Civil Remedy Notice of Insurer Violations
Login

Filing Number:     781526
Filing Accepted:  9/5/2024
         Print Filing
Complainant
Last/Business Name *  
LENNAR HOMES, LLC   First Name  
Street Address * 5505 WATERFORD DISTRICT DRIVE
City, State Zip * MIAMI, FL 33126
Email Address * LKERR@COGBURNLEGAL.COM
Complainant Type: * Insured
Insured
Last/Business Name*   VICTOR’S STUCCO, INC.   First Name  
Policy # * AGL0016344-02 (2016-17); AGL0016344-03 (2017-18) Claim #* 000014025100
Attorney
Attorney is Applicable
Last Name* KERR First Name * LAUREN Initial D
Street Address* 777 S. HARBOUR ISLAND BLVD., SUITE 245
City, State Zip* TAMPA , FL 33602
Email Address * LKERR@COGBURNLEGAL.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   ARCH SPECIALTY INSURANCE COMPANY
NAIC Company Code 21199
 
Name of individual responsible for violation (if any):* GARTNER+BLOOM, ATTORNEYS FOR ARCH SPECIALTY INSURANCE COMPANY
Type of Insurance * Commercial Property & Casualty   
Reason for Notice *
Claim Denial
Claim Delay
Unfair Trade Practice
* 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)(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.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

Victor’s Stucco, Inc. (“Victors”) purchased at least two commercial general liability (“CGL”) policies from Arch Specialty Insurance Company ("ARCH”) providing coverage for liability because of property damage resulting from Victors’ work, specifically Policy Numbers AGL0016344-02 (2016-17) and AGL0016344-03 (2017-18) (the “Policies”). The insuring agreements of the Policies state, in relevant part: We will pay those sums that the insured becomes legally obligated to pay as damages because of … “property damage” to which this insurance applies. We will have the right and duty to defend the insured against any “suit” seeking those damages … The Policies define “property damage” to include: a. Physical injury to tangible property, including all resulting loss of use of that property … or b. Loss of use of tangible property that is not physically injured … For coverage to be afforded, “property damage” must have been caused by an “occurrence,” which is defined under the Policies as “an accident, including continuous or repeated exposure to substantially the same general harmful conditions”. Not only do the Policies provide coverage to the named insured, Victors, they also provide coverage to Lennar Homes, LLC (“Lennar”) as an additional insured. The Policies contain the following endorsement: BLANKET ADDITIONAL INSURED ENDORSEMENT This endorsement modifies insurance provided under the following: COMMERCIAL GENERAL LIABILITY COVERAGE PART SECTION II – WHO IS AN INSURED is amended to include as an additional insured those persons or organizations who are required under a written contract with you to be named as an additional insured, but only with respect to liability for … “property damage” … caused, in whole or in part, by your acts or omission or the acts or omissions of your subcontractors: a. In the performance of your ongoing operations or “your work”, including “your work” that has been completed . . . The subcontract between Lennar and Victors required that Victors name “Lennar Corporation including its subsidiaries [&] … affiliated companies…” as additional insureds on its CGL policies of insurance for Victors’ ongoing and products/completed operations. Lennar Homes, LLC is a subsidiary/affiliate company of Lennar Corporation.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

This civil remedy notice is being filed because Arch Specialty Insurance Company (“ARCH”) has failed to address Lennar Homes, LLC’s (“Lennar”) tenders of defense in good faith. The ARCH policies implicated are Policy Numbers AGL0016344-02 (2016-17) and AGL0016344-03 (2017-18) (the “Policies”). Lennar has been named as a defendant in an arbitration action styled as Joshua Leigh Vaughan and Amanda Taylor Vaughan v. Lennar Homes, LLC (the “Lawsuit”). The Lawsuit alleges property damage resulting from stucco system-related claims due to work performed by Lennar’s stucco subcontractor, Victor’s Stucco, Inc. (“Victors”). During original construction, Victors performed work on the project pursuant to the terms and conditions of its subcontract with Lennar. Because of the pending allegations and Victors’ work at the subject property, Lennar tendered the claim to ARCH. To date, ARCH has failed to provide either Lennar or Victors with a defense in the Lawsuit. Included in the subcontract between Lennar and Victors was a requirement that Victors would secure commercial general liability ("CGL") insurance and name Lennar as an Additional Insured. Victors purchased at least two policies, the Policies, from ARCH, which provide coverage for liability because of property damage resulting from Victors’ work. This coverage extends to both the named insured, Victors, and the additional insured, Lennar. The Policies provides blanket coverage where required by written contract, as described supra. Because the written subcontract required Victors to name Lennar as an additional insured, Lennar is an additional insured under the Policies. This claim has been pending for over a year without ARCH’s participation. Lennar tendered its defense to ARCH on or about August 23, 2023. Lennar again tendered its defense to ARCH on May 20, 2024 and provided ARCH with notice of the Lawsuit. On August 14, 2024, ARCH denied Lennar’s tender of defense. ARCH’s refusal to provide a defense is knowingly wrongful because the Lawsuit, as pled, implicates coverage under the Policies and does not clearly implicate any exclusions under the Policies. "Under Florida law, an insurer's duty to defend its insured against legal action is quite broad, and 'is determined by comparing the allegations contained within the four corners of the underlying complaint with the language of the policy.'" Zurich Am. Ins. Co. v. Southern- Owners Ins. Co., 314 F. Supp. 3d 1284, 1299 (M.D. Fla. 2018) (Howard, J.) citing Addison Ins. Co. v. 4000 Island Blvd. Condo. Ass'n, Inc., 263 F. Supp. 3d 1266, 1269 (S.D. Fla. 2016) (quoting Jones v. Fla. Ins. Guar. Ass'n Inc., 908 So. 2d 435, 443 (Fla. 2005)). That is, an insurer's duty to defend is determined solely by the allegations in the underlying complaint. Zurich, 314 F. Supp. 3d at 1299 citing Category 5 Mgmt. Grp., LLC v. Companion Prop. & Cas. Ins. Co., 76 So. 3d 20, 23 (Fla. 1st DCA 2011); Lawyers Title Ins. Corp. v. JDC (Am.) Corp., 52 F.3d 1575, 1580 (11th Cir. 1995). "The duty arises when the relevant pleadings allege facts that 'fairly and potentially bring the suit within policy coverage.'" Id. citing Lawyers Title Ins. Corp., 52 F.3d at 1580 (quoting Lime Tree Vill. Cmty. Club Ass'n, Inc. v. State Farm Gen. Ins. Co., 980 F.2d 1402, 1405 (11th Cir. 1993)). The actual facts of the situation are not relevant, such that "the insurer must defend even if facts alleged are actually untrue or legal theories unsound." Id. As a result, "an insurer's duty to defend is distinct from, and broader than, the duty to indemnify," Id. citing Sinni v. Scottsdale Ins. Co., 676 F. Supp. 2d 1319, 1323 (M.D. Fla. 2009), which "must be determined by analyzing the policy coverage in light of the facts in the underlying case," J.B.D. Constr., Inc. v. Mid-Continent Cas. Co., 571 F. App'x 918, 927 (11th Cir. 2014) (emphasis added). In addition, where an injured party "alleges facts partially within and partially outside the coverage of the policy, the insurer is obligated to defend the entire suit." Category 5 Mgmt. Grp., LLC, 76 So. 3d at 23. The only way an insurer can avoid its duty to defend based on an exclusion is by showing that the allegations in the underlying complaint fall solely and entirely within that exclusion. See Lime Tree Vill. Cmty. Club Ass’n, Inc. v. State Farm Gen. Ins. Co., 980 F.2d 1402, 1405-07 (11th Cir. 1993); see also Northland Cas. Co. v. HBE Corp., 160 F. Supp. 2d 1348, 1359 (M.D. Fla. 2011). “If the allegations of the complaint leave any doubt regarding the duty to defend, the question must be resolved in favor of the insured requiring the insurer to defend.” Baron Oil Co. v. Nationwide Mut. Fire Ins. Co., 470 So. 2d 810, 814 (Fla. 1st DCA 1985); see also Higgins v. State Farm Fire & Cas. Co., 894 So. 2d 5, 10 (Fla. 2004) (approving standard articulated in Baron Oil); Voeller Constr., Inc. v. Southern-Owners Ins. Co., No. 8:13-cv-3169, 2014 U.S. Dist. Lexis 61862 at *4 (M.D. Fla. May 5, 2014). Lennar disputes the application of any policy exclusions to the Lawsuit entirely. However, even if the exclusions did apply to the Lawsuit, the allegations of the Lawsuit do not fall solely and entirely within ARCH’s purported exclusions and therefore ARCH cannot avoid its duty to defend its insureds. ARCH appears to be relying on the “Residential and Residential Conversion Limitation Endorsement” of the Policies, but it does not apply. The exclusion plainly provides for three exceptions: “[t]his endorsement shall not apply where such development or construction does not exceed 12 units in any one dwelling or housing development or when work is performed on a property that has obtained a certificate of occupancy prior to such work being performed.” The first exception to the exclusion applies to this matter - as the exception plainly reads that “[t]his endorsement shall not apply where such … construction … does not exceed 12 units in any one dwelling…”. The instant matter involves a single-family home and does not exceed 12 units in any one dwelling. At best, the exclusion is ambiguous. “Generally, insurance coverage must be broadly construed in favor of the insured, which exclusions must be narrowly construed against the insurer. . . Further, ambiguous policy provisions are interpreted liberally in favor of the insured and strictly against the drafter who prepared the policy…”. Air Quality Assessors of Florida v. Southern-Owners Ins. Co., 354 So. 3d 569, 572 (Fla. 1st DCA 2022) (internal citations omitted). Moreover, the classification page of the Policies specifically indicates Victors would be performing plastering or stucco work on one- or two-family dwellings and Victors named several residential home developers as additional insureds on the endorsements of the Policies. Therefore, Arch cannot claim in good faith to have issued the Policies to Victors to perform work on one-or two-family homes and name residential home builders as additional insureds, and simultaneously argue the endorsement bars coverage for any property damage resulting from Victors’ work on same. ARCH’s failure to defend its insureds has prejudiced and damaged Lennar. Lennar has been forced to incur defense costs in the Lawsuit, for which ARCH is responsible. The Lawsuit includes allegations of losses covered under the Policies. Under Florida law, ARCH’s duty to defend its insureds was triggered by the Plaintiffs’ allegations, whether they are proven to be true or not. ARCH’s unreasonable handling of Lennar’s claim has caused it to incur substantial legal fees and costs in defending itself against the claims. The attorneys' fees and costs that Lennar has incurred have unjustly burdened Lennar. ARCH has also prejudiced and damaged its named insured by exposing Victors to Lennar’s claim to recover these substantial fees and costs. Lennar has exhausted all available options to convince ARCH to deal with Lennar in good faith, to no avail. Additionally, ARCH has failed to appropriately consider or explore settlement opportunities, subjecting Lennar and Victors to exposure to a verdict. Moreover, by refusing to defend Lennar, ARCH has greatly exposed its named insured Victors to a much larger claim for Lennar’s defense costs in this matter pursuant to the contractual indemnification provisions in the subcontract. Victors and Lennar are deluged with claims arising from Victors’ work. ARCH must exercise its duty of good faith to both Lennar and Victors and must employ “the same degree of care and diligence as a person of ordinary care and prudence should exercise in the management of his own business.” Farinas v. Florida Farm Bureau Gen. Ins. Co., 850 So. 2d 555 (Fla. 4th DCA 2003) (internal citations omitted). Under Farinas, ARCH is obligated to fully investigate all claims at hand to determine how to best limit its insured’s liability; (2) seek to settle as many claims as possible within the policy limits; (3) minimizing the magnitude of possible excess judgments against its insureds by reasoned claim settlement; and (4) keeping the insureds informed of the claim resolution process. ARCH’s obligations extend to all the insureds under the Policies and are not limited to the named insured. Thus ARCH’s obligations extend to additional insureds, like Lennar. To date, Lennar is unaware of ARCH’s investigation, if any, of the claims against Lennar, or its efforts, if any, to resolve as many of the claims against Lennar as possible within existing policy limits. Likewise, ARCH has never advised Lennar how, or if, it intends to minimize the magnitude of possible excess judgments against insured Victors or Lennar, nor has ARCH apprised Lennar of any claim resolution process. Given ARCH’s lack of participation and the other facts outline above, ARCH has utterly failed or even attempted to meet the standard for good faith in this matter. Lennar will be filing suit against ARCH but is also filing this notice in an effort to provide ARCH with a last opportunity to deal with Lennar in good faith as well as to perfect its right to pursue the remedies provided under Section 624.155, Florida Statutes. ARCH can cure by acknowledging its duty to defend and reimbursing Lennar its reasonable defense costs incurred to date and working together with Lennar to resolve this claim.
Comments
User Id Date Added Comment
rca@gartnerbloom.com 11-04-2024 This is Arch Specialty Insurance Company’s (“Arch”) timely response to the Civil Remedy Notice (“CRN”) filed by Lennar Homes, LLC (“Lennar” or “Complainant”) and accepted by the Department of Financial Services on September 5, 2024, bearing Filing Number 781526. Arch is an eligible surplus lines insurer in the State of Florida. The CRN refers to policies AGL0016344-02 issued to Victor’s Stucco, Inc. (“Victor’s” or the “Insured”), which was in effect between August 13, 2016 and August 13, 2017 and AGL0016344-03 which was in effect between August 13, 2017 and August 13, 2018 (the “Arch Policies”).1 Notably, Lennar is not a named insured under the Arch Policies. Arch denies all allegations in the CRN, which is substantively and procedurally defective and should be withdrawn. Arch denies any wrongdoing in connection with this matter. Not only is the CRN both procedurally and substantively defective, it is also rife with demonstrably false statements and evidences Complainant’s violation of Fla. Stat. §624.155(5), which requires the claimant to act in good faith. The CRN misidentifies counsel for Arch as the person(s) “representing the insurer who are most responsible for/knowledgeable of the facts giving rise to the allegations in this notice.” The person(s) “representing the insurer who are most responsible for/knowledgeable of the facts giving rise to the allegations in this notice” is Barbara Schlessinger of Fortitude P&C Solutions, Inc., authorized claims administrator for Arch. Ms. Schlessinger can be contacted through counsel for Arch identified herein. I. The CRN Does Not Comply with Florida Law The purpose of a Civil Remedy Notice is to put an insurer on notice of an alleged violation, provide the attendant circumstances, and explain the details of the alleged violation in order to provide the insurer with 60 days to “cure” the alleged claim defects. See Talat Enterprises, Inc. v. Aetna Casualty and Surety Co., 753 So.2d 1278 (Fla. 2000). A valid civil remedy notice must include sufficient specificity to put the insurer on notice of what actions it can take to “cure” the alleged violations and provide a reasonable opportunity to do so. Factually insufficient civil remedy notices fail to satisfy a necessary condition precedent to a bad faith cause of action. Julien v. United Property & Casualty Insurance Company, 311 So.3d 875 (Fla. 4th DCA 2021). The CRN contends Arch violated 624.155(1)(b)(1), “[n]ot 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.” The CRN further alleges that Arch violated 626.9541(1)(i)(3)(a), “[f]ailing to adopt and implement standards for the proper investigation of claims.” The CRN alleges that Arch violated 626.9541(1)(i)(3)(b), “[m]isrepresenting pertinent facts or insurance policy provisions relating to coverages at issue.” The CRN alleges that Arch violated 626.9541(1)(i)(3)(d), “[d]enying claims without conducting reasonable information based upon available information.” Arch denies these allegations. The CRN alleges that the Arch Policies provide “coverage for liability because of property damage resulting from Victors’ [sic] work…” which not only provide coverage to the Named Insured, Victor’s but “also provide coverage to Lennar Homes, LLC, as an additional insured.” The CRN claims that Arch has “failed to address Lennar Homes, LLC’s…tenders of defense in good faith.” This is incorrect and Arch denies these allegations. The CRN describes a purported arbitration action in which the homeowners, Joshua Leigh Vaughan and Amanda Taylor Vaughan (“Vaughans”), “sued” Lennar for property damage “resulting from stucco system-related claims due to work performed by Lennar’s stucco subcontractor”, Victor’s (the “Arbitration”). The CRN asserts that Arch failed to provide a defense to either Lennar or Victor’s in the Arbitration. Although Lennar alleges in the CRN that Arch has failed to provide a defense to Victor’s, no Demand for Arbitration against Victor’s was ever provided to Arch, and Victor’s has not sought a defense from Arch. Arch has no duty to defend Victor’s, and no duty to defend Lennar, because the Arch Policies unambiguously exclude coverage for the Vaughans’ claim. Arch has advised Victor’s and Lennar of its position multiple times. Arch denies any allegations of statutory violations and violations of Florida law in the CRN. Arch further confirms it denied coverage after a good faith investigation, which Arch first communicated to Lennar, in response to Lennar’s August 23, 2023 tender, by letter dated October 10, 2023. Arch responded to Lennar’s Demand for a Defense to the Arbitration on August 14, 2024. The October 10, 2023 letter and August 14, 2024 letter speak for themselves and are incorporated herein by reference. In addition, Arch reiterated its coverage position regarding the Vaughans’ claim by letters dated October 17, 2023, December 12, 2023, January 11, 2024, March 7, 2024, June 13, 2024 and September 4, 2024. The CRN seeks a defense, reasonable defense costs incurred in the Arbitration to date, and “working together with Lennar to resolve this claim.” Arch denies that it owes Lennar a defense and objects to the “cure” to the extent it seeks remedies that are not recoverable under Florida law. Arch maintains its coverage position, which has been communicated to Lennar with respect to the Vaughans’ claim no less than eight separate times. Because the CRN is facially defective, factually incorrect, does not state with specificity the information required by Fla. Stat. Section 624.155(3)(b), and includes unavailable remedies to cure, it should be withdrawn. Please allow the below to summarize Arch’s position and its good faith investigation. II. Arch’s Good Faith Investigation Lennar purported to tender its defense of the Arbitration on or about May 20, 2024 in a document titled Supplemental Tender of Indemnity and Defense, Demand for Full, Complete, Certified Copy of Insurance Policy, and Lennar’s Demand for Arbitration. Arch responded on August 14, 2024. In conjunction with Lennar’s August 23, 2023 Tender and its May 20, 2024 Supplemental Tender, Lennar included, among other things, a December 28, 2021 Notice of Construction Defect under Florida Statute 558 regarding the Vaughan Home (“Home”), with two exhibits: an December 13, 2021 Report of Structural Engineering and Inspections, Inc. and a December 17, 2021 Repair Estimate of SS Consultation Services, LLC. Lennar also included, among other things, A Master Trade Partner Agreement dated November 1, 2016 between Lennar and Victor’s, an April 14, 2017 Certificate of Occupancy for the Home, and a Vendor Payment record reflecting that Victor’s performed stucco work at the Home in the Storey Park Community before February 14, 2017. The Storey Park Community is a large housing development exceeding 100 homes, in Orlando Florida. Lennar seeks coverage under the Arch Policies as an additional insured. Whether Lennar qualifies as an additional insured under the Arch Policy depends upon whether Lennar has been sued for vicarious liability. The Statement of the Nature of the Dispute included with the Vaughans’ Demand for Arbitration dated August 7, 2023, does not include a cause of action for vicarious liability against Lennar. Amerisure Ins. Co. v. Seneca Specialty Ins. Co., 20-20442-CIV, 2020 WL 3317035, at *7 (S.D. Fla. June 18, 2020) (interpreting identical policy language to that at issue and finding that absent a separately pleaded cause of action for vicarious liability that specifically implicates the named insured’s work, there is no additional insured coverage and no duty to defend a purported additional insured). Accordingly, Lennar does not qualify as an additional insured under the Arch Policies. The Arch Policies include, in part, the following language under the Commercial General Liability Coverage Form at Section 2., Exclusions: RESIDENTIAL AND RESIDENTIAL CONVERSION LIMITATION ENDORSEMENT This insurance does not apply to any claim, “suit”, demand or loss that alleges: A. “Bodily injury”, “property damage”, or “personal and advertising injury” that in any way arises out of, relates to or results from the new development or construction, in whole or in part, of any: (1) “Non-commercial dwelling or residence”; or (2) Building converted at any time, in whole or in part, to a “non-commercial dwelling or residence” B. “Property damage” included within the “products-completed operations hazard” to any: (1) “Non-commercial dwelling or residence”; or (2) Building which is converted, in whole or in part, to a “non-commercial dwelling or residence” at any time. This endorsement shall not apply where such development or construction does not exceed 12 units in any one dwelling or housing development or when work is performed on a property that has obtained a certificate of occupancy prior to such work being performed. For purposes of this endorsement, “non-commercial dwellings or residences” include, but are not limited to, homes, condominiums, cooperatives, town homes, lofts and time-share properties. However, “noncommercial dwellings or residences” do not include: (1) Apartment buildings and other residential dwellings wherein all of the residential units are held for rental or lease to the general public; (2) Hotels or motels, except any units within or otherwise part of such hotels or motels that are condominiums, time-share properties or similar types of property sold to others. All other terms and conditions of this Policy remain unchanged. Therefore, even if Lennar somehow qualified as an additional insured under the Arch Policies, which it does not, the Residential and Residential Conversion Limitation endorsement unambiguously excludes coverage for the Vaughan claim. Lennar, having sought a defense from Arch for 12 homes as of the date of Arch’s October 10, 2023 coverage position letter, cannot meet its burden to show that the exceptions to the Arch Residential and Residential Conversion Limitation endorsement apply. LaFarge Corp. v. Travelers Indem. Co., 118 F.3d 1511, 1516 (11th Cir. 1997); Certain Underwriters at Lloyd's London Subscribing to Policy BRT3A000415-02 v. A.M.A. Consulting & Constr. Services, Inc., 21-CV-20979, 2022 WL 542893, at *7 (S.D. Fla. Feb. 7, 2022), report and recommendation adopted sub nom. Certain Underwriters at Lloyd's London v. A.M.A. Consulting & Constr. Services, Inc., 21-CV-20979, 2022 WL 539183 (S.D. Fla. Feb. 23, 2022) (finding no duty to defend or indemnify where the policy included an exclusion for condominium projects of more than 25 units and there was no dispute that the insured was engaged in work on a condominium project of more than 25 units). Arch’s coverage position was communicated to Lennar in numerous correspondence, including its October 10, 2023 letter and its August 14, 2024 letter and was most recently reiterated in Arch’s September 4, 2024 correspondence. Certified mail receipts confirm that Lennar received Arch’s October 10, 2023 correspondence as well as Arch’s January 11, 2024, March 7, 2024, June 13, 2024 and August 14, 2024 coverage position letters. Arch maintains its coverage position now. III. Conclusion Arch has acted in good faith, and it denies all allegations within the CRN, and all allegations of bad faith, including any alleged violation of Florida bad faith statutes. Arch specifically denies each and every accusation of wrongful conduct made against it in the CRN. Fla. Stat. §624.155(5) requires claimants “act in good faith in furnishing information regarding the claim, in making demands of the insurer, in setting deadlines, and in attempting to settle the claim.” The Arch Policies unambiguously exclude coverage for the Home. Lennar’s allegations have no basis in fact or law and Lennar’s demands are not made in good faith. Accordingly, Arch reserves all rights and remedies available to it under law, including without limitation Fla. Stat. §624.155(5)(b)2., which, to the extent necessary, permits Arch to present and the trier of fact to consider evidence of the Complainant’s failure to act in good faith in any bad faith action. While this response is meant to be comprehensive, Arch’s response is based upon the limited information provided in the CRN and the information it has to date. If Complainant feels that Arch is not in possession of all the facts, please inform the undersigned immediately. Please also note that Arch’s response is not necessarily exhaustive and does not preclude Arch from asserting any other valid reason for seeking rejection and return of the CRN. Finally, please be advised that Arch reserves all of its rights under the terms provisions, conditions, definitions, limitations, and exclusions contained within the Arch Policies which now or may hereafter apply, and under applicable law. No action taken by Arch, its attorneys or its representatives in the investigation of this matter is intended to be, nor is to be construed as an admission of coverage or liability under the Arch Policies. 1 - Arch issued four commercial general liability insurance policies to Victor’s. In addition to the policies identified in the CRN, Arch also issued policies AGL0016344-00 (Aug 13, 2014 – Aug 13, 2015) and AGL0016344-01 (Aug 13, 2015 – Aug 13, 2016), neither of which apply because they both expired before Victor’s performed any work at the home described in the CRN.
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.

Before submitting a Notice using this system, please verify that all text has been entered correctly and completely. Once the Notice has been submitted, the text cannot be changed or deleted.




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