Civil Remedy Notice of Insurer Violations
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Filing Number:     789924
Filing Accepted:  11/1/2024
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Complainant
Last/Business Name *  
JEFFREY STEINBACH   First Name   YOLANDA DIBELLA AND
Street Address * 7807 SCRUBOAK CT.
City, State Zip * HUDSON, FL 34667
Email Address * JEFFREYWSTEINBACH@GMAIL.COM
Complainant Type: * Insured
Insured
Last/Business Name*   JEFFREY STEINBACH   First Name   YOLANDA DIBELLA AND
Policy # * 1501-2102-7791 Claim #* FL24-0107155
Attorney
Attorney is Applicable
Last Name* SULISUFAY First Name * LAURA Initial T
Street Address* 3411 W. FLETCHER AVE, STE. B,
City, State Zip* TAMPA, , FL 33618
Email Address * PRESUIT@SULILAW.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
NAIC Company Code 10861
 
Name of individual responsible for violation (if any):* BRUNO BRETAS AND ANY OTHER INDIVIDUAL FROM, OR AGENT OF, UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY, WHO WAS INVOLVED IN THE CLAIM.
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Unfair Trade Practice
Unsatisfactory Settlement Offer
Claim Delay
Claim Denial
Other : Violations of code of Ethics
Other : Not treating the Insured with good faith claims conduct
Other : Looking for ways to deny full recovery to the Insured
Other : Looking for ways to delay full recovery to the Insured
Other : Failing to properly investigate the Insured’s loss
Other : Failing to provide the Insured with the full benefits awarded under the contract of insurance in a t
Other : Not training, supervising, or managing adjusters properly so that prompt and full payments are made.
Other : Not adjusting claims and evaluating loss properly
Other : Shifting the burden of insuring the loss to the Insured
Other : Failing to implement proper standards for the adjustment and investigation of claims
* 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)(c) Failing to acknowledge and act promptly upon communications with respect to claims.
626.9541(1)(i)(3)(d) Denying claims without conducting reasonable investigations based upon available information.
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.
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.
626.9541(1)(i)(4) Failing to pay undisputed amounts of partial or full benefits owed under first-party property insurance policies within 60 days after an insurer receives notice of a residential property insurance claim, determines the amounts of partial or full benefits, and agrees to coverage, unless payment of the undisputed benefits is prevented by factors beyond the control of the insurer as defined in s. 627.70131(5).
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

THE POLICY LANGUAGE RELEVANT TO THE VIOLATIONS INCLUDES ALL APPLICABLE LOSS PAYMENT AND COVERAGE PROVISIONS OF POLICY NUMBER 1501-2102-7791, INCLUDING THE DECLARATIONS PAGE AND ALL ENDORSEMENTS TO THE POLICY, WITH RESPECT TO COVERAGES A, B, C, AND D. ADDITIONALLY, ANY SECTIONS RELIED UPON BY THE INSURER IN ITS FAILURE TO FULLY PAY THE CLAIM, INCLUDING THE DUTIES IN THE EVENT OF LOSS PROVISIONS AND THE POLICY'S EXCLUSION OF COVERAGE PROVISIONS. THE VIOLATIONS ALLEGED ARE ALSO STATUTORILY BASED AND DO NOT RELY ON ANY SPECIFIC POLICY LANGUAGE. 627.70131(7)(a) Within 60 days after an insurer receives notice of an initial, reopened, or supplemental property insurance claim from a policyholder, the insurer shall pay or deny such claim or a portion of the claim unless the failure to pay is caused by factors beyond the control of the insurer which reasonably prevent such payment. The insurer shall provide a reasonable explanation in writing to the policyholder of the basis in the insurance policy, in relation to the facts or applicable law, for the payment, denial, or partial denial of a claim. If the insurer’s claim payment is less than specified in any insurer’s detailed estimate of the amount of the loss, the insurer must provide a reasonable explanation in writing of the difference to the policyholder. Any payment of an initial or supplemental claim or portion of such claim made 60 days after the insurer receives notice of the claim, or made more than 15 days after there are no longer factors beyond the control of the insurer which reasonably prevented such payment, whichever is later, bears interest at the rate set forth in s. 55.03. 627.4137(1)(e) – Each insurer which does or may provide liability insurance coverage to pay all or a portion of any claim which might be made shall provide, within 30 days of the written request of the claimant, a statement, under oath, of a corporate officer or the insurer's claims manager or superintendent setting forth the following information with regard to each known policy of insurance, including excess or umbrella insurance: A copy of the policy. 627.444(2)(a) Notwithstanding any other law, an insurer shall provide to an insured within 15 calendar days after an individual or entity designated by the insurer receives the insured's written request, either: A loss run statement; 627.70131 (1)(a) - Upon an insurer's receiving a communication with respect to a claim, the insurer shall, within 7 calendar days, review and acknowledge receipt of such communication unless payment is made within that period of time or unless the failure to acknowledge is caused by factors beyond the control of the insurer. If the acknowledgment is not in writing, a notification indicating acknowledgment shall be made in the insurer's claim file and dated. A communication made to or by a representative of an insurer with respect to a claim shall constitute communication to or by the insurer.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

Universal Property & Casualty Insurance Company has committed the following in handling the insured’s claim: 1. Failing to act in due diligence and good faith to resolve claims 2. Placing the financial interest of the Carrier before that of the Insured 3. Looking for ways to deny benefit payments and otherwise “low ball” or “stone wall” claims. 4. Not adjusting the claims promptly and fairly 5. Not attempting in good faith to settle claims 6. Conducting Inadequate investigations 7. Failing to employ policies and procedures to conduct adequate investigations 8. Failing to provide an estimate that complies with the Florida Building Codes. 9. Shifting the burden of investigating the loss onto the Insured. 10. Misrepresenting the terms of the insurance policy. 11. Failing to provide a copy of the insurance policy within 30 days. optional 12. Failing to provide a loss run statement within 15 days. optional Jeffrey Steinbach and Yolanda DiBella are the homeowners with an all-risks insurance policy issued by Universal Property and Casualty Insurance Company (hereinafter “Carrier”),. On or about March 24, 2024, while the policy was in full force and effect, the Insured’s property located at 7807 ScrubOak CT, Hudson, FL 34667 sustained significant damage as a result of Wind. The insured promptly reported the claim and fully cooperated with the carrier’s investigation. The Carrier assigned claim number FL24-0107155 to the loss. After reporting the claim, Carrier retained an unqualified and biased field adjuster to adjust the loss. This adjuster had a financial incentive to adjust the loss in a manner that would minimize Carrier’s losses. Instead of adjusting the claim fairly, honestly, in good faith, and with due regard for the Insured’s interest, the adjuster made a conscious effort to ignore evidence of covered losses to the property. Then in a letter dated April 18th 2024, the carrier notified the Insured that it had completed its investigation into the loss and valued the damages under the insured’s deductible. Given the vastly underestimated cost of repairs, the Insured’s disagreement with the coverage decision, and the scope and nature of the damage resulting from the loss, the Insured through its retained representatives disputed the coverage determination and submitted an estimate prepared by Hunter Claims for $95,234.98. Which was a fair and reasonable assessment of the loss. Worst still, Carrier failed to retain qualified experts necessary to identify the repairs necessary to restore the property to its pre-loss condition within reasonable time. Under the circumstances surrounding this claim, had Carrier acted fairly and honestly toward the Insured and with due regard for the Insured’s interests, Carrier could and should have attempted in good faith to settle this claim. Carrier did not and, instead, dishonestly and unfairly placed its own interests well ahead of those of the Insured. In doing so, Carrier violated Section 624.155(1)(b)(1), Florida Statutes. Carrier’s use of unqualified and bias adjusters, and failure to retain experts necessary to identify the repairs necessary to restore the property to its pre-loss condition evidences Carrier’s failure to adopt and implement standards for the proper investigation of claims in violation of Section 626.9541(1)(i)(3)(a), Florida Statutes. Carrier’s use of unqualified and bias adjusters, and failure to retain experts necessary to identify the repairs necessary to restore the property to its pre-loss condition, evidences Carrier’s failure to conduct a reasonable investigation based upon available information. When applying the facts present here to Florida law, it is clear that Carrier is acting in bad faith. Florida Statute § 624.02 defines insurance as a contract whereby one undertakes to indemnify another or pay or allow a specified amount or a determinable benefit based on determinable contingencies. Inherent is the fact that payment must be made timely and promptly so that insureds may mitigate their damages and be put back into the position they were in prior to the loss as quickly as possible. Carrier has breached this duty by refusing to properly and timely adjust the loss. Moreover, Section 69B-220.201 of the Florida Administrative Code defines Carrier’s adjusters conduct here as an unfair claims settlement practice. Specifically, Section 69B-220.201(3) provides that “[a]n adjuster shall not approach investigations, adjustments, and settlements in a manner prejudicial to the insured” and that “[a]n adjuster shall make truthful and unbiased reports of the facts after making a complete investigation.” As detailed above, Carrier’s investigation and adjustment of this claim was done in a manner prejudicial to Insured, was incomplete, and lacked truthful and unbiased reports of the facts. Upon receiving notice of the loss, the Insurer had the duty to provide the full benefits under the policy. This includes providing the Insured with a proper investigation and the funds necessary to return the home to its pre-loss condition. However, when the Insurer conducted its inspection of the insured property, the Insurer’s representatives failed to conduct a thorough and adequate investigation, or the representatives intentionally ignored the damage observed and failed to make truthful and unbiased reports of the facts after investigating. As a result, the Insurer breached the policy by failing to fully indemnify the Insured for the covered loss. The conduct outlined above is done within the Insurer’s routine course of the business. There may be further wrongful conduct which has not been made known to the Insured at this moment. Certain conduct or actions may be discovered throughout discovery or cannot be verified without a review of the Insurer’s claim file and standards and procedures for the adjustment and investigation of claims. In short, the Insurer is not acting with due regard for the Insured’s interests or safety. In Florida, the work of adjusting insurance claims engages the public trust. The Insurer has breached this trust and its duty to the Insured. The Insurer and its agents conducted cursory and inadequate investigations and wrongfully denied full coverage for the claim. Moreover, the Insurer has engaged in bad faith practices designed to delay claims and prevent the Insured from recovering what is rightfully owed under the subject policy of insurance. The Insurer’s actions and inactions have continued to frustrate and delay the resolution of the Insured claim. The Insurer’s actions amount to but are not limited to the following: 1. Claim Delay: The Carrier has delayed processing the claim, causing frustration and inconvenience to the Insured. 2. Lack of Good Faith Conduct: The Carrier has not treated the Insured with good faith conduct expected when handling claims. 3. Attempt to Reduce Recovery: The Carrier has actively sought ways to minimize the amount owed to the Insured under the policy. 4. Attempt to Deny Recovery: The Carrier has looked for reasons to deny coverage altogether, rather than fulfill its obligations under the policy. 5. Failure to Property Evaluate Loss: Claims have not been assessed accurately or promptly, resulting in delays and incomplete indemnity for the Insured. 6. Inadequate Training and Supervision of Adjusters: The Carrier has not ensured its adjusters are adequately trained to handle claims promptly and fairly. 7. Placing Company Interests over Insured Interests: The Carrier has prioritized its financial interests over the health and safety of the Insured. 8. Failure to Provide Complaint Estimates: Estimates provided by the Carrier do not comply with Florida Building Codes. 9. Shifting Investigation Burden to Insured: The Carrier has unfairly placed the burden of investigating the claim onto the Insured. 10. Conducting Inadequate Investigations: The Carrier’s Investigation into the claim have been insufficient or cursory. Therefore, to cure the defects outlined in this civil remedy notice, the Insurer must: 1. Admit full coverage for the Insured’s loss and tender all additional amounts owed under the Policy for the covered loss to the insured property Please email any responses to this civil remedy notice to presuit@sulilaw.com A copy of this form submitted to the FDFS has been sent via email to the following parties, providing them notice of the filing of the civil remedy notice: • Universal Property & Casualty Insurance Company via DFS Filing • Claims Department, Universal Property & Casualty Insurance Company via online portal • Jeffrey Steinbach and Yolanda DiBella via email jeffreywsteinbach@gmail.com
Comments
User Id Date Added Comment
sm1130@universalproperty.com 12-20-2024 December 20, 2024 VIA ELECTRONIC FILING Florida Department of Financial Services Bureau of Consumer Assistance Civil Remedy Section 200 East Gaines Street Tallahassee, FL 32399-0322 Re: DFS File No.: 789924 Filing Date: 11/1/2024 Complainant(s): Yolanda DiBella and Jeffrey Steinbach Insured(s): Yolanda DiBella and Jeffrey Steinbach Policy No.: 1501-2102-7791 Claim No.: FL24-0107155 Dear Sir/Madam: Please allow this to serve as Universal Property & Casualty Insurance Company’s (“Universal”) formal response to the above-referenced Civil Remedy Notice filed by attorney Laura T Sulisufay, on behalf of Complainants, Yolanda DiBella and Jeffrey Steinbach (also referenced as “Insureds.”) The Notice alleges violations of Sections 624.02, 624.155, 626.9541, 627.70131, 627.4137, and 627.444, Fla. Stats., and Florida Administrative Code Section 69B-220.201. Universal denies that it violated these or any statutes, Florida law, Administrative Code or policy provisions regarding the claim adjustment of this matter. With that said, Universal asserts that the Notice fails to comply with the specific notice and information requirements as set forth in Civil Remedy Notice of Insurer Violation document provisions, Section 624.155, Florida Statutes and Florida law. The Notice is deficient as a matter of law as it fails to comply with Section 624.155, Florida Statutes. See 316, Inc. v. Maryland Cas. Ins. Co., 625 F. Supp. 2d 1187 (N.D. Fla. 2008); Rousso v. Liberty Surplus Ins. Corp., 2010 WL 7367059, (S. D. Fla. 2010); Heritage Corp. of South Fla. v. Nat’l Union Fire Ins. Co. of Pittsburgh, P.A., 580 F. Supp. 2d 1294 (S.D. Fla. 2008); Talat Enterprises, Inc. v. Aetna Cas. & Surety Co., 753 So. 2d 1278 (Fla. 2000). Pursuant to Section 624.155(3)(b), Florida Statutes the Notice “shall state with specificity” the following information: 1. The statutory provision, including the specific language, which the authorized insurer allegedly violated; 2. the facts and circumstances giving rise to the violation; 3. the name of any individual involved in the violation; 4. reference to specific policy language that is relevant to the violation, if any...; 5. a statement that the Notice is given in order to perfect the right to pursue the civil remedy authorized by this section. Moreover, the Department of Financial Services (“DFS”), created form DFS-10-363, which lays out 15 requirements that the Complainant(s) must respond to with specificity. The Florida Supreme Court holds that Section 624.155, Florida Statutes “must be strictly construed.” Talat Enterprises, Inc. v. Aetna Cas. and Sur. Co., 753 So. 2d 1278, 1283 (Fla. 2000). Strict construction is appropriate as “this statute is in derogation of the common law.” Id. When interpreting a statute in derogation of the common law, “[a] court will presume that such a statute was not intended to alter the common law other than as clearly and plainly specified in the statute.” Time Ins. Co., Inc. v. Burger, 712 So. 2d 389, 393 (Fla. 1998). Such an interpretation would mean that statutory bad faith cases cannot proceed unless the Complainant(s) specifically complied with all statutory requirements. Pin-Pon Corp. v. Landmark American Ins. Co., 500 F. Supp. 3d 1336 (S.D. Fla. 2020); Julien v. United Property & Casualty Ins. Co., 311 So.3d 875 (Fla. 4th DCA 2021). The Notice fails to meet the requirement of Section 624.155, Florida Statutes, on several grounds. First, the Civil Remedy Notice requires the Complainants “pursuant to section 624.155, F.S. please indicate all statutory provisions alleged to have been violated.” The Notice filed by the Complainants in this matter includes almost every statutory provision that could be claimed against an insurance company, without the requisite specificity as to how, if at all, they are relevant or applicable to any facts alleged in the Notice. Because the Notice fails to identify any specific statutes, Universal is unable to properly respond and the Notice does not comply with Fla. Stat. § 624.155. Second, with respect to the requirement to set forth with specificity the “facts and circumstances giving rise to the violation,” the Notice fails to allege any specific conduct on the part of Universal that would violate any policy provision or statute. The Complainants provide fourteen (14) reasons for submitting the Notice. However, the Complainants’ allegations regarding these “Reasons for Notice” have no factual support anywhere in the Notice. The Notice asserts general allegations containing inaccurate, speculative and conclusory statements rather than specifying facts to support any alleged statutory violation. For example, the Notice states “[i]nstead of adjusting the claim fairly, honestly, in good faith, and with due regard for the Insured’s interest, the adjuster made a conscious effort to ignore evidence of covered losses to the property.” The Complainants fail to assert any facts to support these conclusory statements. As an additional example, the Notice states in part: “Universal Property & Casualty Insurance Company has committed the following in handling the insured’s claim: 1. Failing to act in due diligence and good faith to resolve claims 2. Placing the financial interest of the Carrier before that of the Insured 3. Looking for ways to deny benefit payments and otherwise “low ball” or “stone wall” claims. 4. Not adjusting the claims promptly and fairly 5. Not attempting in good faith to settle claims 6. Conducting Inadequate investigations 7. Failing to employ policies and procedures to conduct adequate investigations 8. Failing to provide an estimate that complies with the Florida Building Codes. 9. Shifting the burden of investigating the loss onto the Insured. 10. Misrepresenting the terms of the insurance policy. 11. Failing to provide a copy of the insurance policy within 30 days. optional 12. Failing to provide a loss run statement within 15 days. Optional [sic]” The Complainants’ conclusory statements outlined above are unsupported by facts in the Notice and do not provide the requisite specificity as to how Universal allegedly violated any policy provision or statute. Further, at no time has Universal placed the burden to investigate the claim on the Insureds. Moreover, the Notice does not set forth any facts regarding any misrepresentations made by Universal and does not identify the person or persons who made such misrepresentations, nor does it identify to whom any misrepresentations were made. The Notice further alleges, “[t]he conduct outlined above is done within the Insurer’s routine course of the business. There may be further wrongful conduct which has not been made known to the Insured [sic] at this moment.” The Notice does not specify any facts to support these speculative and conclusory statements. The Complainants are required to provide with specificity the facts and circumstances giving rise to the alleged violation strictly related to Complainants’ allegations, not conjecture or speculation of what may be the carrier’s business practices. In addition, the Notice alleges that Universal breached Section 624.02, Florida statutes, and Florida Administrative Code Section 69B-220.201 but fails to provide facts to specify how this statute and/or code was breached. The Notice is replete with inaccuracies, conclusory statements and supposition in lieu of specifying facts to support any of the alleged misconduct or statutory violations. The failure to specify facts to support the conclusory allegations of misconduct hinders Universal’s ability to appropriately investigate the allegations in the Notice. It is evident that the statement of facts falls short of the specificity required by Sec. 624.155, Fla. Stat. As a result, the Complainants fail to comply with the requirements provided in Section 624.155(3)(b)(2), Florida Statutes. Third, the Notice fails to satisfy the requirement to identify the person or persons representing the insurer most responsible for or knowledgeable of the facts giving rise to the allegations. In order to comply with the requirements of Section 624.155, Florida Statutes, the Complainant(s) must name the individual(s) involved with specificity as it relates to the purported violation(s) to allow Universal to properly investigate the allegations. The Notice lacks the requisite specificity as required by Section 624.155, Florida Statutes. Here, the Notice states “BRUNO BRETAS…” however, the Notice fails to include any specificity as to what facts the named individual has knowledge of that gave rise to any purported allegation(s) and/or what, if anything, they did or failed to do as it relates to the claim at issue. The Complainants also attempt a “catch-all” by stating “AND ANY OTHER INDIVIDUAL FROM, OR AGENT OF, UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY, WHO WAS INVOLVED IN THE CLAIM.” which significantly prejudices Universal because the Complainants are failing to notify Universal of the individuals that purportedly committed statutory violations or the specific statutory violations any individual purportedly committed. The failure to provide the requisite specificity precludes Universal from taking any corrective action and potentially curing any purported allegation. Specific identification of a person or persons with the most knowledge within Universal is of particular importance because the Complainants allege that Universal “misrepresent[ed] pertinent facts or insurance policy provisions relating to coverages at issue” in the Notice. The Notice, however, fails to include the requisite specificity as to whom made any misrepresentations or when any of these misrepresentations occurred. Accordingly, the Notice is insufficient as a matter of law. Fourth, the Notice fails to satisfy Section 624.155(3)(b)(4), Florida Statutes, in that it fails to reference any specific policy language relevant to any alleged violation. Instead, the Notice improperly cites to Sections 627.70131, 627.4137, and 627.444, Florida Statutes, however, these are not policy provisions within the Policy and moreover, there are no facts specified to place Universal on notice of how it allegedly violated these statutes. When the Complainants do mention the Policy, the Notice states: “THE POLICY LANGUAGE RELEVANT TO THE VIOLATIONS INCLUDES ALL APPLICABLE LOSS PAYMENT AND COVERAGE PROVISIONS OF POLICY NUMBER 1501-2102-7791, INCLUDING THE DECLARATIONS PAGE AND ALL ENDORSEMENTS TO THE POLICY, WITH RESPECT TO COVERAGES A, B, C, AND D. ADDITIONALLY, ANY SECTIONS RELIED UPON BY THE INSURER IN ITS FAILURE TO FULLY PAY THE CLAIM, INCLUDING THE DUTIES IN THE EVENT OF LOSS PROVISIONS AND THE POLICY'S EXCLUSION OF COVERAGE PROVISIONS. THE VIOLATIONS ALLEGED ARE ALSO STATUTORILY BASED AND DO NOT RELY ON ANY SPECIFIC POLICY LANGUAGE.” The Complainants references “ALL APPLICABLE…COVERAGE PROVISIONS OF POLICY,” which in essence cites the entire Policy. It therefore fails to reference policy language that pertains to any allegation. Additionally, the broad references to sections and/or provisions in the Policy provide no guidance or explanation, such that Universal is left to wonder what policy provisions Complainants believe were allegedly violated or breached and why. General, vague, and overbroad references to the entire subject policy do not satisfy the specificity required by Section 624.155(3)(b)(4), Florida Statutes. As such, the Notice is deficient as a matter of law. See generally Julien v. United Property & Casualty Ins. Co., 311 So.3d 875 (Fla. 4th DCA 2021). In summary, as outlined above, the Complainants failed to respond to each of the fields set forth on the DFS Form with the requisite specificity including, but not limited to, the failure to satisfy the requirement to identify the person or persons representing the insurer most responsible for or knowledgeable of the facts giving rise to the allegations, the failure to reference specific policy language relevant to the alleged violation, and the failure to sufficiently allege facts and circumstances giving rise to any violation. Therefore, the Notice is legally deficient and fails to satisfy the condition precedent to filing a bad faith action. Pin-Pon Corp. v. Landmark American Ins. Co., 500 F. Supp. 3d 1336 (S.D. Fla. 2020); Julien v. United Property & Casualty Ins. Co., 311 So.3d 875 (Fla. 4th DCA 2021). For the aforementioned reasons, the Notice is deficient as a matter of law. Nonetheless, and without waiving the above-referenced deficiencies, the following shall provide you with Universal’s response to the Notice. On March 27, 2024, Universal was notified by the Insured, Jeffrey Steinbach, that the roof of the insured location was damaged the same day. On April 10, 2024, Universal inspected the property and documented any visible damage. On April 18, 2024, Universal, in accordance with the terms and conditions of the Policy, advised the Insureds that the claimed damage to the roofing system was due to wear and tear. Additionally, Universal advised that the interior dwelling property damage, as estimated, fell below the applicable deductible. On May 15, 2024, the Insureds submitted a competing estimate totaling $95,234.98 prepared by HunterClaims on their behalf. On July 9, 2024, Universal advised the Insureds that based on the facts known to date, no additional amounts were owed. Additionally, Universal advised the Insureds of the Policy’s alternative dispute resolution methods. Universal did not breach any duty to its Insureds. An insurer has no obligation to pay whatever amount its insureds demand. Accordingly, the alleged statutory violations and factual allegations of wrongdoing set forth in the Notice lack factual support and are without merit. Therefore, the Notice is legally deficient and fails to satisfy the condition precedent to filing a bad faith action. Universal complied with all policy provisions and applicable Florida Statutes and law regarding the adjustment of this claim. We trust that the foregoing is sufficient to advise you of Universal’s position regarding this matter and fully responds to the Notice filed by the Complainants. Sincerely, /s/ Stephen Methe Stephen Methe
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