Filing Number: 795442
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| Filing Accepted: 12/5/2024 |
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KUBASIEWICZ
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First Name |
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DARWIN AND KAREN |
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| Street Address
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460 PINE EAGLE DRIVE |
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FLEMING ISLAND,
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32003
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| Email Address
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DARWINK@ATT.NET |
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Insured |
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| Last/Business Name* |
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KUBASIEWICZ |
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First Name |
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DARWIN AND KAREN |
| Policy # * |
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7709HR029888 |
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Claim #* |
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181281-GP |
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Attorney is Applicable
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| Last Name* |
O'NEIL
First Name *
JONATHAN
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| Street Address* |
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203 FORT WADE ROAD, SUITE 260 |
| City, State Zip* |
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PONTE VEDRA
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FLORIDA
32081
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| Email Address * |
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JONATHAN@WOOLSEYMORCOM.COM |
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| Insurer Type
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 Authorized Insurer
 Unauthorized Insurer
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| Insurer Name |
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| Insurer Name* |
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NATIONWIDE PROPERTY AND CASUALTY INSURANCE COMPANY
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| Insurer Name* |
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NAIC Company Code 37877 |
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| Name of individual responsible for violation (if any):*
CAMERON CULLEN (FLA. ADJ. LIC. # W772268)
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| Type of Insurance
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Residential Property & Casualty
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| Reason for Notice
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Claim Delay
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Other
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Wrongful claim denial
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Unfair Trade Practice
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Other
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Unfair claim settlement practices
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Other
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Unreasonable investigation
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Other
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Failure to act on claim
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Other
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Failure to conduct a reasonable investigation based on available information
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Other
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Failure to maintain proper complaint handling procedures
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Other
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Misrepresenting the insurance policy provisions to the insured
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Other
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Misrepresenting Florida statutory provisions to the insured
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Other
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Misrepresenting facts to the insured
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Other
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Failure to acknowledge and act promptly upon communications with respect to claims
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Other
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Denying claims without conducting reasonable investigations based upon available information
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Statutory provision(s) which the insurer allegedly violated.
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| 624.155(1)(b)(1) |
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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.
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| 624.155(1)(b)(3) |
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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.
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| 626.9541(1)(i)(2) |
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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.
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| 626.9541(1)(i)(3)(a) |
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Failing to adopt and implement standards for the proper investigation of claims.
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| 626.9541(1)(i)(3)(b) |
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Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue.
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| 626.9541(1)(i)(3)(c) |
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Failing to acknowledge and act promptly upon communications with respect to claims.
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| 626.9541(1)(i)(3)(d) |
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Denying claims without conducting reasonable investigations based upon available information.
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| 626.9541(1)(i)(3)(e) |
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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.
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| 626.9541(1)(i)(3)(f) |
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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.
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| 626.9541(1)(i)(3)(g) |
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Failing to promptly notify the insured of any additional information necessary for the processing of a claim.
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| 626.9541(1)(i)(3)(h) |
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Failing to clearly explain the nature of the requested information and the reasons why such information is necessary.
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| 626.9541(1)(i)(4) |
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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).
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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 — PERILS INSURED AGAINST
A. Coverage A — Dwelling And Coverage B — Other Structures
1. We insure against direct physical loss to property described in Coverages A and B.
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[A]ny ensuing loss to property described in Coverages A, B, and C not precluded by any other provision in this policy is covered..
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B. Coverage C — Personal Property We insure for direct physical loss to the property described in Coverage C caused by any of the following perils unless the loss is excluded in Section I — Exclusions . . . 2. Windstorm Or Hail.
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D. Coverage D — Loss Of Use
The limit of liability for Coverage D is the total limit for the coverages in 1. Additional Living Expense, 2. Fair Rental Value and 3. Civil Authority Prohibits Use below. 1. Additional Living Expense If a loss covered under Section I makes that part of the "residence premises" where you reside not fit to live in, we cover any necessary increase in living expenses incurred by you so that your household can maintain its normal standard of living. Payment will be for the shortest time required to repair or replace the damage or, if you permanently relocate, the shortest time required for your household to settle elsewhere. Payment will not exceed the actual loss sustained or the Coverage amount shown in the Declarations. 2. Fair Rental Value If a loss covered under Section I makes that part of the "residence premises" rented to others or held for rental by you not fit to live in, we cover the fair rental value of such premises less any expenses that do not continue while it is not fit to live in. Payment will be for the shortest time required to repair or replace such premises. Payment will not exceed the actual loss sustained or the Coverage amount shown in the Declarations. 3. Civil Authority Prohibits Use If a civil authority prohibits you from use of the "residence premises" as a result of direct damage to neighboring premises by a Peril Insured Against, we cover the loss as provided in 1. Additional Living Expense and 2. Fair Rental Value above for no more than two weeks.
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E. Additional Coverages
These additional coverages are subject to the policy deductible except as noted. In no event will the deductible be applied more than once to any one loss.
1. Debris Removal a. We will pay your reasonable incurred expense for the removal of: (1) Debris of covered property if a Peril Insured Against that applies to the damaged property causes the loss; or (2) Ash, dust or particles from a volcanic eruption that has caused direct loss to a building or property contained in a building. This expense is included in the limit of liability that applies to the damaged property. If the amount to be paid for the actual damage to the property plus the debris removal expense is more than the limit of liability for the damaged property, an additional 5% of that limit is available for such expense. b. We will also pay your reasonable incurred expense, up to $1,000, for the removal from the "residence premises" of: (1) Your trees felled by the peril of Windstorm or Hail or Weight of Ice, Snow or Sleet; or (2) A neighbor's trees felled by a Peril Insured Against under Coverage C. The $1,000 limit is the most we will pay in any one loss, regardless of the number of fallen trees. No more than $500 of this limit will be paid for the removal of any one tree. This coverage is additional insurance.
2. Reasonable Emergency Measures a. We will pay up to the greater of $3,000 or 1% of your Coverage A limit of liability for the reasonable costs incurred by you for necessary measures taken solely to protect covered property from further damage when the damage or loss is caused by a Peril Insured Against. b. We will not pay more than the amount in a. above, unless we provide you approval within 48 hours of your request to us to exceed the limit in a. above. In such circumstance, we will pay only up to the additional amount for the measures we authorize. If we fail to respond to your request to exceed the limit in a. above within 48 hours of your request to us and the damage or loss is caused by a Peril Insured Against, you may exceed the amount in a. above only up to the cost incurred by you for the reasonable emergency measures necessary to protect the covered property from further damage. c. If, however, the damage or loss is caused by a windstorm or a windstorm during a hurricane (and hurricane form H 03 15 FL is attached to the policy) and windstorm is a peril covered by the policy, the amount we pay under this additional coverage is not subject to the $3,000 or 1% Coverage A limitation in a. above. d. A reasonable measure under this Additional Coverage E.2. may include a permanent repair when necessary to protect the covered property from further damage or to prevent unwanted entry to the property. To the degree reasonably possible, the damaged property must be retained for us to inspect.
3. Trees, Shrubs And Other Plants We cover trees, shrubs, plants or lawns, on the "residence premises", for loss caused by the following Perils Insured Against: a. Fire or lightning; b. Explosion; c. Riot or civil commotion; d. Aircraft; e. Vehicles not owned or operated by a resident of the "residence premises"; f. Vandalism or malicious mischief; g. Theft; or h. Collapse of a building. We will pay up to 5% of the limit of liability that applies to the dwelling for all trees, shrubs, plants or lawns. No more than $500 of this limit will be paid for any one tree, shrub or plant. We do not cover trees, shrubs, plants or lawns: a. Grown for "business" purposes; or b. That are part of, or a continuation of, a forest, including national forest or wildlife preserve. This coverage is additional insurance.
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11. Ordinance Or Law a. You may use up to 25% of the limit of liability, or higher limit if shown on the Declarations, that applies to Coverage A — Dwelling and provides coverage for the increased costs you "incur" due to the enforcement of any ordinance or law which requires or regulates: (1) The construction, demolition, remodeling, renovation or repair of that part of a covered building or other structure damaged by a Peril Insured Against; (2) The demolition and reconstruction of the undamaged part of a covered building or other structure, when that building or other structure must be totally demolished because of damage by a Peril Insured Against to another part of that covered building or other structure; or (3) The remodeling, removal or replacement of the portion of the undamaged part of a covered building or other structure necessary to complete the remodeling, repair or replacement of that part of the covered building or other structure damaged by a Peril Insured Against. b. You may use all or part of this ordinance or law coverage to pay for the increased costs you "incur" to remove debris resulting from the construction, demolition, remodeling, renovation, repair or replacement of property as stated in a. above.
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14. Biological Deterioration Or Damage Clean Up And Removal In the event that a covered cause of loss results in "biological deterioration or damage" to property covered under Coverages A, B, and C, we will pay, up to the amount shown on the Declarations, for: a. The cost to clean up, remove and dispose of the "biological deterioration or damage" to covered property; b. The cost to tear out and replace any part of the building or other covered property needed to gain access to the "biological deterioration or damage"; c. The cost of testing which is performed in the course of clean up and removal of the "biological deterioration or damage" from the "residence premises"; and d. Additional living expenses you may incur, as outlined under Coverage D that result from items a., b. or c. above.
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Also refer to:
Coverage A provision, coverage B provision, coverage C provision, coverage D provision, all additional coverages provisions, all coverages provided by endorsement or rider, the declarations page, loss payment or settlement provision, duties in event of loss policy provision, all terms and conditions of section I of the insurance policy, the insurance policy definitions section, the insurance policy‘s exclusion of coverage provisions, all insurance policy provisions that provide coverage to the insured property, and all policy provisions.
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Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.
624.155(1)(a)(1) – violating 626.9541(1)(i)
626.9541(1)(a)(1) -- misrepresenting the terms of an insurance policy.
626.9541(1)(i) -- unfair claim settlement practices.
Facts of the case:
Nationwide Property & Casualty Insurance Company (“NATIONWIDE”) has committed the following in handling the insureds’ claim: 1) failure to pay benefits owed; 2) failure to act in due diligence and good faith to resolve claims; 3) placing the financial interest of the insurer before that of the policy holder and claimant; 4) failure to properly train, evaluate, and manage adjusters retained to represent the policies and procedures of NATIONWIDE; 5) looking for ways to delay benefit payments and otherwise “low ball” or “stone wall” claims; 6) looking for ways to deny the insureds’ claim; 7) looking for ways to reduce recovery to the insureds; 8) failure to perform a reasonable investigation; 9) misrepresenting Florida statutory provisions to its insured; 10) misrepresenting insurance policy provisions to the insureds; 11) NATIONWIDE has failed and refused to acknowledge coverage and promptly pay the benefits due and owed to the insureds; 12) the reasons for this may be attributed to improper training, supervision, and/or motivation of outside adjusters and claims supervisors to promptly and fairly adjust and pay full benefits available to the insureds. The insurer may have failed to adopt proper standards of investigation and adjustment of losses or is otherwise not implementing those standards because a proper investigation and full and prompt payment for the loss is not occurring.
In Florida, the work of adjusting insurance claims engages the public trust. NATIONWIDE has breached this duty by its adjustment of the insureds’ claim of loss. NATIONWIDE has failed to create and implement adequate guidelines for proper investigation to evaluate claims handling and for training and supervision of employees resulting in violations as set forth above. NATIONWIDE has failed and/or refused to thoroughly, accurately, and completely investigate and evaluate the insureds’ insurance claim for damages. Despite the insureds’ timely notification to NATIONWIDE of their insurance claim, NATIONWIDE has failed and refused to acknowledge the covered loss and pay all amounts due and owing to the insureds under the policy of insurance. NATIONWIDE has failed to promptly settle the insureds’ insurance claim, when the obligation to settle the claim had become reasonably clear, under one portion of the insurance, in order to influence settlements under other portions of the insurance policy coverage. Despite the insureds’ pleas otherwise, NATIONWIDE has failed and refused to acknowledge its obligation to tender all insurance proceed monies due and owing the insured or assist the insureds in mitigation of the damages.
In exchange for a premium paid by the insureds, NATIONWIDE issued the subject insurance policy which provided coverage for the insured property from November 24, 2022, to November 24, 2023, for “direct physical loss to property described in Coverages A and B.” As such, the subject all-risk Policy contains coverage for all direct physical losses to the insured property unless the loss is specifically and unambiguously excluded from coverage by the Policy. On or about October 4, 2023, the insured property suffered a windstorm loss, and the insureds immediately submitted a claim to NATIONWIDE for property damage, i.e., storm and wind damage throughout the insured property. Hence, the insureds suffered a substantial loss regarding the real property and continue to suffer such loss. Having suffered such substantial damage, the insureds promptly notified NATIONWIDE of the loss in an effort to mitigate the current damage and prevent the exacerbation of any additional losses. The desired result did not follow. NATIONWIDE since being presented the Insureds’ claim has misrepresented policy provisions to avoid paying the insured what they are owed under the policy. Ultimately, NATIONWIDE has failed and refused to properly settle the insureds’ claim in good faith. The insureds have requested that NATIONWIDE conduct an investigation, admit coverage, and pay damages; NATIONWIDE has failed and refused to do so. In short, NATIONWIDE has failed to handle its insureds’ claim in good faith in violation of Fla. Stat. 624.155(1)(b)(1), 624.155(1)(b)(3), and 626.9541(1)(i).
Based upon NATIONWIDE’s investigation and property inspection, which confirmed windstorm damages from the subject loss, NATIONWIDE nevertheless sent correspondence to the insureds dated November 3, 2023 (signed by HERITGE’s adjuster, Cameron Cullen - Fla. Adj. Lic. # W772268) and communicated its unequivocal denial of the claim. In regard to insurance contracts, a specific refusal to pay a claim is the breach which triggers the cause of action. Allstate Ins. Co. v. Kaklamanos, 843 So. 2d 885, 892 (Fla. 2003); Donovan v. NATIONWIDE Fire and Cas. Co., 574 So. 2d 285, 286 (Fla. 2nd DCA 1991) (finding that a breach of contract takes place at the moment the insurance company refuses to pay a claim). Therefore, NATIONWIDE breached the Policy. Moreover, any argued exclusions and/or limitations to coverage are devoid of anti-concurrent causation language. Thus, “coverage may exist where an insured risk constitutes a concurrent cause of the loss even when it is not the prime or efficient cause.” Sebo v. Am. Home Assurance Co., Inc., 208 So. 3d 694, 699 (Fla. 2016). In addition, under the Policy, any ensuing loss to property not excluded or excepted in this policy is covered. Hence, there are a myriad of coverages under the Policy that would provide coverage for the loss. Nevertheless, NATIONWIDE failed and refused to acknowledge the covered loss and pay all amounts due and owing for the loss. Therefore, NATIONWIDE breached the Policy.
Questioning the propriety of NATIONWIDE’s coverage denial, and given the extensive nature of the physical damage, the insured retained a loss consultant, Property Pros Consulting. (“PPC”), to perform an investigation and damage evaluation in accordance with industry standards and Florida law. Based on its investigation, PPC determined that a windstorm on or about September 11, 2023, caused damage throughout exterior of the insured property (particularly the roof warranting its replacement). Moreover, PPC determined that at least $59,598.41 worth of repairs would be required to return the property to its pre-loss condition as a result of the windstorm loss. Nevertheless, NATIONWIDE failed and refused to acknowledge the covered loss and pay all amounts due and owing under the Policy. Therefore, NATIONWIDE breached the Policy.
Thereafter, the insureds sent correspondence to NATIONWIDE enclosing the supporting PPC report outlining the cause, scope, and cost of the loss along with other supporting documents and requested NATIONWIDE to reconsider its coverage denial. Nevertheless, NATIONWIDE failed and refused to acknowledge the covered loss and pay all amounts due and owing under the Policy. Therefore, NATIONWIDE breached the Policy
On December 5, 2024, the insureds sent correspondence to NATIONWIDE enclosing their Sworn Statement in Proof of Loss, the supporting PPC report outlining the cause, scope, and cost of the loss along with other supporting documents, the Notice of Intent to Initiate Litigation, and requested NATIONWIDE to reconsider its coverage denial. To date, NATIONWIDE has failed and refused to acknowledge the covered loss and pay all amounts due and owing under the Policy. Therefore, NATIONWIDE breached the Policy.
As such, NATIONWIDE’s coverage denial is a blatant misrepresentation of the available coverages under the Policy in direct violation of Fla. Stats. 626.9541(1)(a)(1), 626.9541(1)(i)(3)(b), 626.9541(1)(a)(1), and 626.9541(1)(i)(2) and is nothing more than a mere pretext to wrongfully deny and delay this claim. As a result, NATIONWIDE has materially misrepresented the coverages under the subject policy to the insured for the purpose and with the intent of effecting settlement of the insureds’ claim on less favorable terms than those provided in, and contemplated by, the subject policy in direct violation of Fla. Stat. § 626.9541(1)(i)(2). Further, NATIONWIDE is in violation of Florida statutes §§ 626.9541(1)(a)(1), 626.9541(1)(i)(3)(b), and 626.9541(1)(a)(1) by misrepresenting pertinent facts and insurance policy provisions relating to coverages at issue; and also in violation of Fla. Stat. 626.9541(1)(i)(3)(d) by denying the insureds’ claim without conducting a reasonable investigation based upon available information.
In summary, the insureds’ loss is clearly covered by the terms of the policy of insurance with NATIONWIDE. However, NATIONWIDE chose to deny coverage for the insureds’ loss. Despite clear evidence that the damages were covered and caused by a covered peril, the claim was denied. To date, NATIONWIDE continues to deny the insureds and its insured full indemnity for the claim. While NATIONWIDE refuses to honor this claim, a jury in Clay County will likely do what NATIONWIDE has refused; exercise the benefit of doubt in favor of the insureds in finding full coverage for this loss. Indeed, the insureds will undoubtedly meet the burden of proof at trial, under the NATIONWIDE all-risk policy, to show that, while NATIONWIDE provided insurance coverage, damage occurred to the insured property. See Jones v. Federated Nat'l Ins. Co., 235 So. 3d 936, 942 (Fla. 4th DCA 2018). With the data presented within NATIONWIDE’s investigation and PPC’s investigation, NATIONWIDE’s burden to demonstrate by the greater weight of the evidence that all the physical damage to the insured property was caused solely by excluded perils under the policy and not in combination with a covered peril has not and cannot be met. See Sebo v. Am. Home Assurance Co., Inc., 208 So. 3d 694 (Fla. 2016). Despite clear indicators of covered damage, NATIONWIDE nevertheless inexplicably denied the insureds’ claim.
As of today, NATIONWIDE has failed and refused to inform the insureds of their rights under the policy of insurance and Florida statutes, has improperly delayed the insureds’ claim, has wrongfully denied the insureds’ claim, and has failed and refused to adequately indemnify the insured for the loss and defiantly continues to do so. Indeed, from the time of receiving the claim, NATIONWIDE has purposely and maliciously delayed in adjusting the subject claim in an effort to either avoid paying the claim altogether or, at the very least, avoid paying the full extent of the loss. Notably, under Florida law, “[t]he filing of a lawsuit does not extinguish the insurer’s obligations under the policy to adjust and pay the claim.” Tristar Lodging, Inc. V. Arch Specialty Ins. Co., 434 F. Supp. 2d 1286, 1289 (M.D. Fla. 2006).
To date, the insureds have made a good faith effort to comply with all of the requirements under the subject policy of insurance, and it is only fair that NATIONWIDE do the same. Yet, that is not the case. The insureds feel that the insured property is a valuable asset, and, by continuously delaying the proper handling of this claim, NATIONWIDE is putting the insured property at risk. As responsible property owners, the insureds purchased insurance to protect the property, paid all of the premiums, and have kept up to date with the responsibilities under the policy. Yet, when the insureds needed to rely on the insurance because of this unforeseen loss, NATIONWIDE turned its back and delayed and wrongfully denied coverage that the insureds are rightfully owed.
Ultimately, NATIONWIDE has failed and refused to properly investigate the loss. The insureds have requested that NATIONWIDE admit coverage and pay damages, NATIONWIDE has failed and refused to do so, and continues to refuse to fully indemnify the insureds for the loss and pay the amounts necessary to properly repair the insureds’ property, despite knowing it is required to do so. In short, NATIONWIDE has failed to handle its insureds’ claim in good faith.
In Florida, the work of adjusting insurance claims engages the public trust; NATIONWIDE has breached this duty by its insufficient adjustment of the insureds’ claim. NATIONWIDE has failed to create and implement adequate guidelines for proper investigation to evaluate claims handling and for training and supervision of employees resulting in statutory violations set forth above. NATIONWIDE has failed and/or refused to thoroughly, accurately, and completely investigate and evaluate the insureds’ insurance claim for damages.
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 upon determinable contingencies. Inherent is the fact that payment must be made timely and promptly so that the insured may mitigate their damages to put them back into the position they were prior to loss as quickly as possible. NATIONWIDE breached this duty.
The actions taken by NATIONWIDE in the handling / adjustment of the insureds’ claim were willful, wanton, and with complete disregard for the rights of its insured and occur with such a frequency as to indicate a general business practice and are in violation of Fla. Stat. 624.155 and 626.9541.
NATIONWIDE’s actions amount to but are not limited to the following:
1. Claim delay
2. Wrongful claim denial
3. Unfair trade practice
4. Unfair claim settlement practices
5. Unreasonable investigation
6. Failure to act on claim
7. Failure to conduct a reasonable investigation based on available information
8. Failure to maintain proper complaint handling procedures
9. Misrepresenting the insurance policy provisions to the insured
10. Misrepresenting Florida statutory provisions to the insured
11. Misrepresenting facts to the insured
12. Failure to acknowledge and act promptly upon communications with respect to claims
13. Denying claims without conducting reasonable investigations based upon available information
14. 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.
15. 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.
16. Failing to promptly notify the insured of any additional information necessary for the processing of a claim.
17. Failing to clearly explain the nature of the requested information and the reasons why such information is necessary.
18. Failing to pay undisputed amounts of partial or full benefits owed under first-party property insurance policies within 90 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 an act of God, prevented by the impossibility of performance, or due to actions by the insured or claimant that constitute fraud, lack of cooperation, or intentional misrepresentation regarding the claim for which benefits are owed.
Therefore, to cure the defects outlined in this civil remedy notice, NATIONWIDE must:
(1): Admit full coverage for the insureds’ loss;
(2): Tender all insurance monies due and owing to the insured for the loss under the subject Policy;
(3): Pay statutory interest on the amount of unpaid contract damages from the date of loss to the present time pursuant to Florida statute 627.70131; and
(4): Pay the insureds’ attorneys’ fees and costs pursuant to Florida Statute § 627.428 and/or § 626.9373.
A copy of this form submitted to the FDFS has been emailed and/or uploaded and also printed out and mailed to the following parties providing them notice of the filing of this civil remedy notice:
Nationwide Property & Casualty Insurance Company
P.O. Box 182068.
Columbus, OH 43215-2068
nationwide-claims@nationwide.com
CULLEC2@nationwide.com
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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.
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DFS-10-363
Rev. 10/14/2008
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