Civil Remedy Notice of Insurer Violations
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Filing Number:     789821
Filing Accepted:  11/1/2024
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Complainant
Last/Business Name *  
LITTLE   First Name   NANCY AND GORDON
Street Address * 401 N. OXFORD DRIVE
City, State Zip * ENGLEWOOD, FL 34223
Email Address * NLITTLE428@HOTMAIL.COM
Complainant Type: * Insured
Insured
Last/Business Name*   LITTLE   First Name   NANCY AND GORDON
Policy # * PFL356639-05 Claim #* CFL22586147
Attorney
Attorney is Applicable
Last Name* SAVAGE First Name * SHELBY Initial L.
Street Address* 1700 W. MAIN ST., SUITE 100
City, State Zip* PENSACOLA , FL 32502
Email Address * SSAVAGE@TWWLAWFIRM.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   PEOPLE'S TRUST INSURANCE COMPANY
NAIC Company Code 13125
 
Name of individual responsible for violation (if any):* LANEY RHEA; RONALD JACKSON; TINA KEMPS; SARAH DAVIS; TRAVIS HUBBARD; CAROLINA QUINONES; PATRICK CUNNINGHAM; AARON BRENEMAN; ARIELLE MOLINET PETERS; JESSICA MYLES
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Claim Delay
Unsatisfactory Settlement Offer
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)(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)(c) Failing to acknowledge and act promptly upon communications with respect to claims.
626.9541(1)(i)(3)(e) Failing to affirm or deny full or partial coverage of claims, and, as to partial coverage, the dollar amount or extent of coverage, or failing to provide a written statement that the claim is being investigated, upon the written request of the insured within 30 days after proof-of-loss statements have been completed.
626.9541(1)(i)(3)(f) Failing to promptly provide a reasonable explanation in writing to the insured of the basis in the insurance policy, in relation to the facts or applicable law, for denial of a claim or for the offer of a compromise settlement.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

SECTION I – PROPERTY COVERAGES A. Coverage A–Dwelling A. We cover: 1. The dwelling on the "residence premises" shown in the Declarations, including structures attached to the dwelling B. Coverage B – Other Structures 1. We cover other structures, when premium for Coverage B is shown on the Declarations page, on the "residence premises" set apart from the dwelling by clear space. This includes structures connected to the dwelling by only a fence, utility line, or similar connection. D. Loss Settlement Covered property losses are settled as follows: 1. Property of the following types: a. Personal property; b. Awnings, carpeting, household appliances, outdoor antennas and outdoor equipment, whether or not attached to buildings; and c. Structures that are not buildings; at actual cash value at the time of loss but not more than the amount required to repair or replace. 2. Buildings under Coverage A or B at replacement cost without deduction for depreciation, subject to the following: a. If, at the time of loss, the amount of insurance in this policy on the damaged building is eighty percent (80%) or more of the full replacement cost of the building immediately before the loss, we will pay the cost to repair or replace, after application of deductible and without deduction for depreciation, but not more than the least of the following amounts: (1) The limit of liability under this policy that applies to the building; (2) The replacement cost of that part of the building damaged for like construction and use on the same premises; or (3) The necessary amount actually spent to repair or replace the damaged building. d. We will initially pay at least the actual cash value of the insured loss less any applicable deductible. We will then pay the necessary amounts actually spent to repair or replace the damaged building as work is performed and expenses are incurred. If a total loss of the covered dwelling occurs, we shall pay the replacement cost coverage without reservation of any depreciation in value, subject to policy limits. J. Our Option At our option: 1. For losses settled on an actual cash value basis, we may repair or replace any part of the damaged property with material or property of like kind and quality. 2. For losses covered under Coverage A – Dwelling, insured fore Replacement Cost loss Settlement as outlined in SECTION I – CONDITIONS, Loss Settlement, we may repair the damaged property with material of like kind and quality without deduction for depreciation. 9. Our right to repair or replace, and our decision to do so, is a material part of this contract and under no circumstances relieves you or us of our mutual duties and obligations under this contract. S. Appraisal: Where “we” elect to repair: 1. If “you” and “we” fail to agree on the amount of loss, which includes the scope of repairs, either may demand an appraisal as to the amount of loss and the scope of repairs. 2. The scope of repairs shall establish the work to be performed and completed by Rapid Response Team, LLC™. Such repair is in lieu of issuing any loss payment to “you” that otherwise would be due under the policy. The amount of loss shall establish only the initial amount paid to Rapid Response Team, LLC™ by “us”, and any additional amounts required to complete repairs shall be “our” responsibility and will be paid to Rapid Response Team, LLC™ without regard to policy limits or the amount of initial payments. This Civil Remedy Notice is also grounded in People’s Trust Insurance Company’s statutory duty to act in good faith and deal fairly with its insured when handling claims.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

The policyholders, Nancy and Gordon Little (collectively “Little”), sustained losses to their property located at 401 N. Oxford Drive, Englewood FL 34223 caused by and following Hurricane Ian as referenced in this Civil Remedy Notice. Little timely notified People’s Trust Insurance Company (“People’s Trust”) of the claim. In addition to the numerous statutory violations and wrongful conduct outlined in Little’s first Civil Remedy Notice (DFS No. 701021, filed on June 20, 2023) and restated below, People’s Trust has also recently committed the following statutory violations and wrongful acts since the filing of the first Civil Remedy Notice: This matter went to appraisal to determine the amount of the loss and cost to repair. In March 2024, an appraisal award was entered in the amount of $158,233.65 actual cash value, and $170,620.02 replacement cost value under Dwelling, Other Structures, Matching, and Screen Enclosure. The appraisal award itself states that it is “valid and binding upon all parties.” People’s Trust designated their contractor—Rapid Response Team, LLC (RRT)—to perform the repairs. People’s Trust violated the right to repair provision in the policy by failing to enact repairs in a timely and efficient manner and in good faith. Although the appraisal award was entered in March 2024, People’s Trust did not complete the necessary replacement of Little’s roof until September 2024, six months later. This unacceptable delay caused additional damage to occur inside the home because the covered damage the building sustained caused the envelope to be compromised, allowing additional water and outdoor elements to intrude and damage the home. Further, People’s Trust has also failed to comply with its own policy provision to accept the appraisal award as valid and binding and an establishment of the scope of repairs to be performed by People’s Trust’s selected contractor, RRT. Although the appraisal award required the replacement of certain windows in the home and People’s Trust is obligated to repair the home in accordance with the Florida Building Code, People’s Trust has breached this portion of its right to repair obligation by refusing to upgrade Little’s windows to hurricane grade windows as required by the Florida Building Code. In addition, People’s Trust has also recently assigned the file to a new RRT project manager—Shannon, to replace the former Emily—who has informed Little that a new estimate needs to be created. This conduct violates People’s Trust’s obligation to treat the appraisal award as valid and binding and repair the home to its pre-loss condition in accordance with the appraisal award. People’s Trust’s attempt to circumvent the appraisal award and further delay and stall this claim has been in bad faith and has caused Little additional harms and losses over and above the amount owed by People’s Trust for the necessary repairs. Once People’s Trust invoked its right to repair and moved forward with the appraisal process, People’s Trust was bound by the appraisal award and the scope determination made by the umpire. People’s Trust was under an obligation to enact the repairs within a reasonable time and perform the repairs in good faith with quality materials and workmanship. People’s Trust’s failure to perform the repairs within a reasonable time and in accordance with the scope set forth in the appraisal award constitutes a breach of the right to repair provision and an intentional handling of this claim in bad faith. As stated in Little’s first Civil Remedy Notice (DFS No. 701021, filed June 20, 2023), during the initial stages of the claim adjustment process, Little’s claim was passed from desk adjuster to desk adjuster—four total—causing unacceptable delay and disorganization each time the claim was passed to a new adjuster who would have to get up to speed on the claim. This process required Little to resubmit evidence that had previously been provided to People’s Trust multiple times, causing further delay and inefficient handling of this claim. This passing of the claim from one adjuster to another also hindered Little’s ability to reach their assigned desk adjuster to receive updates on the claim, with many of their inquiries and messages going completely unanswered, if not outright ignored. People’s Trust’s willful or negligent failure to ensure open and constant communication with its insureds violated both its duty under the policy to timely adjust this claim and its duty under Fla. Stat. § 626.9541(1)(i)(3)(c) to acknowledge and act promptly upon communications with respect to claims. People’s Trust’s dilatory, inefficient, and unacceptable adjustment of this claim in this manner also shows People’s Trust has failed to implement and follow adequate guidelines for the proper investigation to evaluate claims and the appropriate training and supervision of its employees and adjusters resulting in the statutory violations identified in this Civil Remedy Notice above. In addition to its wrongful handling of communications on this claim, People’s Trust has also uncovered or been presented with ample evidence showing the accurate scope of covered damage and the cost to repair it. However, People’s Trust ignored or dismissed this evidence and claimed damage was either not caused by a covered peril or was limited, excluded, or not as extensive as the evidence showed in an effort to wrongfully minimize the claim value so People’s Trust could save money on this claim. This conduct was in bad faith and has caused both significant delay of payment in full on the claim as well as additional harms and losses to Little over and above the amount owed under the policy of insurance. People’s Trust’s initial inspection of the property was conducted on October 22, 2022, and Little was informed an estimate of the damages would be forthcoming. However, this did not happen in a timely manner. Weeks upon weeks passed with Little attempting to get an update on the claim, to no avail, and no estimate was provided. People’s Trust did not complete its estimate until two months after the inspection and almost three months after the hurricane. This delay was unacceptable and caused significant delays and difficulties on this claim. People’s Trust estimate of the covered damage was also grossly inaccurate and failed to identify all items of damage and accurately estimate the cost to repair it. People’s Trust’s field adjuster was either not sufficiently trained or experienced to identify and estimate all damage caused by wind or his estimate was improperly or erroneously adjusted by the desk adjuster to result in an estimate that was inaccurate, far too low, and not supported by patent evidence at the property showing the damages were much greater. Specifically, People’s Trust’s determination that the entirety of the covered damage to Little’s dwelling and other structures amounted to only $10,758.62 was grossly inaccurate and constituted an active effort by People’s Trust to ignore evidence and minimize the claim value so People’s Trust could avoid its obligation to pay Little the full and fair value of this claim. People’s Trust’s estimate did not identify or accurately estimate the cost to repair the extensive wind damage to the property including, but not limited to, damage to the roof, which was struck by a felled tree, the soffits which were blown out, the living room interior and ceiling, the pool deck, a leaking bathroom and bedrooms, and approximately eleven trees which were felled by wind and removed from the property. People’s Trust also wrongfully minimized the damage to Little’s one thousand square foot guest house which had soffits blown out, shingles removed, and water coming down the walls. People’s Trust’s attempt to invoke its right to repair while limiting the repairs to this severely inadequate amount of $10,758.62 was in bad faith with the goal of avoiding its full obligation to Little. In finally submitting its late estimate and initial coverage decision to Little, People’s Trust also instructed Little, if they disagreed with People’s Trust’s coverage decision, their only option was to submit a sworn proof of loss. People’s Trust issued this demand fully aware of the consequences that accompany an insureds’ failure to produce a timely, accurate sworn proof of loss. People’s Trust’s decision to issue such a burdensome request in such a short time after a catastrophic storm—when local, skilled contractors and estimators are incredibly hard to locate and retain—was a strategic tactic intended to harass and bully its own policyholders. Rather than adjust the claim in Little’s best interest with the goal of identifying all covered damage and finding all coverage available to repair it, People’s Trust chose to weaponize its policy provisions and use them to place steep demands on Little with severe consequences during an already trying and difficult time. As a result of People’s Trust’s efforts to wrongfully minimize the claim value and limit its obligation to Little, Little was forced to incur costs in hiring a local, reputable, skilled public adjuster to prepare a thorough and accurate estimate of $163,983.42 replacement cost value on the dwelling and $18,947.67 on other structures, which represents a far more accurate estimate of the cost to repair the entirety of the covered damage. Had People’s Trust adjusted the claim initially in good faith and in Little’s best interest, People’s Trust’s inspection and estimate would have resulted in a fair amount of compensation that would not have forced Little to have to hire a public adjuster to protect their interests and right to be paid in full on the claim. People’s Trust’s conduct in this regard—showing a lack of concern for its inadequate adjustment of this claim and its failure and/or refusal to pay Little what it knows is the true amount required to repair the property—has been in bad faith. People’s Trust’s minimal initial payment on this claim and delay of full payment on the claim also shows People’s Trust hopes Little will tire of its delay and stall tactics and eventually accept less than the full amount they are owed on the claim. Comparing People’s Trust’s $10,758.62 estimate of the covered damage to Little’s dwelling and other structures to Little’s public adjuster’s estimate of $182,931.09 in damage to the dwelling and other structures, People’s Trust’s estimate amounts to less than 6% of the actual claim value. An estimate this inexplicably low could only have been reached in bad faith with the goal of ignoring ample and credible evidence showing the accurate scope of covered damages and the cost to repair them and wrongfully minimizing the claim value. People’s Trust’s inaccurate and erroneous estimate of the damages has caused serious delay on this claim and additional harms and losses to Little and violated People’s Trust’s contractual and statutory obligation to adjust this claim in good faith and Little’s best interest. Although Little submitted a sworn proof of loss to People’s Trust supported by their public adjuster’s detailed estimate and photo report, People’s Trust did not give this evidence a prompt or meaningful response. Numerous initial attempts by Little’s public adjuster to reach Little’s desk adjuster to discuss the sworn proof of loss and significant disparity in the estimates went unanswered and/or ignored by People’s Trust. Once a desk adjuster could be reached, the same pattern ensued requiring the new adjuster to be brought up to speed and a request was issued for documents and photos that been previously submitted to People’s Trust, causing further delay on this claim. Although a reinspection was finally scheduled to afford People’s Trust a second opportunity to identify all covered damage and, this time, prepare an accurate estimate of the cost to repair the damage, People’s Trust’s unacceptable delay of action and payment and/or repair on this claim have been in bad faith, to the detriment of Little. Although People’s Trust prepared a second estimate, dated May 12, 2023, following the reinspection, People’s Trust only increased its estimate of the covered damages up from its original $10,758.62 to $41,212.25—comprised of $32,843.62 replacement cost value on the dwelling and $8,368.63—this estimate still woefully underestimates the scope of covered damage and the cost to repair it. People’s Trust’s revised estimate only constitutes 23% of the actual claim value and does not fulfill its obligation to pay Little the full and fair value of this claim. People’s Trust’s increase of its estimate of the damages in stairstep increments evidences an intent to exhaust and bully Little in hopes they will eventually accept less than they are entitled to on this claim. In addition to the statutory violations outlined above, consistently throughout People’s Trust’s adjustment of this claim, People’s Trust failed to respond timely to communications, emails, and inquiries from both its insureds and their public adjuster in violation of both its duty under the policy to timely adjust this claim and its duty under Fla. Stat. § 626.9541(1)(i)(3)(c) to acknowledge and act promptly upon communications with respect to claims. People’s Trust’s decision to ignore and/or refuse to engage in open communication regarding this claim shows an intent by People’s Trust to hinder Little’s ability to defend and preserve their claim. This conduct has been a bad faith attempt to put Little at a disadvantage so People’s Trust can pay less than the full and fair value of the claim. People’s Trust’s failure and/or refusal to settle the insurance claim when under all circumstances it could have and should have done so had it acted fairly and honestly towards Little is wrongful conduct. As a result of People’s Trust’s wrongful conduct, Little was and still is forced to expend out of pocket monies to submit their insurance claim, e.g., retaining a public adjuster to prepare an accurate estimate and legal counsel to file this Civil Remedy Notice in hopes of finally forcing People’s Trust to honor its obligations under the insurance policy to pay the entirety of the insurance proceeds due and owing to Little. People’s Trust is obligated to Little to tender all insurance proceeds owing and due and/or commence repairs under an accurate scope of the covered damages to restore the property to its pre-loss condition. People’s Trust’s failure or refusal to fulfill these obligations to Little has been in bad faith and is a breach of the insurance agreement which requires People’s Trust to promptly pay or repair the property and put Little back into the position they were in prior to the loss as quickly as possible. To date, People’s Trust has failed to timely pay or deny the claim in full or repair the property in direct violation of Fla. Stat. § 627.70131. People’s Trust’s actions, in this regard, have been in bad faith. It is clear from People’s Trust’s failure to issue the benefits owed and its intentional attempt to avoid its full obligations to Little, that People’s Trust has engaged in a pattern of fraudulent and dilatory tactics to the prejudice and harm of Little. To cure the defects outlined in this Civil Remedy Notice, People’s Trust must: (1) Immediately tender all undisputed insurance proceeds to Little with statutory interest owed; (2) Act fairly and honestly towards Little and with due regard for their interest in attempting to settle this claim; (3) Immediately tender all insurance monies due and owing to Little with statutory interest; and (4) Pay Little the fair value of their insurance claim. People’s Trust Insurance Company’s address is 18 People’s Trust Way, Deerfield Beach, FL 33441.
Comments
User Id Date Added Comment
bfrankel@gmail.com 12-20-2024 RE: Insured: Nancy and Gordon Little Claim No.: CFL22586147 Policy No.: PFL356639-05 Date of Loss: September 28, 2022 DFS File No.: 789821 Accepted: November 1, 2024 Gentlemen: On behalf of People’s Trust Insurance Company (hereinafter “PTI”), I am responding to the Civil Remedy Notice filed on behalf of PTI’s insureds, Nancy and Gordon Little. The Civil Remedy Notice of Insurer Violation submitted lacks specificity and merely tracks the language of the bad faith statutes, citing general allegations of misconduct without setting forth the facts and circumstances giving rise to the alleged violations. The Civil Remedy Notice filed on behalf of Nancy and Gordon Little alleges a laundry list of allegations without factual support, and without specificity or telling the insurer how it can “cure” the alleged violations. The carrier maintains that it has not been in violation of the law, and that the above-referenced Civil Remedy Notice filed by Nancy and Gordon Little is defective on its face and does not comply with the specificity requirements set forth in Florida Statute §624.155. A simple review of the facts reveals that there was no “bad faith” in the handling of this claim. The first notice of this loss was reported by the insured on September 30, 2022, as roof, pool cage, shed and soffit damage as a result of Hurricane Ian. On the same day the claim was reported, PTI issued a Homeowner Bill of Rights letter to the insured, and sent a claim acknowledgment letter, outlining what the insured could expect during the claim process. People’s Trust also sent its preferred contractor, Rapid Response Team, to conduct emergency services at the property. On October 22, 2022, a licensed field adjuster inspected the property with the insured and a roofing contractor. At the inspection, the field adjuster observed wind-related damage to the dwelling and guest house. He created estimates to repair the damage totaling $10,758.62. On December 21, 2022, a formal coverage determination letter was sent to the insured, in which coverage was afforded and PTI invoked its option to repair. Ultimately, a scope dispute developed and the parties went to appraisal pursuant to the terms and conditions of the policy. Following the appraisal award, the parties prepared to participate in the appraisal process. To the extent the insureds’ Notice complains of under-scoping the loss, PTI has an appraisal clause in the policy to address any scope issues that may arise between the carrier and insured. On November 1, 2024, People’s Trust Insurance Company received the Civil Remedy Notice of Insurer Violation filed on behalf of the insured, which generally asserts allegations of misconduct by the insurer in the handling of the claim. Since the time the Civil Remedy Notice was filed, PTI’s preferred contractor, Rapid Response Team (“RRT”), has completed mold remediation at the property, including clearance testing. RRT has also discovered additional damages related to the duct work, which are being addressed. In other words, the repairs are underway and PTI intends to complete all repairs pursuant to and in excess of the appraisal award necessary to return the property to its pre-loss condition. To the extent the Notice alleges repair delays, the repairs are currently ongoing and- while repair delay is not within the purview of Florida’s bad faith statutes- PTI submits that this allegation has been remedied. Any damages stemming from repair delay, whether or not the fault of RRT, will be addressed accordingly. The undersigned has also contacted counsel for the insured to address her concerns directly and the lines of communication remain open as to any issues that may arise between the parties during the repair process. While the Civil Remedy Notice alleges that the Florida Building code requires that the insureds’ jalousie windows be upgraded to hurricane impact windows, this is not a correct statement of the Code. The Florida Building code requires impact resistant openings, which can include shutters and does not require windows be upgraded to the extent of hurricane impact windows. Counsel for PTI has addressed this with the insureds’ counsel. As the Department knows, a Civil Remedy Notice of Insurer Violation is a prerequisite to bringing a bad faith lawsuit against People’s Trust. The November 1, 2024 Civil Remedy Notice contains broad accusations and conclusions without any factual support and fails to meet the specificity requirement set forth in Florida Statute §624.155. Based on these broad allegations, People’s Trust is not aware of the facts surrounding the alleged statutory violations or what the insured believes People’s Trust must do in order to “cure” these allegations within the sixty day safe harbor period. The Civil Remedy Notice alleges that People’s Trust Insurance Company committed, inter alia, the following violations: • Not attempting in good faith to settle all claims when, under all the circumstances, it could and should have done so had it acted fairly and honestly toward the insured and with due regard for her or his interests; • 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; • Failing to adopt and implement standards for the proper investigation of claims; • Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue; • Failing to acknowledge and act promptly upon communications with respect to claims; • Failing to affirm or deny full or partial coverage of claims, and as to partial coverage, the dollar amount or extent of coverage, or failing to provide a written statement that the claim is being investigated, upon the written request of the insured within 30 days after proof-of-loss statements have been completed; and • Failing to promptly provide a reasonable explanation in writing to the insured of the basis in the insurance policy, in relation to the facts or applicable law, for denial of a claim or for the offer of a compromise settlement. The above recitations are nothing more than a laundry list of accusations and conclusions without any factual support. Florida Statute §624.155(3)2 requires that a Civil Remedy Notice state with specificity the facts and circumstances that give rise to the alleged violations. With regard to alleged violation number one, above, the Notice includes no specific facts as to how PTI has failed to negotiate and settle claims; in fact, the insured was not entitled to a monetary payment because PTI invoked its option to repair. As to item numbers two and four, there are no facts offered to tell the carrier how it misrepresented facts other than the incorrect statement that the Florida Building Code requires upgraded hurricane impact windows. There are no facts as to how PTI failed to implement standards for the proper investigation of claims, or what communications (who sent, how sent, when, or to whom) to which PTI failed to respond. Alleged violation number sixth, above, asserts that PTI failed to respond to the Proof of Loss submitted in March 2023 within 30 days; in fact, PTI did respond and requested a Letter of Representation so that it could communicate with the insureds’ public adjuster. With regard to the seventh alleged violation, the Notice does not explain how PTI failed to explain the basis for its coverage determination and in fact the coverage determination does explain it in detail and attached a copy of the Preferred Contractor Endorsement. A Civil Remedy Notice is not intended to be a guessing game. If the insureds maintain that People’s Trust committed the above-listed violations, they must provide specificity as to the facts and circumstances giving rise to these alleged violations. Based on these broad accusations People’s Trust does not know what is being alleged and/or how the insured believes People’s Trust can “cure” all of the alleged violations. The two main allegations of the Civil Remedy Notice- under-scoping the loss and repair delay- are not per se violations of the bad faith statutes. Florida Statute §624.155 is not a notice statute. It is intended to advise the carrier of any alleged violations so that it can “cure” them within the statutory “cure period”. A Civil Remedy Notice must be made with sufficient specificity to allow the insurer to understand and to cure any purported violation. Longpoint Condominium Assn. v. Allstate Ins. Co., 2005 WL 1315810 (N.D. Fla.2005). The Civil Remedy Notice filed by Nancy and Gordon Little is factually insufficient because there is no specificity regarding the allegations against People’s Trust. Here, the allegations concerning the claim have no nexus with the bad faith statutes listed in the Civil Remedy Notice, thereby presenting a situation that precludes the insurer from understanding what the actual improper conduct in the claims handling may be, and precluding the insurer from adequately or timely responding. Nonetheless, the repairs are currently underway and lines of communication open between counsel for the parties. As shown, PTI has not acted in bad faith but has observed the terms and conditions of the Policy. As discussed above, People’s Trust Insurance Company maintains that it has not been In violation of the law and that the Civil Remedy Notice filed by Nancy and Gordon Little is defective on its face and does not comply with the specificity requirements set forth in Florida Statute §624.155. We trust the foregoing fully explains the facts and circumstances of the claim and addresses any concerns raised. If we can provide other information or clarification of information concerning the claim, please do not hesitate to contact the undersigned. Very truly yours, Arielle Molinet Peters Corporate Counsel, Claims/Legal People’s Trust Insurance Company Cc: Shelby Savage
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