by failing to “conduct reasonable investigations based upon available information,” Claimant fails to provide specific information on how ASIC failed to conduct a reasonable investigation of the subject claim. Furthermore, ASIC has at all times acted in good faith in conducting its reasonable investigation of the claim. G. 626.9541(1)(i)(3)(g) – Failing to promptly notify the insured of any additional information necessary for the processing of a claim. RESPONSE: ASIC denies that it has violated Florida Statutes Section 626.9541(1)(i)(3)(g), as alleged in the Notice. Claimant merely cites to the statute, without providing any factual support for this allegation. Claimant fails to state what ASIC failed to promptly notify the insured. ASIC’s records show that ASIC received notice of the subject loss on May 18, 2022, with a reported date of loss of May 3, 2022. ASIC sent a letter acknowledging the claim on the day after it received notice, May 19, 2022. ASIC then engaged an independent adjuster to inspect the property. ASIC issued a letter to Claimant’s public adjuster requesting a letter of representation, plumber’s report, estimate and photographs on May 31, 2022. Nevertheless, the independent adjuster inspected the subject property on June 7, 2022. After the initial inspection, ASIC, once again, requested the LOR and plumber’s report with photographs via letter dated July 11, 2022. Thereafter, ASIC issued its coverage determination letter on July 22, 2022, providing an explanation for policy benefits. ASIC’s coverage letter indicated lack of documentation – referencing its prior request for a plumbers report with the cause of loss and description of rate and flow of water release. Per the terms of the Policy, Claimant is required to cooperate with ASIC in its investigation. Nevertheless, Claimant failed to respond to ASIC’s request for documentation prior to filing suit. ASIC further denied any mold associated with the subject Claim and cited to relevant policy exclusions in support of its denial. Claimant filed suit on or about September 16, 2022. Although the Notice alleges that ASIC violated Florida Statutes Section 626.9541(1)(i)(3)(g) by failing to “promptly notify the insured of any additional information necessary for processing the claim,” ASIC cannot have violated this section because it fully advised the homeowner of his rights under the policy and to submit further supporting documentation, if any. H. 626.9541(1)(i)(3)(h) – Failing to clearly explain the nature of the requested information and the reasons why such information is necessary. RESPONSE: ASIC denies that it has violated Florida Statutes Section 626.9541(1)(i)(3)(h), as alleged in the Notice. Claimant merely cites to the statute, without providing any factual support for this allegation. Claimant fails to state what ASIC failed to clearly explain the nature of the requested information and the reasons why such information is necessary. ASIC advised the homeowner of his rights under the policy and requested information that supported the alleged damages in order to aid ASIC’s investigation. ASIC’s records show that ASIC received notice of the subject loss on May 18, 2022, with a reported date of loss of May 3, 2022. ASIC sent a letter acknowledging the claim on the day after it received notice, May 19, 2022. ASIC then engaged an independent adjuster to inspect the property. ASIC issued a letter to Claimant’s public adjuster requesting a letter of representation, plumber’s report, estimate and photographs on May 31, 2022. Nevertheless, the independent adjuster inspected the subject property on June 7, 2022. After the initial inspection, ASIC, once again, requested the LOR and plumber’s report with photographs via letter dated July 11, 2022. Thereafter, ASIC issued its coverage determination letter on July 22, 2022, providing an explanation for policy benefits. ASIC’s coverage letter indicated lack of documentation – referencing its prior request for a plumbers report with the cause of loss and description of rate and flow of water release. Per the terms of the Policy, Claimant is required to cooperate with ASIC in its investigation. Nevertheless, Claimant failed to respond to ASIC’s request for documentation prior to filing suit. ASIC further denied any mold associated with the subject Claim and cited to relevant policy exclusions in support of its denial. Claimant filed suit on or about September 16, 2022. Although the Notice alleges that ASIC violated Florida Statutes Section 626.9541(1)(i)(3)(h) by failing to “to clearly explain the nature of the requested information and the reasons why such information is necessary,” ASIC cannot have violated this section because it fully explained the homeowner’s rights under the policy and requested that he provide any documentation that supported his alleged claim for loss. CONCLUSION Contrary to any assertions set forth in the CRN or otherwise, at all times material to this claim, ASIC promptly acknowledged and investigated LaShawn Evans’ claim. Based upon the foregoing, Claimant’s Notice is devoid of sufficient facts and circumstances to support his accusations of wrongdoing under the statutory provisions identified. The Notice is devoid of detail, deficient on its face, and not supported by the facts. Thus, the allegations in the Notice are without merit. Should you have any questions or if we can be of any further assistance, please do not hesitate to contact us.
Acknowledgement
* The submitter hereby states that this notice is given in order to perfect the rights of the person(s) damaged to pursue civil remedies authorized by Section 624.155, Florida Statutes.

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DFS-10-363
Rev. 10/14/2008