Civil Remedy Notice of Insurer Violations
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Filing Number:     806165
Filing Accepted:  2/10/2025
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Complainant
Last/Business Name *  
ARIZA   First Name   JON AND ANDREA
Street Address * 11577 48TH AVE N
City, State Zip * SAINT PETERSBURG, FL 33708
Email Address * N/A
Complainant Type: * Insured
Insured
Last/Business Name*   ARIZA   First Name   JON AND ANDREA
Policy # * FPH3-000122746 Claim #* 01000119531
Attorney
Attorney is Applicable
Last Name* ELIMELECH First Name * REBECCA Initial R
Street Address* 1500 N.E. 162ND ST.
City, State Zip* MIAMI , FLORIDA 33162
Email Address * RELIMELECH@ILGPA.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   FIRST PROTECTIVE INSURANCE COMPANY
NAIC Company Code 10897
 
Name of individual responsible for violation (if any):* N/A
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Claim Delay
Unsatisfactory Settlement Offer
Unfair Trade Practice
* Statutory provision(s) which the insurer allegedly violated.
 
624.155(1)(b)(1) Not attempting in good faith to settle claims when, under all the circumstances, it could and should have done so, had it acted fairly and honestly toward its insured and with due regard for her or his interests.
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)(g) Failing to promptly notify the insured of any additional information necessary for the processing of a claim.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

SECTION I – PROPERTY COVERAGES A. Coverage A – Dwelling 1. We cover: a. The dwelling on the "residence premises" shown in the Declarations, including structures attached to the dwelling; and b. Materials and supplies located on or next to the "residence premises" used to construct, alter or repair the dwelling or other structures on the "residence premises". B. Coverage B – Other Structures 1. We cover other structures on the "residence premises" set apart from the dwelling by clear space. This includes structures connected to the dwelling by only a fence, utility line, or similar connection. C. Coverage C – Personal Property 1. Covered Property We cover personal property owned or used by an "insured" while it is anywhere in the world. After a loss and at your request, we will cover personal property owned by: a. Others while the property is on the part of the "residence premises" occupied by an "insured"; or b. A guest or a "residence employee", while the property is in any residence occupied by an "insured". 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. 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 This peril includes loss to watercraft of all types and their trailers, furnishings, equipment, and outboard engines or motors, only while inside a fully enclosed building. This peril does not include loss to the property contained in a building caused by rain, snow, sleet, sand or dust unless the direct force of wind or hail damages the building causing an opening in a roof or wall and the rain, snow, sleet, sand or dust enters through this opening.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

Jon Ariza and Andrea Ariza (hereinafter the “Insureds”), paid for a policy of insurance with First Protective Insurance Company d/b/a Frontline Insurance (hereinafter, “Insurer”) bearing policy number FPH3-000122746 (the “Policy”). The Policy provides coverage for damage to the Insureds’ property located at 11577 48th Ave. N, Saint Petersburg, FL 33708 (the “Property”), including the significant damage that occurred as a result of Hurricane Helene on or about September 26, 2024 (the “loss”). Specifically, the Insureds’ Property sustained substantial damage to the roof, interior and exterior. The home was flooded with three feet of contaminated water, a mix of saltwater and sewer water, which caused extensive damage throughout the property. All personal contents were affected, along with pool equipment, air conditioning units, and filters, which were completely destroyed. The air handler was ripped from the garage ceiling and wall, and a licensed professional has condemned the entire unit. The fence is missing, and the dock has a noticeable bow in it. The pavers near the pool have sunk due to lost silt. A built-in grill and smoker were thrown around, and sheds were torn apart. The pool is now filled with black and brown water, with fish swimming in it. The pavers in the driveway have large gaps and have sunk, as the sand and filler have shifted. The washing machine was displaced and is now lying on its side. The stone and stucco grill were heavily damaged. There has been no electrical or plumbing work done yet. Water from the flood, a contaminated mix of saltwater and sewer water, went over the toilet. Shingles are missing from the roof, which is relatively new. The Insureds promptly reported their claim to the Insurer. On November 14, 2024, the Insurer sent a reservation of rights letter to the Insureds requesting documents and information, including cause of loss documentation, photos and videos of the damages at the time of the loss, an inspection, emergency services documents and rebuild estimates and invoices. On November 19, 2024, the Insurer sent a letter to the Insureds advising that their inspection of the property on November 14, 2024, revealed damages caused by wind to the roof and damages to the fence and interior damages caused by flood and/or surge. The Insurer informed the Insureds that they are unable to issue payment as the damages to the property totaled $776.20, which is less than the policy deductible of $ 6,580.00. In this letter, the Insurer also denied coverage for the repair to the fence, contents, and interior damages, alleging that the Homeowners Policy excludes coverage for flood and storm surge. The Insureds contacted the Insurance Litigation Group, P.A. (hereafter, ILGPA), who conducted a thorough inspection of the property and compiled an estimate of damages. ILGPA, on behalf of the Insureds, forwarded said estimate which fully detailed the Insureds’ damages and total $45,015.66. However, the Insurer refuses to resolve the Insureds’ claim and pay for all damages to the Property. The Insurer’s conduct is in bad faith and violates Florida’s statutes concerning the adjustment of insurance claims. First, Florida Statute § 624.155(1)(B)(1) requires good faith in the settlement of claims. The Insurer is in violation of this Statute for failing to provide a reasonable repair estimate. What is more, the Insurer violated Florida Statute § 624.155(1)(b)(3) by failing to promptly settle the claim, when the obligation to settle the claim became reasonably clear. Again, the Insurer failed to make a good faith offer to settle this claim and failed to account for the full scope of the damages. They failed to respond to the estimate provided by ILGPA, on the Insureds’ behalf, in a timely manner. They are obligated to provide coverage for all damages to the Insureds’ Property, and not attempt to resolve this claim with lowball offers. Additionally, the Insurer’s conduct violates Florida Statute § 626.9541, which prohibits unfair settlement practices. More specifically, the Insurer has violated Florida Statute § 626.9541(1)(i)(3)(a) by failing to adopt and implement standards for the proper investigation of claims. The Insureds complied with the Insurer’s request for information on December 23, 2024. However, the Insurer has failed to fairly adjust the Insureds’ loss. Further, the Insurer has violated Florida Statute § 626.9541(1)(i)(3)(c) by failing to acknowledge and act promptly with the Insureds and its counsel. As mentioned above, the Insurer failed to account for the full scope of the damages and has additionally failed to respond to the estimate provided by ILGPA, on behalf of the Insureds, in a timely manner, delaying the resolution of this claim. Had the Insurer done so, it would have immediately settled this claim on a fair and reasonable basis and provided full coverage to its Insureds. Moreover, the Insurer violated Florida Statute § 626.9541(1)(i)(3)(g), by failing to promptly notify the Insureds of any additional information necessary for the processing of a claim. The Insureds timely reported their claim on October 06, 2024. However, the Insurer did not request documents and information from the Insureds that are material to the Insurer’s evaluation of the claim until November 14, 2024. Therefore, to cure the defects outlined in this Civil Remedy Notice, the Insurer must: (1) create and implement adequate guidelines for the proper investigation and evaluation of claims and for the training and supervision of employees, which will avoid future statutory violations and avoid this from occurring in the future; (2) immediately tender all insurance proceeds due and owing its Insureds under the Policy in the amount of $45,015.66 (less the deductible and any prior payments), plus all statutory interest; (3) act fairly and honestly towards its Insureds and with due regard for their interests in attempting to settle their Insureds’ claim; (4) hold the claim open in the event that its errors and delay does or may cause the Insureds to suffer either further loss and/or damage; and, (5) stipulate to the Insureds’ entitlement to attorney’s fees and court costs pursuant to Florida Statutes §§ 627.428 and 626.9373. Acknowledgment This notice is given in order to perfect the right to pursue the civil remedy authorized by Florida Statutes section 624.155, should First Protective Insurance Company d/b/a Frontline Insurance fail to cure the violations set forth in this Civil Remedy Notice within the given cure period.
Comments
User Id Date Added Comment
bkelley@wallenkelley.com 04-09-2025 April 9, 2025 Florida Department of Financial Services Consumer Assistance/Civil Remedy Section Larson Bldg., 200 E. Gaines Street Tallahassee, Florida 32399-0322 Re: Complainants: Jon and Andrea Ariza Address: 11577 48th Ave N, Saint Petersburg, FL 33708 Insureds: Jon and Andrea Ariza Policy #: FPH3-000122746 Claim: 01000119531 Attorney: Rebecca R. Elimelech, Esq. Email: relimelech@ilgpa.com Address: 1500 NE 162nd Street, Miami, FL 33162 DOI File #: 806165 Date of Acceptance: February 10, 2025 To Whom It May Concern: Please accept this as the response of First Protective Insurance Company ("Frontline") to the Civil Remedy Notice filed by the Complainants, Jon and Andrea Ariza. Frontline’s response is specifically in regard to Claim 01000119531, which is related to a claim for Insureds’ property located at 11577 48th Ave N, Saint Petersburg, FL 33708, which was Insureds by Frontline under Policy # FPH3-000122746 with effective dates of that Policy being October 23, 2023 through October 23, 2024, and was in effect on the alleged date of loss, September 25, 2024, as a result of Hurricane Helene. It should be noted from the onset that this Civil Remedy Notice is moot, as the Insureds have withdrawn the aforementioned claim. Statement of Facts This matter arises from an alleged Hurricane Helene claim at the Insureds’ Saint Petersburg, Florida residence. For the convenience of the reader, I have broken down the Statement of Facts that will detail Frontline’s handling of the file. 1. Claim: 01000119531 The instant claim was reported to Frontline on October 6, 2024. After receipt of the claim, Frontline assigned a claim number, 01000119531, and, on October 6, 2024, sent an acknowledgment letter to the Insureds. In addition, Frontline provided a Homeowners’ Bill of Rights to inform them of their rights under the Policy. Frontline also sent correspondence requesting an executed sworn proof of loss in an effort to ascertain the amount of damages being claimed and a third letter informing the Insureds of their right to mediate the claim. Specifically, the claim notification letter stated: “This communication is intended to confirm receipt of the above-captioned claim, filed under your Frontline insurance policy. Your claim will be handled by Frontline’s claim team, who will contact you to discuss the claims process, initiate an investigation and arrange for an inspection of the loss, as needed. As required by your policy conditions, please take the necessary steps to protect covered property from further damage. Additionally, please photograph, document, and save all receipts for any emergency or temporary repairs. Please also retain for our inspection all damaged property. Please be advised that in order to adequately investigate your claim, Frontline is requesting you complete, sign, date, notarize and return to Frontline the enclosed Proof of Loss and Claim for Damaged Property forms within sixty (60) days from the date of this letter. Frontline may also require you and/or any others to submit to an Examination Under Oath to discuss the circumstances of the claim(s). These requests are made pursuant to the policy conditions outlined in Section I – Conditions … Your Duties After Loss, which we encourage you to carefully review in your Frontline policy of insurance. Thank you for insuring with Frontline. We appreciate your business and look forward to working together to solve this matter.” Thereafter, on October 6, 2024, Frontline’s Desk Adjuster, Jonathan Jennings, called the Insureds to take their Recorded Statement and discuss the claim, date of loss, and damages. The Insureds stated that Hurricane Helene flooded their house and caused interior and exterior damage. They claimed damages to doors, windows, pool, A/C, plumbing, fence, sheds, boat dock, furniture, and more. Following this Recorded Statement, Frontline sent the Insureds a Reservation of Rights letter on October 8, 2024, that stated as follows: “We received your claim on October 06, 2024, for Hurricane Helene for storm surge throughout your home with a reported date of loss of September 25, 2024. We discussed the flood damage on a recorded line where you stated the storm surge came in through the home up to three feet. We are issuing this reservation of rights letter to you because there is a question as to whether Frontline is obligated to indemnify you under the policy for the reported loss. Frontline will evaluate every claim which is reported to us and make payment for those losses which are covered under your policy number FPH3-000122746, with effective dates of October 23, 2023 to October 23, 2024; however, we must inform you that based on our preliminary evaluation, we have identified issues that may restrict, limit or exclude coverage, and we will be continuing our evaluation under a Reservation of Rights. The following policy exclusion may apply to the loss based on the facts provided to Frontline thus far: • It is questionable whether the loss was caused by flood, surface water, waves, including tidal wave and tsunami, tides, tidal water, storm surge, wave wash, overflow of any body of water, or spray from any of these, all whether or not driven by wind, including storm surge. Your policy, HOMEOWNERS 3 – SPECIAL FORM HO 00 03 05 11 as modified by SPECIAL PROVISIONS – FLORIDA FIM 00 23 11 21: SECTION I - PERILS INSURED AGAINST A. Coverage A - Dwelling And Coverage B - Other Structures Paragraph A.1 . in Form HO 00 03 is deleted and replaced by the following: 1. We insure for sudden and accidental direct physical loss to covered property described in Coverages A and B unless the loss is otherwise excluded or limited in this policy. However, loss does not include, and we will not pay for, any "diminution in value." 2. We do not insure, however, for loss: a. Excluded under Section I - Exclusions; SECTION I – EXCLUSIONS A. We do not insure for loss caused directly or indirectly by any of the following. Such loss is excluded regardless of any other cause or event contributing concurrently or in any sequence to the loss. These exclusions apply whether or not the loss event results in widespread damage or affects a substantial area. 3. Water This means: a. Flood, surface water, waves, including tidal wave and tsunami, tides, tidal water, storm surge, wave wash, overflow of any body of water, or spray from any of these, all whether or not driven by wind, including storm surge; b. Water which: (1) Backs up through sewers or drains; (2) Backs up or is otherwise discharged from a septic system or drain field, or related equipment or similar systems; or (3) Overflows or is otherwise discharged from: (a) A sump, sump pump, irrigation system, or related equipment; or (b) A roof drain, gutter, down spout, or similar fixtures, or equipment; c. Water below the surface of the ground including water which exerts pressure on or seeps, leaks or flows through a building, sidewalk, driveway, patio, foundation, swimming pool, or other structure: or d. Waterborne material, sewage, or any other substance carried or otherwise moved by any of the water referred to in paragraphs a. through c. of this Exclusion. This Exclusion 3., applies to, but is not limited to, escape, overflow or discharge for any reason, of water, waterborne mate rial, sewage, or any other substance, from a dam, levee, seawall, or any other boundary or containment system. This Exclusion 3. applies regardless of whether any of the above, in 3.a. through 3.d., is caused by an act of nature or is otherwise caused. However, direct loss by fire, explosion, or theft resulting from any of the above in paragraphs a. through d. of this Exclusion is covered. (This is exclusion A.3. in Form HO 00 03) *** The aforementioned policy provisions are only excerpts from your policy. All policy terms and conditions continue to apply to your claim. For the reasons set forth above, and for any other good and valid reasons which may become known during our evaluation of this claim, you are notified that any action taken by Frontline or its authorized representatives to evaluate the cause of loss, determine the amount of loss or damage, or attempt to adjust any claim arising out of the alleged loss shall not waive any of the terms or conditions of the policy of insurance described above. Frontline does not intend by this letter to waive any policy defenses in addition to those stated above, but specifically reserves its right to assert such additional policy defenses at any time. As outlined in our letter dated October 6, 2024, we request that you provide the following documents and information that are material to Frontline’s evaluation of your claim: • Photos/Videos: All photos and videos taken at the time of the loss and of the damage(s being claimed. • Emergency Services Documents: Submit all documents from (name of mitigation company) including but not limited to the signed contract, photos, dry logs, moisture readings, estimate and invoice. • Rebuild Estimates/Invoices: Submit all related estimates, invoices, contracts, work authorizations, photos and supporting documentation from all repair firms. (If we are aware of any contractors, include the following language “including but not limited to all related documents from (name of contractor(s)”). Also note that your signed Sworn Proof of Loss is required to be provided to us within 30 days after the reported date of loss. Please provide the requested information through the web portal at www.frontlineinsurance.com (Main Menu > Upload Claim Documents). Please note the following Duties After Loss in your policy, HOMEOWNERS 3 – SPECIAL FORM HO 00 03 05 11 as modified by SPECIAL PROVISIONS – FLORIDA FIM 00 23 11 21, which states in relevant part: *** SECTION I - CONDITIONS C. Duties After Loss is deleted and replaced by the following: C. Duties After Loss. An "assignment agreement does not change the obligations to perform the duties required under this Policy. In case of a loss to covered property, you must see that the following are done. These duties must be performed either by you, an "insured" seeking coverage, or a representative of either: 1. Your Duties After Loss a. Give immediate notice to us or our agent. Except for Reasonable Emergency Measures taken under Additional Coverage 2., there is no coverage for repairs that begin before the earlier of: (1) 72 hours after we are notified of the loss; (2) The time of loss inspection by us; or (3) The time of other approval by us. If you unreasonably deny us access to inspect the loss during the period in a. above, coverage for repairs beyond Reasonable Emergency Measures begins the earlier of when we are given access to inspect the loss or when we fail to appear at a scheduled loss inspection. b. To the degree reasonably possible, retain the damaged property and any photographs of the damaged property; and Allow us to inspect, subject to the paragraph above, all damaged property prior to its removal from the "residence premises" and make copies of the photographs. c. Notify the police in case of loss by theft. d. Notify the credit card or fund transfer card company in case of loss under Credit Card or Fund Transfer Card coverages. e. Protect the property from further damage. The following must be performed: (1) Take reasonable emergency measures that are necessary to protect the covered property from further damage, as provided under Additional Coverage 2. A reasonable emergency measure under 5.a. above 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. (2) Keep an accurate record of repair expenses, if to the degree reasonably possible, take pictures prior to repairs commencing. f. Cooperate with us in the investigation of a claim. This includes speaking to and sharing information with us or any person authorized to act on our behalf, and providing documents which can be reasonably obtained by you, to facilitate our ,investigation of the claim . You, any “insured" seeking coverage, or a representative of either of these: (1) Must cooperate with our investigation; (2) Must not act in any manner that prevents us or any person authorized to act on our behalf, from investigating the claim; and (3) May not act in any manner to obstruct our investigation. g. Prepare an inventory of damaged personal property showing the quantity, description, actual cash value and amount of loss. Attach all bills, receipts, and related documents that justify the figures in the inventory. h. As often as we reasonably require: (1) Show us the damaged property and the cause of loss and the condition it was in at the time of loss, if possible, except as to any repairs performed under SECTION I PROPERTY COVERAGES Additional Coverages, 2. Reasonable Emergency Measures; (2) Provide us with records and documents we request and permit us to make copies; (3) You, and any and all "insureds;" and Any member, officer, director, partner, or similar representative of the association, corporation, or other entity, if you are the association, corporation, or other entity, who is an "insured;"-must: (a) Submit to examination under oath and recorded statements at the location insured or other reasonable location designated by us, while not in the presence of each other or any other "insured” (b) Provide government issued photo identification. If you do not possess government issued photo identification, a signed sworn statement identifying who you are may be provided; and (c) Sign any transcript of the examinations under oath and recorded statements; At our request, the examinations will be conducted separately and not in the presence of any other persons except legal representation ; Such examinations and recorded statements must either be in person or utilize video and audio technology, or both, as determined by us; (4) Permit us to take samples of damaged and undamaged property for inspection, testing, and analysis; and (5) Any and all "insureds" must execute all authorizations for the release of information when requested by us, which we deem relevant to the investigation of your loss. (6) Allow us or any person authorized on our behalf: (a) Access to the "residence premises;" (b) To inspect the "residence premises" and to inspect, subject to 2. above, all damaged property prior to its removal from the "residence premises;" and (c) To require an "insured" or their representative, or both if reasonably possible, to be present at our 1inspection and to assist in identifying the damaged property during the inspection; (7) At our request, identify the person or persons with knowledge of how the loss occurred and the extent of damage; (8) For losses covered under Coverage A and B, allow us to reinspect, including but not limited to taking photographs and/or video of the property to confirm repairs invoiced by any "assignees(s)" or third parties were completed, or following a supplemental or re-opened claim. i. Submit to us, within 60 days after the loss, your signed, sworn proof of loss which sets forth, to the best of your knowledge and belief: (1) The description of the loss, including the date and time of the loss, the cause of loss, a description of how the loss occurred, when the loss was discovered, and who discovered the loss; (2) The names of all persons who resided at the insured location at the time of the loss; (3) The interest of all "insureds," "assignees" if any, and all others in the property, involved and all liens on the property; (4) Other insurance which may cover the loss; (5) Changes in title or occupancy of the property during the term of the policy· (6) Specifications of damage to the dwelling and other structures, including; (a) Detailed descriptions of the damage to the property; (b) Repair estimates which show the extent of damage to each item or property; (c) Estimated amount(s) to repair or replace each item of property; and (d) Amount(s) of payment made for any temporary or permanent repairs. Photographs and other supporting documentation that exists should be included to the extent it is reasonable and practical to obtain; (7) The inventory of damaged personal property described in C.7. above; (8) Receipts for additional living expenses incurred and records that support the fair rental value; and (9) Evidence or affidav.it that support a claim under the Credit Card, Fund Transfer Card, Forgery and Counterfeit Money coverage, stating the amount and cause of loss. j. Produce any updates to the documents and information described above, including revised descriptions of loss, scope of loss, estimates, or other supporting information: (1) As this information becomes available, and if additional loss or damage is discovered or incurred; and (2) If you are provided with new estimates or invoices regarding the losses submitted or not submitted in the proof of 1loss. The duties above apply regardless of whether you, an "insured" seeking coverage, or a representative of either retains or is assisted by a party who provides legal advice, insurance advice or expert claim advice, regarding an insurance claim under this Policy. The aforementioned policy provisions are only excerpts from your policy. All policy terms and conditions continue to apply to your claim. Should you have any questions or concerns, please feel free to contact me Monday through Friday between the hours of 7:00 a.m. and 7:00 p.m. I can be reached at 972-522-4885. If I am not available when you call, please leave me a detailed message, and I will return your call as soon as possible.” Thereafter, Frontline retained the services of a licensed Field Adjuster to inspect the property. Thus, on October 12, 2024, Jack Chiniski of Veteran Catastrophe Services called the Insureds and scheduled an inspection for October 19, 2024. However, on October 16, 2024, Mr. Chiniski received a text from the Insureds’ counsel that the date would not work. Mr. Chiniski offered four dates for the inspection, but because the Insureds’ counsel denied all four dates, on October 21, 2024, Frontline assigned the claim to a different Field Adjuster with Veteran Catastrophe Services, Andrew Kopicz. On October 22, 2024, Mr. Kopicz call the Insureds’ counsel to schedule an inspection. He followed up with emails on October 24, 2024, and October 28, 2024, to which there was no response. On October 28, 2024, Mr. Jennings called the Insureds and asked them to give their counsel his information and for their counsel to submit a Letter of Representation. On October 28, 2024, Field Adjuster Justin Glass with Veteran Catastrophe Services took over attempting to schedule an inspection with the Insureds and their counsel. On October 28, 2024, he sent an email to the Insureds’ counsel requesting to schedule the inspection. He sent follow up emails on November 1, 2024 and November 7, 2024. Finally, on November 11, 2024, the Insureds’ counsel submitted their Letter of Representation and scheduled the Field Adjuster inspection for November 12, 2024. After receipt of the Insureds’ counsel’s letter of representation stating that Insurance Litigation Group would be representing the Insureds, on November 12, 2024, Frontline sent an acknowledgment letter that stated: “This serves to acknowledge our receipt of your Letter of Representation between our policyholder Jon D Ariza, Andrea Ariza and Insurance Litigation Group. These documents were submitted and addressed to Frontline Insurance and received on November 29, 2024. As we continue to evaluate this claim, we look forward to working with you to discuss the facts and circumstances to determine if the policy covers the loss. Should you have any questions or concerns please feel free to contact me Monday through Friday between the hours of 8:00 a.m. and 7:00 p.m. CST. I can be reached at 972-522-4104. If I am not available when you call, please leave me a detailed message, and I will return your call as soon as possible.” On November 12, 2024, Justin Glass of Veteran Catastrophe Services inspected the property in the presence of the Insureds and their counsel’s representative, Eli Rizvi. During the inspection, Mr. Glass took photographs of the boat deck, fence, exterior, interior, and roof of the home. He subsequently prepared a report summarizing his findings and sent the report and photographs to Frontline to review. Following receipt and review of the Field Adjuster’s report and photographs, on November 14, 2024, Frontline sent the Insureds and their counsel a Reservation of Rights letter that stated: “We received your claim on October 06, 2024, for Hurricane Helene for storm surge throughout your home with a reported date of loss of September 25, 2024. We discussed the flood damage on a recorded line where you stated the storm surge came in through the home up to three feet. We are issuing this reservation of rights letter to you because there is a question as to whether Frontline is obligated to indemnify you under the policy for the reported loss. Frontline will evaluate every claim which is reported to us and make payment for those losses which are covered under your policy number FPH3-000122746, with effective dates of October 23, 2023 to October 23, 2024; however, we must inform you that based on our preliminary evaluation, we have identified issues that may restrict, limit or exclude coverage, and we will be continuing our evaluation under a Reservation of Rights. Failure to comply with the following “Duties After Loss” may have jeopardized, or may result in prejudice to, Frontline’s evaluation of this claim: • It is questionable whether you protected the insured property from further damage. • It is questionable whether you have kept an accurate record of the repair expenses. • It is questionable whether you have cooperated with us in our investigation of your claim. In addition, the following policy exclusions may apply to the loss based on the facts provided to Frontline thus far: • It is questionable whether the loss was caused by flood, surface water, waves, including tidal wave and tsunami, tides, tidal water, overflow of any body of water, or spray from any of these, all whether or not driven by wind, including storm surge. Your policy, HOMEOWNERS 3 – SPECIAL FORM HO 00 03 05 11 as modified by SPECIAL PROVISIONS – FLORIDA FIM 00 23 11 21, states in relevant part: SECTION I - PERILS INSURED AGAINST A. Coverage A - Dwelling And Coverage B - Other Structures Paragraph A.1. in Form HO 00 03 is deleted and replaced by the following: 1. We insure for sudden and accidental direct physical loss to covered property described in Coverages A and B unless the loss is otherwise excluded or limited in this policy. However, loss does not include, and we will not pay for, any "diminution in value." 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. … SECTION I – EXCLUSIONS A. We do not insure for loss caused directly or indirectly by any of the following. Such loss is excluded regardless of any other cause or event contributing concurrently or in any sequence to the loss. These exclusions apply whether or not the loss event results in widespread damage or affects a substantial area. 3. Water This means: a. Flood, surface water, waves, including tidal wave and tsunami, tides, tidal water, storm surge, wave wash, overflow of any body of water, or spray from any of these, all whether or not driven by wind, including storm surge; b. Water which: (1) Backs up through sewers or drains; (2) Backs up or is otherwise discharged from a septic system or drain field, or related equipment or similar systems; or c. Water below the surface of the ground including water which exerts pressure on or seeps, leaks or flows through a building, sidewalk, driveway, patio, foundation, swimming pool, or other structure: or d. Waterborne material, sewage, or any other substance carried or otherwise moved by any of the water referred to in paragraphs a. through c. of this Exclusion. This Exclusion 3., applies to, but is not limited to, escape, overflow or discharge for any reason, of water, waterborne material, sewage, or any other substance, from a dam, levee, seawall, or any other boundary or containment system. This Exclusion 3. applies regardless of whether any of the above, in 3.a. through 3.d., is caused by an act of nature or is otherwise caused. However, direct loss by fire, explosion, or theft resulting from any of the above, in A.3.a. through A.3.d., is covered. For the reasons set forth above, and for any other good and valid reasons which may become known during our evaluation of this claim, you are notified that any action taken by Frontline or its authorized representatives to evaluate the cause of loss, determine the amount of loss or damage, or attempt to adjust any claim arising out of the alleged loss shall not waive any of the terms or conditions of the policy of insurance described above. Frontline does not intend by this letter to waive any policy defenses in addition to those stated above, but specifically reserves its right to assert such additional policy defenses at any time. As outlined in our letter dated November 14, 2024, we request that you provide the following documents and information that are material to Frontline’s evaluation of your claim: • Cause of Loss Documentation: Retain and provide evidence of the cause of loss and provide documentation as to the repair of the source of loss. • Photos/Videos: All photos and videos taken at the time of the loss and of the damage(s being claimed. • Inspection: Our field adjuster has scheduled an inspection of the insured property. We asked that you attend the inspection. • Emergency Services Documents: Submit all documents from (name of mitigation company) including but not limited to the signed contract, photos, dry logs, moisture readings, estimate and invoice. • Rebuild Estimates/Invoices: Submit all related estimates, invoices, contracts, work authorizations, photos and supporting documentation from all repair firms. Also note that your signed Sworn Proof of Loss is required to be provided to us within 60 days after the reported date of loss. Please provide the requested information through the web portal at www.frontlineinsurance.com (Main Menu > Upload Claim Documents). Please note the following Duties After Loss in your policy, HOMEOWNERS 3 – SPECIAL FORM HO 00 03 05 11 as modified by SPECIAL PROVISIONS – FLORIDA FIM 00 23 11 21, which states in relevant part: SECTION I - CONDITIONS C. Duties After Loss is deleted and replaced by the following: C. Duties After Loss. An "assignment agreement does not change the obligations to perform the duties required under this Policy. In case of a loss to covered property, you must see that the following are done. These duties must be performed either by you, an "insured" seeking coverage, or a representative of either: 1. Your Duties After Loss a. Give immediate notice to us or our agent. Except for Reasonable Emergency Measures taken under Additional Coverage 2., there is no coverage for repairs that begin before the earlier of: (1) 72 hours after we are notified of the loss; (2) The time of loss inspection by us; or (3) The time of other approval by us. If you unreasonably deny us access to inspect the loss during the period in a. above, coverage for repairs beyond Reasonable Emergency Measures begins the earlier of when we are given access to inspect the loss or when we fail to appear at a scheduled loss inspection. b. To the degree reasonably possible, retain the damaged property and any photographs of the damaged property; and Allow us to inspect, subject to the paragraph above, all damaged property prior to its removal from the "residence premises" and make copies of the photographs. c. Notify the police in case of loss by theft. d. Notify the credit card or fund transfer card company in case of loss under Credit Card or Fund Transfer Card coverages. e. Protect the property from further damage. The following must be performed: (1) Take reasonable emergency measures that are necessary to protect the covered property from further damage, as provided under Additional Coverage 2. A reasonable emergency measure under 5.a. above 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. (2) Keep an accurate record of repair expenses, if to the degree reasonably possible, take pictures prior to repairs commencing. f. Cooperate with us in the investigation of a claim. This includes speaking to and sharing information with us or any person authorized to act on our behalf, and providing documents which can be reasonably obtained by you, to facilitate our, investigation of the claim. You, any “insured" seeking coverage, or a representative of either of these: (1) Must cooperate with our investigation; (2) Must not act in any manner that prevents us or any person authorized to act on our behalf, from investigating the claim; and (3) May not act in any manner to obstruct our investigation. g. Prepare an inventory of damaged personal property showing the quantity, description, actual cash value and amount of loss. Attach all bills, receipts, and related documents that justify the figures in the inventory. h. As often as we reasonably require: (1) Show us the damaged property and the cause of loss and the condition it was in at the time of loss, if possible, except as to any repairs performed under SECTION I PROPERTY COVERAGES Additional Coverages, 2. Reasonable Emergency Measures; (2) Provide us with records and documents we request and permit us to make copies; (3) You, and any and all "insureds;" and Any member, officer, director, partner, or similar representative of the association, corporation, or other entity, if you are the association, corporation, or other entity, who is an "insured;"-must: (a) Submit to examination under oath and recorded statements at the location insured or other reasonable location designated by us, while not in the presence of each other or any other "insured” (b) Provide government issued photo identification. If you do not possess government issued photo identification, a signed sworn statement identifying who you are may be provided; and (c) Sign any transcript of the examinations under oath and recorded statements; At our request, the examinations will be conducted separately and not in the presence of any other persons except legal representation ; Such examinations and recorded statements must either be in person or utilize video and audio technology, or both, as determined by us; (4) Permit us to take samples of damaged and undamaged property for inspection, testing, and analysis; and (5) Any and all "insureds" must execute all authorizations for the release of information when requested by us, which we deem relevant to the investigation of your loss. (6) Allow us or any person authorized on our behalf: (a) Access to the "residence premises;" (b) To inspect the "residence premises" and to inspect, subject to 2. above, all damaged property prior to its removal from the "residence premises;" and (c) To require an "insured" or their representative, or both if reasonably possible, to be present at our 1inspection and to assist in identifying the damaged property during the inspection; (7) At our request, identify the person or persons with knowledge of how the loss occurred and the extent of damage; (8) For :1osses covered under Coverage A and B, allow us to reinspect, including but not limited to taking photographs and/or video of the property to confirm repairs invoiced by any "assignees(s)" or third parties were completed, or following a supplemental or re-opened claim. i. Submit to us, within 60 days after the loss, your signed, sworn proof of loss which sets forth, to the best of your knowledge and belief: (1) The description of the loss, including the date and time of the loss, the cause of loss, a description of how the loss occurred, when the loss was discovered, and who discovered the loss; (2) The names of all persons who resided at the insured location at the time of the loss; (3) The interest of all "insureds," "assignees" if any, and all others in the property involved and all liens on the property; (4) Other insurance which may cover the loss; (5) Changes in title or occupancy of the property during the term of the policy· (6) Specifications of damage to the dwelling and other structures, including; (a) Detailed descriptions of the damage to the property; (b) Repair estimates which show the extent of damage to each item or property; (c) Estimated amount(s) to repair or replace each item of property; and (d) Amount(s) of payment made for any temporary or permanent repairs. Photographs and other supporting documentation that exists should be included to the extent it is reasonable and practical to obtain; (7) The inventory of damaged personal property described in C.7. above; (8) Receipts for additional living expenses incurred and records that support the fair rental value; and (9) Evidence or affidav.it that support a claim under the Credit Card, Fund Transfer Card, Forgery and Counterfeit Money coverage, stating the amount and cause of loss. j. Produce any updates to the documents and information described above, including revised descriptions of loss, scope of loss, estimates, or other supporting information: (1) As this information becomes available, and if additional loss or damage is discovered or incurred; and (2) If you are provided with new estimates or invoices regarding the losses submitted or not submitted in the proof of 1loss. The duties above apply regardless of whether you, an "insured" seeking coverage, or a representative of either retains or is assisted by a party who provides legal advice, insurance advice or expert claim advice, regarding an insurance claim under this Policy. The aforementioned policy provisions are only excerpts from your policy. All policy terms and conditions continue to apply to your claim. Should you have any questions or concerns, please feel free to contact me Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m. I can be reached at 972-522-4104. If I am not available when you call, please leave me a detailed message, and I will return your call as soon as possible.” Following receipt of no additional documents from the Insureds or their counsel, on November 19, 2024, Frontline sent a coverage decision letter that stated: “This letter follows my voice mail attempt on November 19, 2024, where I advised the results of our evaluation and the policy provisions which apply to your claim. Frontline evaluated the claim you reported on October 06, 2024, for Hurricane Helene storm surge throughout your home. As part of that evaluation, Frontline inspected the insured location November 14, 2024. The inspection revealed damages caused by wind to your roof and damages to fence and interior damages caused by flood and/or surge. Based upon Frontline’s current evaluation, as well as the information you have provided to date, enclosed is the estimate of the covered damage and a Statement of Loss providing a breakdown of your claim. As you will note, the loss of $776.2 is less than the policy deductible of $ 6,580.00. As a result, we are not able to extend payment at this time. Once you have selected a contractor to complete the covered repairs to your home, if the estimate for repairs exceeds the enclosed estimate and/or if additional damages are discovered you must immediately inform us by producing any updates to documents including revised descriptions of the loss, scope of loss, estimates, or other supporting documentation and allow an inspection before repairs are made. Failure to do so may jeopardize your ability to recover for the full amount of the additional damages. Frontline reserves the right to inspect the property and/or requires additional information prior to the release of any funds. Respectfully, we are unable to pay for the repair to your fence, contents, and interior damages as your Homeowners Policy excludes coverage for flood, storm surge. Your policy, HOMEOWNERS 3 – SPECIAL FORM HO 00 03 05 11 as modified by SPECIAL PROVISIONS – FLORIDA FIM 00 23 11 21, states in relevant part: SECTION I - PERILS INSURED AGAINST A. Coverage A - Dwelling And Coverage B - Other Structures Paragraph A.1. in Form HO 00 03 is deleted and replaced by the following: 1. We insure for sudden and accidental direct physical loss to covered property described in Coverages A and B unless the loss is otherwise excluded or limited in this policy. However, loss does not include, and we will not pay for, any "diminution in value." 2. We do not insure, however, for loss: a. Excluded under Section I - Exclusions; SECTION I – EXCLUSIONS A. We do not insure for loss caused directly or indirectly by any of the following. Such loss is excluded regardless of any other cause or event contributing concurrently or in any sequence to the loss. These exclusions apply whether or not the loss event :results in widespread damage or affects a substantial area. 3. Water is deleted and replaced by the following: 3. Water This means: a. Flood, surface water, waves, including tidal wave and tsunami, tides, tidal water, storm surge, wave wash, overflow of any body of water, or spray from any of these, all whether or not driven by wind, including storm surge; b. Water which: (1) Backs up through sewers or drains; (2) Backs up or is otherwise discharged from a septic system or drain field, or related equipment or similar systems; or (3) Overflows or is otherwise discharged from: (a) A sump, sump pump, irrigation system, or related equipment; or (b) A roof drain, gutter, down spout, or similar fixtures, or equipment; c. Water below the surface of the ground including water which exerts pressure on or seeps, leaks or flows through a building, sidewalk, driveway, patio, foundation, swimming pool, or other structure: or d. Waterborne material, sewage, or any other substance carried or otherwise moved by any of the water referred to in paragraphs a. through c. of this Exclusion. This Exclusion 3., applies to, but is not limited to, escape, overflow or discharge for any reason, of water, waterborne mate rial, sewage, or any other substance, from a dam, levee, seawall, or any other boundary or containment system. This Exclusion 3. applies regardless of whether any of the above, in 3.a. through 3.d., is caused by an act of nature or is otherwise caused. However, direct loss by fire, explosion, or theft resulting from any of the above in paragraphs a. through d. of this Exclusion is covered. (This is exclusion A.3. in Form HO 00 03) The aforementioned policy provisions are only excerpts from your policy. All policy terms and conditions continue to apply to your claim. Our denial of your claim for fence, contents, and interior damages does not relieve you of any duty to maintain your property, and you should move forward with any repairs necessary to protect the property from further damage. Please note the following Duties After Loss in your policy, HOMEOWNERS 3 – SPECIAL FORM HO 00 03 05 11 as modified by SPECIAL PROVISIONS – FLORIDA FIM 00 23 11 21, which states in relevant part: SECTION I - CONDITIONS C. Duties After Loss is deleted and replaced by the following: C. Duties After Loss. An "assignment agreement” does not change the obligations to perform the duties required under this Policy. In case of a loss to covered property, you must see that the following are done. These duties must be performed either by you, an "insured" seeking coverage, or a representative of either: 1. Your Duties After Loss b. To the degree reasonably possible, retain the damaged property and any photographs of the damaged property; and Allow us to inspect, subject to the paragraph above, all damaged property prior to its removal from the "residence premises" and make copies of the photographs. e. Protect the property from further damage. The following must be performed: (2) Keep an accurate record of repair expenses, if to the degree reasonably possible, take pictures prior to repairs commencing. f. Cooperate with us in the investigation of a claim. This includes speaking to and sharing information with us or any person authorized to act on our behalf, and providing documents which can be reasonably obtained by you, to facilitate our, investigation of the claim. You, any “insured" seeking coverage, or a representative of either of these: (1) Must cooperate with our investigation; (2) Must not act in any manner that prevents us or any person authorized to act on our behalf, from investigating the claim; and (3) May not act in any manner to obstruct our investigation. h. As often as we reasonably require: (1) Show us the damaged property and the cause of loss and the condition it was in at the time of loss, if possible, except as to any repairs performed under SECTION I PROPERTY COVERAGES Additional Coverages, 2. Reasonable Emergency Measures; (2) Provide us with records and documents we request and permit us to make copies; (8) For 1osses covered under Coverage A and B, allow us to reinspect, including but not limited to taking photographs and/or video of t:he property to confirm repairs invoiced by any "assignees(s)" or third parties were completed, or following a supplemental or re-opened claim. j. Produce any updates to the documents and information described above, including revised descriptions of loss, scope of loss, estimates, or other supporting information: (1) As this information becomes available, and if additional loss or damage is discovered or incurred; and (2) If you are provided with new estimates or invoices regarding the losses submitted or not submitted in the proof of loss. The duties above apply regardless of whether you, an "insured" seeking coverage, or a representative of either retains or is assisted by a party who provides legal advice, insurance advice or expert claim advice, regarding an insurance claim under this Policy. If we fail to agree on the settlement of your loss, either you or we may demand a mediation in accordance with the rules established by the Florida Department of Financial Services and as stated in your policy. Your policy states in relevant part: SECTION I - CONDITIONS In Forms HO 00 03, HO 00 04 and HO 00 06: F. Appraisal is deleted and replaced by the following: F. Mediation or Appraisal. If you and we fail to agree on the settlement regarding the loss, prior to filing suit, you must notify us of your disagreement in writing so that either may: 1. Demand a mediation of the loss in accordance with the rules established by the Florida Department of Financial Services. The loss must be $500 or more, prior to the application of the deductible; or there must be a difference of $500 or more between the loss settlement amount we offer and the loss settlement amount that you request. The settlement in the course of the mediation is binding only if both parties agree, in writing, on a settlement and you have not rescinded the settlement within 3 business days after reaching settlement. You may not rescind the settlement after cashing or depositing the settlement check or draft we provided to you. We will pay the cost of conducting any mediation conference except When you fail to appear at a conference. That conference will then be rescheduled upon your payment of the mediator's fee for that rescheduled conference. However. if we fail to appear at a mediation conference, we will pay the actual cash expenses you incur in attending the conference and also pay the mediator's fee for that rescheduled conference. If, however. we demanded the mediation and either party rejects the mediation results, you are not required to submit to. or participate in, any appraisal of the loss as a precondition to action against us for failure to pay the loss. … The aforementioned policy provisions are only excerpts from your policy. All policy terms and conditions continue to apply to your claim. Frontline does not intend by this letter to waive any policy defenses in addition to those stated above, but specifically reserves its right to assert additional policy defenses at any time. WE ARE CONTINUING TO EVALUATE YOUR CLAIM INVOLVING YOUR INSURED PROPERTY AND MAY ISSUE ADDITIONAL PAYMENTS. IF YOU HAVE QUESTIONS, CONCERNS, OR ADDITIONAL INFORMATION REGARDING YOUR CLAIM, WE ENCOURAGE YOU TO CONTACT US. Should you have any questions or concerns or have any additional information you would like to be considered, please feel free to contact me Monday through Friday between the hours of 8:00 a.m. and 7.00 p.m. CST I can be reached at 972-522-4104. If I am not available when you call, please leave me a detailed message, and I will return your call as soon as possible.” Nevertheless, in a good faith effort to continue to adjust the claim following its original coverage determination, on November 19, 2024, Frontline sent the Insureds’ counsel an email that stated: “We are still currently reviewing and evaluating the subject claim. At this time, we are requesting additional information in order to assist in our review. Please see the attached Reservation of Rights letter with the additional information being requested. Attached are our undisputed damage of loss and as well as below deductible letter, statement of loss, and estimate.” Frontline then sent another email on December 5, 2024 that stated: “I have been reassigned to your claim and will be serving as the desk adjuster. Below you will find my direct contact information. Attached are our undisputed damage of loss and as well as below deductible letter, statement of loss, and estimate. We are still currently reviewing and evaluating the subject claim. At this time, we are requesting additional information in order to assist in our review. Please see the attached Reservation of Rights letter with the additional information being requested. These will also be sent out certified to your office. A certified copy of the policy is also mailed to your office. Requested information or other items can be submitted through the web portal at www.frontlineinsurance.com ( Main Menu > File A Claim > Upload documents to an existing claim).” As there was no response provided, Frontline then sent another email on December 10, 2024 that stated: “We have sent you our Reservation of Rights with a request for information via mail and email. We are requesting your submission of the following: 1. Disputing Estimate and supporting documents 2. Completed Sworn Proof of Loss 3. Invoices/Receipts and photos (if available) of completed repairs for damages claimed. This additional information is needed to properly evaluate your claim. If you have any of the above referenced material, please submit the documentation you have through the web portal at www.frontlineinsurance.com ( Main Menu > Upload Claim Documents). Once you have uploaded the requested information and or any additional information to the web portal at www.frontlineinsurance.com, the claim will reopen for us to resume our handling and investigation of your claim.” Seemingly in response to same, on January 8, 2025, the Insureds, via their counsel, invoked appraisal. Thus, on January 14, 2025, Frontline responded with a letter that stated: “On January 8, 2025, your attorney, Insurance Litigation Group, submitted a request to invoke the appraisal provision of the policy. This letter is to advise you that your attorney’s request was premature and not in compliance with the policy. Please be reminded your Homeowners insurance policy assigns you specific duties following a loss, including the duty to protect the property from further damage, keep an accurate record of repairs, and produce updates including revised description of loss, estimates or other supporting information. We direct you to your HO 00 03 05 11 HOMEOWNERS 3 – SPECIAL FORM, as amended by the FIM 00 23 11 21 SPECIAL PROVISIONS – FLORIDA. Please refer to SECTION 1 CONDITIONS for more details, but note the following language that may apply: SECTION I - CONDITIONS C. Duties After Loss is deleted and replaced by the following: C. Duties After Loss. An "assignment agreement does not change the obligations to perform the duties required under this Policy. In case of a loss to covered property, you must see that the following are done. These duties must be performed either by you, an "insured" seeking coverage, or a representative of either: 1. Your Duties After Loss b. To the degree reasonably possible, retain the damaged property and any photographs of the damaged property; and Allow us to inspect, subject to the paragraph above, all damaged property prior to its removal from the "residence premises" and make copies of the photographs. … e. Protect the property from further damage. The following must be performed: … (2) Keep an accurate record of repair expenses, if to the degree reasonably possible, take pictures prior to repairs commencing. f. Cooperate with us in the investigation of a claim. This includes speaking to and sharing information with us or any person authorized to act on our behalf, and providing documents which can be reasonably obtained by you, to facilitate our, investigation of the claim. You, any “insured" seeking coverage, or a representative of either of these: (1) Must cooperate with our investigation; (2) Must not act in any manner that prevents us or any person authorized to act on our behalf, from investigating the claim; and (3) May not act in any manner to obstruct our investigation. … h. As often as we reasonably require: (1) Show us the damaged property and the cause of loss and the condition it was in at the time of loss, if possible, except as to any repairs performed under SECTION I PROPERTY COVERAGES Additional Coverages, 2. Reasonable Emergency Measures; (2) Provide us with records and documents we request and permit us to make copies; … (8) For losses covered under Coverage A and B, allow us to reinspect, including but not limited to taking photographs and/or video of the property to confirm repairs invoiced by any "assignees(s)" or third parties were completed, or following a supplemental or re-opened claim. … i. Submit to us, within 60 days after the loss, your signed, sworn proof of loss which sets forth, to the best of your knowledge and belief: (1) The description of the loss, including the date and time of the loss, the cause of loss, a description of how the loss occurred, when the loss was discovered, and who discovered the loss; (2) The names of all persons who resided at the insured location at the time of the loss; (3) The interest of all "insureds," "assignees" if any, and all others in the property, involved and all liens on the property; (4) Other insurance which may cover the loss; (5) Changes in title or occupancy of the property during the term of the policy· (6) Specifications of damage to the dwelling and other structures, including; (a) Detailed descriptions of the damage to the property; (b) Repair estimates which show the extent of damage to each item or property; (c) Estimated amount(s) to repair or replace each item of property; and (d) Amount(s) of payment made for any temporary or permanent repairs. Photographs and other supporting documentation that exists should be included to the extent it is reasonable and practical to obtain; (7) The inventory of damaged personal property described in C.7. above; (8) Receipts for additional living expenses incurred and records that support the fair rental value; and j. Produce any updates to the documents and information described above, including revised descriptions of loss, scope of loss, estimates, or other supporting information: (1) As this information becomes available, and if additional loss or damage is discovered or incurred; and (2) If you are provided with new estimates or invoices regarding the losses submitted or not submitted in the proof of 1loss. The duties above apply regardless of whether you, an "insured" seeking coverage, or a representative of either retains or is assisted by a party who provides legal advice, insurance advice or expert claim advice, regarding an insurance claim under this Policy. … Please be aware your policy provides methods of alternative dispute resolution including mediation and appraisal, which require the parties to review the dispute for a minimum of 10 days before invoking. Accordingly, we direct you to your HO 00 03 05 11 HOMEOWNERS 3 SPECIAL FORM as amended by the FIM 00 23 11 21 SPECIAL PROVISIONS - FLORIDA. Please refer to SECTION 1 CONDITIONS for more details, but note the following language that may apply: In Forms HO 00 03, HO 00 04 and HO 00 06: F. Appraisal is deleted and replaced by the following: F. Mediation or Appraisal. If you and we fail to agree on the settlement regarding the loss, prior to filing suit, you must notify us of your disagreement in writing so that either may: 2. Request an appraisal of the loss if we fail to agree on the amount of the loss. a. A request for appraisal must be in writing and be signed by all Named "Insureds" shown in the Declarations. You must comply with SECTION I - CONDITIONS, C. Duties After Loss before making a request for appraisal. At least 10 days before requesting appraisal, the party seeking appraisal must provide the other party with a written estimate of the amount of any dispute that results from the covered cause of loss. The estimate shall include a description of each item of damaged property in dispute as a result of the covered loss, along with the extent of damage and the estimated amount to repair or replace the item. b. In this event, each party will choose a competent appraiser within 20 days after receiving a written request from the other. To qualify as a competent appraiser, neither the appraiser nor the company that employs the appraiser is entitled to receive a fee that is dependent on the amount of the appraisal award. However, the payment of an hourly or flat fee shall not render an appraiser incompetent under this provision. c. The two appraisers will choose a competent, disinterested umpire. If they cannot agree upon an umpire within 15 days, you or we may request that the choice be made by a judge of a court of record in the state where the "residence premises” is located. d. The appraisers will separately set the amount of the loss. If the appraisers submit a written report of an agreement to us, the amount agreed upon will be the amount of the loss. If they fail to agree, they will submit their differences to the umpire. A decision agreed to by any two will set the amount of the loss. In all instances, the written report of agreement will be in writing and shall include the following: (1) A detailed list, including the amount to repair or replace, of each specific item included in the award from the appraisal findings; (2) The agreed amount of each item, its replacement cost value and corresponding actual cash value; and (3) The statement of "This award is made subject to the terms and conditions of the policy." Each party will: (a) Pay its own appraiser, including their costs associated with producing the estimate in 2.a. of this provision, above; and (b) Bear the other expenses of the appraisal and umpire equally. e. You, we, the appraisers, and the umpire shall be given reasonable and timely access to inspect the property, in accordance with the terms of the policy. f. You" and “we” do not waive any rights by demanding or submitting to an appraisal and retain all contractual rights to determine if coverage applies to each item in dispute. g. Appraisal is only available to determine the amount of the loss of each item in dispute. The appraisers and the umpire have no authority to decide: (1) Any other questions of fact; (2) Questions of law; (3) Questions of coverage; (4) Other contractual issues; or to conduct appraisal on a class-wide-basis. The following conditions are added to SECTION I - CONDITIONS of your policy: T. Notice of Claim If your policy provides hurricane or windstorm coverage, then a claim, supplemental claim or reopened claim for loss or damage caused by hurricane or other windstorm must be given to us in accordance with the terms of this policy and as follows: a. A claim or reopened claim must be reported within two years after the hurricane first made landfall or a windstorm other than a Hurricane caused the damage, or, b. A supplemental claim must be reported within three years after the hurricane first made landfall or a windstorm other than a Hurricane caused the damage, and, c. Within any other applicable statutorily required timeframe; Whichever is less. This condition concerning time for submission of claim does not affect any limitation for legal action against us as provided in this policy under the Suit Against Us Condition including any amendment to that condition The aforementioned policy provisions are only excerpts from your policy. All policy terms and conditions continue to apply to your claim. WE ARE CONTINUING TO EVALUATE YOUR CLAIM INVOLVING YOUR INSURED PROPERTY AND MAY ISSUE ADDITIONAL PAYMENTS. IF YOU HAVE QUESTIONS, CONCERNS, OR ADDITIONAL INFORMATION REGARDING YOUR CLAIM, WE ENCOURAGE YOU TO CONTACT US. As noted above, the request to invoke the appraisal provision of the policy was premature and deficient, specifically: • The request was sent prior to receiving written notification of a dispute with an estimate of the disputed damages – we must be allowed at least 10 days to review the disputed amount before appraisal can be requested. • The request did not include your sworn proof of loss. For the reasons set forth herein, and for any other good and valid reasons which may become known during our investigation of this claim, you are hereby notified that any action taken by Frontline or its authorized representatives to investigate the cause of loss, determine the amount of loss or damage, or attempt to adjust any claim arising out of the alleged loss shall not waive any of the terms or conditions of the policy of insurance described above. Frontline does not intend, by this letter, to waive any policy defense in addition to those stated above, but specifically reserves its right to assert such additional policy defenses at any time. In the interim should you have any questions, please feel free to contact me at 972-522-4104.” Following this letter, on January 14, 2025, Frontline received an email from the Insureds’ counsel following up on their request for appraisal, to which Frontline responded that the Insureds still had not submitted their Sworn Proof of Loss and referred to the aforementioned letter. Thus, the Insureds submitted their Sworn Proof of Loss, and on January 17, 2025, Frontline sent an acknowledgment letter that stated: “We acknowledge receipt of your Sworn Statement in Proof of Loss (“Proof of Loss”) on December 23, 2024. We can neither accept nor reject your Proof of Loss as our evaluation of your claim is ongoing. Please submit the requested information through the web portal at www.frontlineinsurance.com (Main Menu > Upload Claim Documents). Should you have any questions or concerns, please feel free to contact me Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m. I can be reached at 972-522-4104. If I am not available when you call, please leave me a detailed message, and I will return your call as soon as possible.” On January 28, 2025, Frontline sent an appraisal confirmation letter to the Insureds and their counsel that stated: “This letter is to confirm receipt of the appraiser’s contact information submitted by Insurance Litigation Group on January 10, 2025, appointing Eli Brass. The appraisers will choose an umpire within 15 days. If they cannot agree upon an umpire within 15 days, we may request that the choice be made by a judge. Each party will pay its own appraiser, including their costs associated with producing the appraisal estimate; and bear the other expenses of the appraisal and umpire equally. The appraisers, and the umpire shall be given reasonable and timely access to inspect the property, in accordance with the terms of the policy. All parties have agreed to participate in the Appraisal process with regard to eligible aspects of the referenced claim and applicable provisions of your homeowner’s insurance policy. While Frontline agrees to participate in Appraisal in order to set the amount of loss, be reminded, the appraisal panel has no authority to decide questions of fact, law, coverage, or other contractual issues. Frontline herein selects the following appraiser: Greg Loftus 904-318-0013 Gloftus3@gmail.com The report of the agreement will be in writing and shall include the following: • A detailed list, including the amount to repair or replace, of each specific item included in the award from the appraisal findings; • The agreed amount of each item, its replacement cost value and corresponding actual cash value; and • The statement of “This award is made subject to the terms and conditions of the policy.” The final award form, which will be provided by Frontline, will be subject to reduction according to the terms and conditions of the policy, including, but not limited to, applicable policy sublimits, all loss settlement provisions, all applicable deductibles, and prior payments. Additionally, the award is further subject to revision according to coverage under the policy. The appraisal panel has no authority to decide questions of fact, law, coverage, or other contractual issues. Further, “You” and “We” do not waive any rights by demanding or submitting to an appraisal and retain all contractual rights to determine if coverage applies to each item in dispute. Please review your policy, the HOMEOWNERS 3 SPECIAL FORM HO 00 03 05 11, as amended by the SPECIAL PROVISIONS FIM 00 23 11 21, which provides in part: SECTION 1-CONDITIONS In Forms HO 00 03, HO 00 04 and HO 00 06: F. Appraisal is deleted and replaced by the following: F. Mediation or Appraisal. If you and we fail to agree on the settlement regarding the loss, prior to filing suit, you must notify us of your disagreement in writing so that either may: 2. Request an appraisal of the loss if we fail to agree on the amount of the loss. a. A request for appraisal must be in writing and be signed by all Named "Insureds" shown in the Declarations. You must comply with SECTION I - CONDITIONS, C. Duties After Loss before making a request for appraisal. At least 10 days before requesting appraisal, the party seeking appraisal must provide the other party with a written estimate of the amount of any dispute that results from the covered cause of loss. The estimate shall include a description of each item of damaged property in dispute as a result of the covered loss, along with the extent of damage and the estimated amount to repair or replace the item. b. In this event, each party will choose a competent appraiser within 20 days after receiving a written request from the other. To qualify as a competent appraiser, neither the appraiser nor the company that employs the appraiser is entitled to receive a fee that is dependent on the amount of the appraisal award. However, the payment of an hourly or flat fee shall not render an appraiser incompetent under this provision. c. The two appraisers will choose a competent, disinterested umpire. If they cannot agree upon an umpire within 15 days, you or we may request that the choice be made by a judge of a court of record in the state where the "residence premises” is located. d. The appraisers will separately set the amount of the loss. If the appraisers submit a written report of an agreement to us, the amount agreed upon will be the amount of the loss. If they fail to agree, they will submit their differences to the umpire. A decision agreed to by any two will set the amount of the loss. In all instances, the written report of agreement will be in writing and shall include the following: (1) A detailed list, including the amount to repair or replace, of each specific item included in the award from the appraisal findings; (2) The agreed amount of each item, its replacement cost value and corresponding actual cash value; and (3) The statement of "This award is made subject to the terms and conditions of the policy." Each party will: (a) Pay its own appraiser, including their costs associated with producing the estimate in 2.a. of this provision, above; and (b) Bear the other expenses of the appraisal and umpire equally. e. You, we, the appraisers, and the umpire shall be given reasonable and timely access to inspect the property, in accordance with the terms of the policy. f. You" and “we” do not waive any rights by demanding or submitting to an appraisal and retain all contractual rights to determine if coverage applies to each item in dispute. g. Appraisal is only available to determine the amount of the loss of each item in dispute. The appraisers and the umpire have no authority to decide: (1) Any other questions of fact; (2) Questions of law; (3) Questions of coverage; (4) Other contractual issues; or to conduct appraisal on a class-wide-basis. *** Your policy provides specific duties following a loss, including, but not limited to allowing us to inspect the damaged property prior to its removal from the property and showing us the damaged property. Failure to comply with these duties may be prejudicial to the claims process. *** Please review your policy, the HOMEOWNERS 3 SPECIAL FORM HO 00 03 05 11, as amended by the SPECIAL PROVISIONS FIM 00 23 11 21, which provides in part: SECTION I - CONDITIONS C. Duties After Loss is deleted and replaced by the following: C. Duties After Loss. An "assignment agreement does not change the obligations to perform the duties required under this Policy. In case of a loss to covered property, you must see that the following are done. These duties must be performed either by you, an "insured" seeking coverage, or a representative of either: … 1. Your Duties After Loss … b. To the degree reasonably possible, retain the damaged property and any photographs of the damaged property; and Allow us to inspect, subject to the paragraph above, all damaged property prior to its removal from the "residence premises" and make copies of the photographs. e. Protect the property from further damage. The following must be performed: … (2) Keep an accurate record of repair expenses, if to the degree reasonably possible, take pictures prior to repairs commencing. f. Cooperate with us in the investigation of a claim. This includes speaking to and sharing information with us or any person authorized to act on our behalf, and providing documents which can be reasonably obtained by you, to facilitate our, investigation of the claim. You, any “insured" seeking coverage, or a representative of either of these: (1) Must cooperate with our investigation; (2) Must not act in any manner that prevents us or any person authorized to act on our behalf, from investigating the claim; and (3) May not act in any manner to obstruct our investigation. g. Prepare an inventory of damaged personal property showing the quantity, description, actual cash value and amount of loss. Attach all bills, receipts, and related documents that justify the figures in the inventory. h. As often as we reasonably require: (1) Show us the damaged property and the cause of loss and the condition it was in at the time of loss, if possible, except as to any repairs performed under SECTION I PROPERTY COVERAGES Additional Coverages, 2. Reasonable Emergency Measures; (2) Provide us with records and documents we request and permit us to make copies; (3) You, and any and all "insureds;" and Any member, officer, director, partner, or similar representative of the association, corporation, or other entity, if you are the association, corporation, or other entity, who is an "insured;"-must: (a) Submit to examination under oath and recorded statements at the location insured or other reasonable location designated by us, while not in the presence of each other or any other "insured” (b) Provide government issued photo identification. If you do not possess government issued photo identification, a signed sworn statement identifying who you are may be provided; and (c) Sign any transcript of the examinations under oath and recorded statements; At our request, the examinations will be conducted separately and not in the presence of any other persons except legal representation; Such examinations and recorded statements must either be in person or utilize video and audio technology, or both, as determined by us; (4) Permit us to take samples of damaged and undamaged property for inspection, testing, and analysis; and (5) Any and all "insureds" must execute all authorizations for the release of information when requested by us, which we deem relevant to the investigation of your loss. (6) Allow us or any person authorized on our behalf: (a) Access to the "residence premises;" (b) To inspect the "residence premises" and to inspect, subject to 2. above, all damaged property prior to its removal from the "residence premises;" and (c) To require an "insured" or their representative, or both if reasonably possible, to be present at our 1inspection and to assist in identifying the damaged property during the inspection; (7) At our request, identify the person or persons with knowledge of how the loss occurred and the extent of damage; (8) For losses covered under Coverage A and B, allow us to reinspect, including but not limited to taking photographs and/or video of the property to confirm repairs invoiced by any "assignees(s)" or third parties were completed, or following a supplemental or re-opened claim. i. Submit to us, within 60 days after the loss, your signed, sworn proof of loss which sets forth, to the best of your knowledge and belief: (1) The description of the loss, including the date and time of the loss, the cause of loss, a description of how the loss occurred, when the loss was discovered, and who discovered the loss; (2) The names of all persons who resided at the insured location at the time of the loss; (3) The interest of all "insureds," "assignees" if any, and all others in the property, involved and all liens on the property; (4) Other insurance which may cover the loss; (5) Changes in title or occupancy of the property during the term of the policy· (6) Specifications of damage to the dwelling and other structures, including; (a) Detailed descriptions of the damage to the property; (b) Repair estimates which show the extent of damage to each item or property; (c) Estimated amount(s) to repair or replace each item of property; and (d) Amount(s) of payment made for any temporary or permanent repairs. Photographs and other supporting documentation that exists should be included to the extent it is reasonable and practical to obtain; (7) The .inventory of damaged personal property described in C.7. above; (8) Receipts for additional living expenses incurred and records that support the fair rental value; and (9) Evidence or affidav.it that support a claim under the Credit Card, Fund Transfer Card, Forgery and Counterfeit Money coverage, stating the amount and cause of loss. j. Produce any updates to the documents and information described above, including revised descriptions of loss, scope of loss, estimates, or other supporting information: (1) As this information becomes available, and if additional loss or damage is discovered or incurred; and (2) If you are provided with new estimates or invoices regarding the losses submitted or not submitted in the proof of 1loss. The duties above apply regardless of whether you, an "insured" seeking coverage, or a representative of either retains or is assisted by a party who provides legal advice, insurance advice or expert claim advice, regarding an insurance claim under this Policy. … The aforementioned policy provisions are only excerpts from your policy. All policy terms and conditions continue to apply to your claim. Pursuant to the above referenced policy provisions, the appraisal panel has no authority to decide questions of fact, law, coverage, or other contractual issues. Further, “You” and “We” do not waive any rights by demanding or submitting to an appraisal and retain all contractual rights to determine if coverage applies to each item in dispute. Frontline expressly reserves all its rights, conditions, terms, provisions, endorsements, exclusions, or requirements contained in your Policy as well as Florida Law. Any obligation or legal rights, which may now or hereafter be available to you or to Frontline, are hereby reserved. If you have any additional information, or other items submit the same through the web portal at www.frontlineinsurance.com (Main Menu > Upload Claim Documents) or email to appraisaldocs@flhi.com. Should you have any questions or concerns or have any additional information you would like to submit for consideration, please feel free to contact me Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m. I can be reached at (251) 607-4442. Should I not be available when you call, please leave me a detailed message and I will return your call as soon as possible.” Nevertheless, although appraisal was on going, on February 10, 2025, the Insureds, via their counsel, filed this Civil Remedy Notice. On February 13, 2025, the Insureds’ counsel called Frontline to request another inspection of the property. Then, in an email exchange between the Insureds, their counsel, and Frontline, the Insureds stated they wished to withdraw their claim. Thus, on February 28, 2025, Frontline sent a withdrawal acknowledgment letter that stated: “As you know, Frontline provides homeowners insurance to you under policy number FPH3- 000122746 for the above-referenced property location for the policy period October 23, 2023 thru October 23, 2024, subject to all terms and conditions of your policy. This letter follows the email we received on February 26, 2025, regarding the claim for Hurricane damage which reportedly occurred on September 25, 2024. You indicated in the email that you no longer wished to pursue your current Hurricane claim, which was set up under claim number 01000119531 and directed us to cease any further investigation, evaluation and/or adjustment of this claim. Please, understand that should you reconsider your decision to abandon the instant claim, you must immediately notify Frontline of your intent to pursue the claim so we may continue our investigation. However, your decision to delay the reporting and investigation of the loss may cause additional delays and present coverage questions if our ability to independently investigate the original Hurricane damage is prejudiced by your actions. Frontline reserves its right to continue its evaluation in the future should you, for whatever reason, decide to reopen the claim. The decision to abandon your claim does not relieve you of any duties under the policy, including but not limited to, protecting your property from further damage, keeping an accurate record of repairs, taking photos before the repairs commence and showing us the damaged property. You should move forward with any repairs necessary to protect your property from further damage and maintain an accurate record of repairs, including photos and videos… …Should you have any questions or concerns, please feel free to contact me Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m. EST. I can be reached at (251) 607-4442. If I am not available when you call, please leave me a detailed message, and I will return your call as soon as possible.” 2. Nature of the Complainants’ Civil Remedy Complaint As noted above, the Insureds have withdrawn their claim for Hurricane Helene damages, nevertheless: In the Civil Remedy Notice, the Complainants allege Frontline violated: Section 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. Section 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. Section 626.9541(1)(i)(3)(a)—Failing to adopt and implement standards for the proper investigation of claims. Section 626.9541(1)(i)(3)(c)— Failing to acknowledge and act promptly upon communications with respect to claims. Section 626.9541(1)(i)(3)(g)- Failing to promptly notify the insured of any additional information necessary for the processing of a claim. These accusations are unfair given the nature of the facts and damage surrounding this claim. Here, the claim was processed, the Insureds’ property was inspected, requests for information were sent, a Recorded Statement was taken, Frontline came to a reasoned decision that coverage was below the deductible, and continued to adjust and appraise the claim up until withdrawal. Specifically, first, Frontline asserts that it did act in good faith, fairly, and honestly towards the Insureds by taking all necessary steps to decide coverage all while keeping in constant communication with the Insureds and their counsel. Second, Frontline asserts that the obligation to settle the claim is not reasonably clear as adjustment and appraisal was ongoing up until withdrawal. Third, Frontline asserts that it does have standards for the proper investigation of claims, standards that it used during the evaluation of this claim, including sending a Field Adjuster to inspect the property in person, requesting paper documents for Desk Adjusters to evaluate, taking a Recorded Statement of the Insureds, requesting a Sworn Proof of Loss, keeping in communication with the Insureds and their counsel, and going to appraisal when appraisal was ripe. Fourth, Frontline asserts that it always acted promptly, and often followed up with the Insureds when they did not respond promptly to Frontline’s communications. Fifth, Frontline asserts that it did promptly notify the Insureds and their counsel, numerous times, when additional information was necessary. Moreover, the Notice is deficient because it fails to identify any person representing the Insurer that is responsible for any alleged violations. Further, the Complainants have failed to ask for a proper cure of their Civil Remedy Notice. Instead, they have asked for the following cure(s): (1) create and implement adequate guidelines for the proper investigation and evaluation of claims and for the training and supervision of employees, which will avoid future statutory violations and avoid this from occurring in the future. (2) immediately tender all insurance proceeds due and owing its Insureds under the Policy in the amount of $45,015.66 (less the deductible and any prior payments), plus all statutory interest. (3) act fairly and honestly towards its Insureds and with due regard for their interests in attempting to settle their Insureds’ claim. (4) hold the claim open in the event that its errors and delay does or may cause the Insureds to suffer either further loss and/or damage. (5) stipulate to the Insureds’ entitlement to attorney’s fees and court costs pursuant to Florida Statutes §§ 627.428 and 626.9373. Frontline responds: (1) This is an improper cure request because it is vague and does not put Frontline on notice of any statutory violations alleged. Nevertheless, Frontline asserts that it does have adequate guidelines for investigation and evaluation of claims and for the training and supervision of employees. (2) This is an improper cure remedy because it is an estimate, and therefore, does not put Frontline on notice of any amount actually owed, if any. Nevertheless, Frontline asserts that it does not owe any amount, as covered damages, when assessed, were below the deductible and the Insureds have withdrawn their claim. (3) This is an improper cure request because it is vague and does not put Frontline on notice of any time it did not act fairly and honestly. Nevertheless, Frontline asserts that it did, at all times, act fairly and honestly towards the Insureds. (4) This is an improper cure remedy because Frontline did hold the claim open, continuing to adjust the claim and go to appraisal even following its initial coverage determination. (5) This is an improper cure request because it improperly demands that Frontline pay attorney’s fees and costs. In Talat Enterprise, Inc. v. Aetna Casualty and Surety Co., 753 So. 2d 1278, 1283 (Fla. 2000), the Florida Supreme Court adopted the following analysis by United States Magistrate Judge Glazebrook: The Court rejects as unsupported Talat's contention that the insurer must not only pay the claim within the sixty-day window, but must also pay all compensatory damages that flow from any delay in settling the claim. Section 624.155 does not impose on an insurer the obligation to pay whatever the insured demands. The sixty-day window is designed to be a cure period that will encourage payment of the underlying claim, and avoid unnecessary bad faith litigation. Surely an insurer need not immediately pay 100% of the damages claimed to flow from bad faith conduct in order to avoid the chance that the insured will succeed on a bad faith cause of action. If the insurer may avoid a bad faith action only by paying in advance every penny of the damages that it faces if it loses at trial, the insurer would have no reason to pay. Furthermore, few insureds would restrict their demands to compensatory damages. There is no reason why insureds would not demand also the advance payment of punitive damages and attorney's fees. Section 624.155(2)(d) would have no effect or purpose under such an interpretation. The law does not support such an expansive and illogical reading of Fla. Stat. Ann. § 624.155(2)(d). See Talat, 753 So. 2d at 1282 (emphasis added). Conclusion Frontline asserts that there was no misconduct in the adjustment of the Insureds’ claim. As can be seen from the above, Frontline has credible evidence to support its belief that the claim was properly adjusted. The claim was processed, the Insureds’ property was inspected, letters requesting documentation and information were sent, a Recorded Statement of the Insureds was taken, Frontline reasonably came to a decision that coverage was below the deductible, and Frontline agreed to go to appraisal even after this coverage decision. Nevertheless, the Insureds have withdrawn this claim. Frontline has spent considerable time and resources in the investigation of this matter and believes that its efforts were made in good faith and based on the information available at the time of the claim, and it continues to do so. In turn, this Civil Remedy Notice unfairly characterizes the facts of the Insureds’ claim and unfairly paints Frontline in a negative light. Moreover, the lack of specificity within the Civil Remedy Notice, has not given Frontline the ability to “cure” the allegations contained herein above, regardless of the withdraw status of the claim. Sincerely, Lee Alhanti Lee Alhanti, Esq. On Behalf of First Protective Insurance Company
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