Civil Remedy Filing

Civil Remedy Notice of Insurer Violations

Filing Number: 794560

Filing Accepted: 11/27/2024

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Complainant

Last/Business Name *

TAYLOR

First Name

ROBERT TAYLOR & ELIZABETH

Street Address *

804 LAWHON DR.

City, State Zip *

ST. JOHNS, FL 32259

Email Address *

EHTAYLOR804@GMAIL.COM

Complainant Type: *

Insured

Last/Business Name*		TAYLOR		First Name		ROBERT TAYLOR & ELIZABETH
Policy # *		5866815025		Claim #*		01000099298

Attorney

Attorney is Applicable

Last Name*	FOULADI First Name * ANTHONY Initial
Street Address*		2300 MAITLAND CENTER PARKWAY STE.106
City, State Zip*		MAITLAND , FLORIDA 32751
Email Address *		AFOULADI@SERRANOCAGAN.COM

Violation

Insurer Type *		Authorized Insurer Unauthorized Insurer

Insurer Name
Insurer Name*		FIRST PROTECTIVE INSURANCE COMPANY
Insurer Name*
Street Address*
City, State Zip*		,
NAIC Company Code 10897

Name of individual responsible for violation (if any):* N/A
Type of Insurance * Residential Property & Casualty

Reason for Notice *

	Claim Denial
	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.
	624.155(1)(b)(3)		Except as to liability coverages, failing to promptly settle claims, when the obligation to settle a claim has become reasonably clear, under one portion of the insurance policy coverage in order to influence settlements under other portions of the insurance policy coverage.
	626.9541(1)(i)(3)(a)		Failing to adopt and implement standards for the proper investigation of claims.
	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)(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.
	626.9541(1)(i)(3)(i)		Failing to pay personal injury protection insurance claims within the time periods required by s. 627.736(4)(b).

* 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 COVERAGE A. Coverage A – Dwelling (Entire Section) B. Coverage B – Other Structures (Entire Section) C. Coverage C – Personal Property (Entire Section) D. Coverage D – Loss of Use (Entire Section).

* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

On or about 06/02/2023, ROBERT TAYLOR AND ELIZABETH TAYLOR ("Insured"), sustained a covered direct physical loss to Insured's property due to a WIND. Insured reported the loss thereafter to FIRST PROTECTIVE INSURANCE COMPANY ("Insurer"). Prior to the date of loss, Insurer issued a policy of insurance, believed to be policy # 5866815025 which afforded coverage for the aforementioned property for losses caused by the covered peril. The policy was in full force and effect on the date of loss. The Insured promptly notified Insurer of the loss, who then assigned the loss claim # 01000099298. Insurer was fully afforded any and all opportunity to inspect the loss and document the loss. To date, Insurer has paid $0 to Insured on this claim even after numerous attempts by the Insured to provide documentation of additional damages and compensation owed. Insured had no choice but to retain legal representation on or about 10/5/2023, as the Insurer refused to pay the full amount due and owed to its Insured. Insurer has continually failed to negotiate this claim with Insured’s attorney and/or failed to provide a satisfactory settlement offer to resolve the subject claim. This has severely harmed the Insured's ability to remedy their losses and continue with repairs to the property. The only purpose for Insurer's refusal to negotiate the claim is to increase profits and harm their insured. This is either done intentionally as a pattern and practice of Insurer to deny coverage and harm their insureds, or Insurer has failed to properly train and supervise its adjusters to the harm and detriment of their insureds. This pattern and practice is done for only one reason, which again, is to maximize profits and harm their insureds. Insurer has violated the following statutory provisions: 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; 624.155(1)(b)(3): Except as to liability coverages, failing to promptly settle claims, when the obligation to settle a claim has become reasonably clear, under one portion of the insurance policy coverage in order to influence settlements under other portions of the insurance policy coverage. 626.9541(1)(i)(3)(a): Failing to adopt and implement standards for the proper investigation of claims. 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. 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)(3)(i): Unfair claim settlement practices, and any other applicable statutes to the factual allegations included herein. To remedy and/or cure this CRN, Insurer must immediately tender payment in the amount of $103,458.00 less any applicable deductible and prior payment to the Insured to complete the repairs for the Insured property. The payment shall be tendered to the Insured’s attorneys, Serrano Cagan & Cagan at 2300 Maitland Center Parkway, Suite 106, Maitland, Florida 32751.

Comments

User Id		Date Added		Comment
amaddox@penningtonlaw.com		01-20-2025		January 20, 2025 VIA ELECTRONIC FILING THROUGH WWW.FLDFS.COM – CIVIL REMEDY SYSTEM Anthony Fouladi 2300 Maitland Center Parkway, Ste. 106 Maitland, Florida 32751 afouladi@serranocagan.com Civil Remedy Notice Response DFS Filing No.: 794560 Insureds: Robert Taylor and Elizabeth Taylor Complainants: Robert Taylor and Elizabeth Taylor Policy Number: 5866815025 Claim Number: 01000099298 Date CRN Filed: November 27, 2024 Dear Counsel: Undersigned counsel and the law firm of Pennington, P.A. represent FIRST PROTECTIVE INSURANCE COMPANY (“FRONTLINE”) with regard to the above-referenced claim. This shall serve as FRONTLINE’s response to the Civil Remedy Notice of Insurer Violations (“CRN”), filed by or on behalf of Complainants ROBERT TAYLOR and ELIZABETH TAYLOR (hereinafter “Complainants”), with the Florida Department of Financial Services (“DFS”) on November 27, 2024 (DFS Filing No. 794560). COMPLAINANTS ARE NOT IN FULL COMPLIANCE WITH THEIR DUTIES AFTER LOSS Complainants’ CRN is improper as they have failed to fully comply with their duties after loss prior to initiating this action against FRONTLINE, which has caused prejudice to FRONTLINE’s investigation of the claim. Complainants failed to provide an executed Sworn Proof of Loss to FRONTLINE within sixty (60) days after FRONTLINE’s request, as required by the policy. The SPOL was initially requested on June 2, 2023. Not only did Complainants fail to provide the SPOL within sixty (60) days of the request, but they have failed to provide an executed SPOL to date. As Complainants have not fully complied with their duties after loss, they cannot pursue an action against FRONTLINE. This includes the filing of a civil remedy notice. Nowhere within the CRN do Complainants specifically address why they failed to comply with the post-loss contractual obligation. Section 624.155, Florida Statutes cannot be reasonably interpreted in such a way that an insured could avoid complying with their duties after loss, thereby depriving an insurer of information necessary for its continued evaluation of a claim, while also imposing potential sanctions on the insurer. THE CRN FAILS TO COMPLY WITH THE SPECIFICITY REQUIREMENTS OF § 624.155, FLORIDA STATUTES First, Complainants’ CRN does not identify “the person or persons representing the insurer who are most responsible for/knowledgeable of the facts giving rise to the allegations in this notice.” The CRN only states “N/A.” The failure to provide this information constitutes noncompliance with the specificity requirements of the CRN statute and renders this CRN invalid. Demase v. State Farm Fla. Ins. Co., 351 So. 3d 136 (Fla. 5th DCA 2022) (holding that failing to identify persons, policy language, statutory provisions, and specific facts and circumstances did not even meet the lower burden of substantial compliance with the CRN statute, let alone strict compliance). In the section regarding specific relevant policy language, Complainants have listed every coverage of the subject policy, indicating that the “entire section” of Coverages A-D are relevant to the claimed violation. Prior to the filing of this CRN, it was FRONTLINE’s understanding based on the documents it was provided and Complainants’ own assertions that the claim was for damages under Coverage A-Dwelling, only. Damages under Coverage B-Other Structures, Coverage C-Personal Property, and Coverage D-Loss of Use were not claimed by Complainants, nor was any supporting documentation provided to support the applicability of these coverages to this claim. Complainants incorrectly incorporate policy provisions in excess of what was relevant to this claim to allow them the opportunity to allege excessive violations if this bad faith claim were to proceed to litigation. It should be noted that a breach of contract lawsuit has been filed by Complainants and is being actively litigated. Complainants have not claimed damages under Coverages B, C, or D in their Complaint or throughout the discovery process. Complainants’ failure to cite to specific policy language relevant to the violation is contrary to the specificity requirements of § 624.155, Fla. Stat. See also Julien v. United Property & Casualty Insurance Company, 311 So. 3d 875 (Fla. 4th DCA 2021) (broad references to policy language do not satisfy the specificity requirements of the civil remedy notice statute; such requirements are not mere technicalities). For this reason alone, the CRN is impermissibly vague and cannot serve as a prerequisite for pursuing a bad faith claim. The CRN is also impermissibly vague when describing the facts and circumstances that purportedly give rise to the claimed violations. The facts listed in the CRN appear to be boilerplate, copy-and-pasted allegations that could be asserted in any other CRN filed by Complainants’ counsel. In its entirety, the facts and circumstances section is less than one (1) page, comprised primarily of the claimed statutory violations that were asserted in the alleged statutory violations section. Complainants never describe evidentiary facts that supposedly amount to bad faith nor provide any facts as to why the claim should have been covered. Again, these allegations fall far short of the specificity requirements of § 624.155, Fla. Stat. and reiterated by Julien v. United Property & Casualty Insurance Company, 311 So. 3d 875 (Fla. 4th DCA 2021). The only “specific” facts Complainants include are the applicable policy number, the claim number, and the date counsel was retained. Complainants also assert that the property sustained damage on or about June 2, 2023. The actual claimed date of loss was May 26, 2023; June 2, 2023 is the date this claim was reported to FRONTLINE. Complainants have carelessly stated the incorrect date of loss, making it blatantly obvious that Complainants’ CRN is nothing more than an effort to “check the box” of filing a CRN before pursuing a bad faith lawsuit. Complainants make no genuine effort to put FRONTLINE on notice of the alleged violations, describe the facts and law supporting those allegations, or allow FRONTLINE to further investigate the allegations of misconduct and make an informed decision as to how to proceed. This is further evidenced by Complainants’ failure to comply with their duties after loss, as discussed above. The CRN does not meet the requirements of § 624.155, Fla. Stat. and cannot satisfy the conditions precedent for pursuing a bad faith claim. The defects cited above are not mere technicalities. Section 624.155(3)(b), Florida Statutes requires that CRNs be specific: (b) The notice shall be on a form provided by the department and shall state with specificity the following information, and such other information as the department may require: 1. The statutory provision, including the specific language of the statute, 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. If the person bringing the civil action is a third party claimant, she or he shall not be required to reference the specific policy language if the authorized insurer has not provided a copy of the policy to the third party claimant pursuant to written request. 5. A statement that the notice is given in order to perfect the right to pursue the civil remedy authorized by this section. (emphasis added). As Florida’s civil remedy notice procedure is in derogation of common law, § 624.155 “must be strictly construed.” Talat Enters., Inc. v. Aetna Cas. & Sur. Co., 753 So. 2d 1278, 1283 (Fla. 2000) see also Bay v. United Services Automobile Association, 305 So. 3d 294 (Fla. 4th DCA 2020). The CRN at issue simply does not meet these specificity requirements and is invalid. COMPLAINANTS’ REASONS FOR NOTICE ARE UNSUPPORTED BY FACTS The CRN also fails to provide specific facts to support each of the alleged statutory violations. FRONTLINE specifically addresses the statutory violations in Complainants’ CRN as follows: 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. 624.155(1)(b)(3) – Except as to liability coverages, failing to promptly settle claims, when the obligation to settle a claim has become reasonably clear, under one portion of the insurance policy coverage in order to influence settlements under other portions of the insurance policy coverage. FRONTLINE has no duty to settle a claim for which there is no coverage. FRONTLINE fully complied with Florida law and regulations in the adjusting of this claim. The CRN contains nothing more than a list of boilerplate allegations with no legitimate factual support. As discussed above, the singular paragraph of the CRN is comprised primarily of a list of supposed violations without any specific facts pertaining to this claim. Nowhere within the CRN do Complainants specifically address why there is allegedly coverage for the claim in contradiction to the opinions of the engineer retained by FRONTLINE. In fact, Complainants make no mention of the engineer’s inspection or opinions at all. Nor have Complainants provided any information outside of the CRN that, in any way, attempts to explain why Complainants believe there is coverage or that otherwise contradicts FRONTLINE’s coverage determination. Complainants and their representatives have failed to comply with their duties to act in good faith as imposed by § 624.155(5)(b)1. For these additional reasons, the CRN is not enforceable. See Julien v. United Property & Casualty Insurance Company, 311 So. 3d 875 (Fla. 4th DCA 2021) (broad references to policy language do not satisfy the specificity requirements of the civil remedy notice statute; such requirements are not mere technicalities). 626.9541(1)(i)(3)(a) – Failing to adopt and implement standards for the proper investigation of claims. 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. Complainants cite no legitimate facts supporting these allegations nor do they identify any supposed failure in FRONTLINE’s standards or investigation of the claim. In fact, they provide no specific facts pertaining to FRONTLINE’s investigation at all. The “facts and circumstances” section of the CRN only makes broad and baseless allegations. For example, they claim that FRONTLINE “failed to properly train and supervise its adjusters” and “continually failed to negotiate this claim;” yet Complainants never describe evidentiary facts that supposedly show FRONTLINE’s mishandling of the claim. FRONTLINE cannot address a supposed statutory violation when the accuser fails to provide any details regarding the alleged violation. FRONTLINE was consistent in its communication with Complainants throughout the claims handling process. Upon receiving notice of the claim on June 2, 2023, FRONTLINE sent an acknowledgement letter to Complainants that same day to gather additional information about the claim and explain the claims handling process. FRONTLINE’s field adjuster promptly coordinated an inspection of the property, which was completed on June 9, 2023. His report was reviewed, and ELIZABETH TAYLOR’s recorded statement was expeditiously coordinated to obtain further information. ELIZABETH TAYLOR’s recorded statement was completed June 21, 2023, the earliest that her schedule permitted. Upon FRONTLINE’s review of the field adjuster’s findings and ELIZABETH TAYLOR’s recorded statement, FRONTLINE retained an engineer to inspect the property. This inspection was completed on June 27, 2023. Following this inspection, the engineer was provided with additional photos from FRONTLINE on August 2, 2023 to further assist him in forming his opinions. Based on the engineer’s findings and his thorough review of the photos he was provided, FRONTLINE denied the claim and issued a three-page claim denial letter on August 18, 2023, explaining the factual and contractual basis for its claim denial. This letter explained the findings of the engineer inspection, aerial imagery of the property dated October 24, 2021 (prior to the inception of the subject policy) that revealed the same damages Complainants were claiming were the result of this claim, and included specific policy language that clearly stated these perils were not covered under the policy. Following the claim denial, Complainants filed a lawsuit for breach of contract on February 6, 2024. Litigation in that matter is still actively ongoing. On May 14, 2024, Complainants’ counsel informed the undersigned that Complainants would be proceeding with roof repairs or replacement. He informed that if FRONTLINE would like to reinspect the property, it needed to be completed by May 29, 2024. A reinspection was completed by FRONTLINE’s engineer on May 30, 2024. It is clear that FRONTLINE conducted a scrupulous investigation of this claim. Complainants and their representatives failed to include any facts pertaining to FRONTLINE’s investigation of the claim, including inspections, communications, and other information relevant to the claims handling process in their CRN; yet they audaciously assert FRONTLINE’s investigation was unreasonable and its standards are inadequate. 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. Complainants’ claim that FRONTLINE is in violation of this statute is farcical, as they never provided FRONTLINE with a sworn proof of loss. If Complainants completed a proof of loss form, it certainly was never provided to FRONTLINE. FRONTLINE cannot be in violation of a statute that was not even implicated. This further proves that Complainants’ CRN was not filed in good faith and filed for the sole purpose of satisfying the requirement prior to pursuing a bad faith lawsuit. 626.9541(1)(i)(3)(i) – Failing to pay personal injury protection insurance claims within the time periods required by s. 627.736(4)(b). This statute is not applicable to this claim. Personal injury protection has nothing to do with a property insurance claim. See Demase v. State Farm Florida Ins. Co., 2021 WL 3617403 (Fla. 5th J. Cir. July 14, 2021), affd 2022 WL 16909408 (granting summary judgment and noting that the CRN identified § 626.9541(1)(i)(3)(i) which “could not possibly apply to this homeowners insurance claim”). This is further evidence that the CRN is nothing more than a list of boilerplate allegations being used to “check the box” of filing a CRN before pursuing a bad faith lawsuit. THE CURE DEMAND IS IMPROPER Complainants demand that FRONTLINE “immediately tender payment in the amount of $103,458.00 less any applicable deductible and prior payment to the Insured.” They provide no specificity regarding what that amount is based upon or what damages are included, which is particularly concerning considering their vague references to broad sections of the policy, lack of facts, and citation to wholly inapplicable statutory provisions. They also have never provided any information to FRONTLINE to contradict its engineer’s opinions. This figure appears to be based on a replacement cost value estimate completed by Complainants’ counsel, Serrano, Cagan & Cagan, but Complainants have not provided notice to FRONTLINE that any repairs have been performed. Requiring payment on an RCV amount when repairs have not been performed would require FRONTLINE to pay extracontractual damages, which is an improper cure. See Universal Prop. & Cas. Ins. Co. v. Qureshi, --- So.3d ---, 49 Fla. L. Weekly D1575a, No. 4D2023-1338 (Fla. 4th DCA July 24, 2024). Complainants have also made unreasonable demands that do not constitute good faith, both during the claims process and via their defective cure demand. Most notably, Complainants are seemingly relying on the estimate completed by Serrano, Cagan & Cagan on November 10, 2023—almost one (1) month after this claim was denied and over five (5) months after the claimed date of loss. However, Complainants submitted a different estimate to FRONTLINE, completed by Elo Roofing on June 2, 2023, in the amount of $37,216.69, during the claims handling process. Notably, on June 30, 2023, Mrs. Taylor called a representative of FRONTLINE to inform them a tornado struck their home on are about June 27, 2023, causing additional damage. Despite this admission, Complainants are relying on an exorbitant estimate of damages (over $66,000.00 more than their initial estimate), that does not separate the damages they are claiming were caused as a result of this claim and the damages that were caused by the subsequent tornado event. In order to meet Complainants’ cure demand, FRONTLINE would have to blindly commit to paying an amount that is at least partially attributable to a subsequent loss and is well in excess of the amount previously submitted to FRONTLINE by Complainants. Further, as no estimate was provided in conjunction with the CRN, FRONTLINE is left only to speculate as to what damages the amount demanded includes. This additionally renders the civil remedy notice defective. COMPLAINANTS’ CRN VIOLATES THEIR DUTY TO ACT IN GOOD FAITH Pursuant to Section 624.155(5)(b)1., Fla. Stat., “[t]he insured, claimant, and representative of the insured or claimant have a duty to 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.” Complainants and their representatives have failed to comply with this duty of good faith to furnish information regarding the claim by filing a CRN with insufficient facts and misleading allegations. Complainants have also made unreasonable demands that do not constitute good faith, both during the claims process and via their defective cure demand. Most notably, Complainant obtained an estimate for a full roof replacement on June 2, 2023, which totaled $37,216.69. This estimate was provided to FRONTLINE during the claims handling process prior to the claim denial. Yet, Complainants are seemingly relying on an estimate of damages (reflected in their cure demand as $103,458.00) that is over $66,000.00 more than the initial estimate. This second estimate was not completed until November 10, 2023. This is particularly egregious because ELIZABETH TAYLOR admitted to a FRONTLINE representative that the property had been damaged by a tornado event subsequent to the date of loss. Finally, Complainants have not made a good faith effort to resolve this claim or otherwise comply with their co-equal duty to act in good faith, as they provide no information that contradicts the facts and opinions regarding the loss stated in FRONTLINE’s claim denial letter. Had Complainants genuinely desired to resolve this claim, they would have provided information necessary to rebut the facts and opinions they claim are incorrect, rather than merely submitting an exorbitant estimate and using both litigation and the CRN process as a cudgel to try to extract a settlement of a denied claim. As a result, any future bad faith lawsuit must be dismissed. CONCLUSION AND RESERVATION OF RIGHTS FRONTLINE respectfully and categorically denies without limitation all of Complainants’ allegations within the CRN, including but not limited to the alleged violations of the cited provisions of Florida law, regardless of whether or not the specific allegation was cited above. Frontline further denies any and all stated, implied, and/or unspecified allegations, including but not limited to denying any and all allegations of alleged improper claim handling, inadequate investigation, improper delay or denial, failing to adequately and promptly communicate, failing to provide reasonable explanations, failing to affirm or deny coverage, making misrepresentations, general business practices, unfair or deceptive trade practices, and/or unsatisfactory settlement offers or practices, and the like, whether or not specifically alleged by Complainants’ CRN. Frontline has not violated any applicable provision of Florida law in the handling of this claim. Accordingly, FRONTLINE objects to and denies the allegations of the CRN. The objections and denials herein are not necessarily exhaustive, and this response shall not prevent Frontline from asserting any other appropriate objections, denials, and/or defenses related to this claim and/or CRN. Moreover, due to the objections and defects discussed herein, the Department should strike and/or reject the CRN as invalid. As a final matter, it should be emphasized that any policy issued by FRONTLINE is governed by the policy’s terms, conditions, and exclusions together with any endorsements. This CRN response does not waive any such provisions of the policy. Furthermore, any action taken by or on behalf of FRONTLINE, any related insurance company, or its authorized representative(s), whether in the past or future, to investigate the alleged loss, to adjust any claim or request for payment, or in any way related to or arising out of the subject claim or loss, shall not waive any of the terms, conditions, or any other provisions of the policy. Sincerely, /s/ Annabelle L. Maddox Brian E. Chojnowski Annabelle L. Maddox PENNINGTON, P.A. Copy furnished to: Florida Department of Financial Services FIRST PROTECTIVE INSURANCE COMPANY d/b/a FRONTLINE INSURANCE

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