Civil Remedy Notice of Insurer Violations
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Filing Number:     806581
Filing Accepted:  2/12/2025
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Complainant
Last/Business Name *  
JONES   First Name   STEPHEN
Street Address * 10441 HUNTERS CREEK COURT
City, State Zip * JACKSONVILLE, FL 32256
Email Address * STEPHEN@HSJTECH.COM
Complainant Type: * Insured
Insured
Last/Business Name*   JONES   First Name   STEPHEN
Policy # * 2870289194 Claim #* 01000117648
Attorney
Attorney is Applicable
Last Name* KRAPF First Name * GRANT Initial W
Street Address* 2790 SUNSET POINT RD
City, State Zip* CLEARWATER , FL 33759
Email Address * GRANT@KRAPFLEGAL.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   FRONTLINE INSURANCE UNLIMITED COMPANY
NAIC Company Code 10074
 
Name of individual responsible for violation (if any):* STEPHEN COLLIER, CARRIE KUNKLER, AND ANY OTHER INDIVIDUAL FROM, OR AGENT OF, FIRST PROTECTIVE INSURANCE COMPANY D/B/A FRONTLINE INSURANCE, WHO WAS INVOLVED IN THE CLAIM.
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Claim Delay
Unfair Trade Practice
Other : Misrepresenting the terms of the insurance policy
Other : Not treating the Insured with good faith claims conduct
Other : Looking for ways to deny full recovery to the Insured
Other : Looking for ways to delay full recovery to the Insured
Other : Failing to properly investigate the Insured's loss
Other : Failing to provide the Insured with the full benefits awarded under the contract of insurance in a t
Other : Not training, supervising, or managing adjusters properly so that prompt and full payments are made
Other : Not adjusting claims and evaluating loss properly
Other : Shifting the burden of insuring the loss to the Insured
Other : Failing to implement proper standards for the adjustment and investigation of claims
* Statutory provision(s) which the insurer allegedly violated.
 
624.155(1)(b)(1) Not attempting in good faith to settle claims when, under all the circumstances, it could and should have done so, had it acted fairly and honestly toward its insured and with due regard for her or his interests.
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)(2) A material misrepresentation made to an insured or any other person having an interest in the proceeds payable under such contract or policy, for the purpose and with the intent of effecting settlement of such claims, loss, or damage under such contract or policy on less favorable terms than those provided in, and contemplated by, such contract or policy.
626.9541(1)(i)(3)(a) Failing to adopt and implement standards for the proper investigation of claims.
626.9541(1)(i)(3)(c) Failing to acknowledge and act promptly upon communications with respect to claims.
626.9541(1)(i)(3)(d) Denying claims without conducting reasonable investigations based upon available information.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

627.70131(7)(a)Within 60 days after an insurer receives notice of an initial, reopened, or supplemental property insurance claim from a policyholder, the insurer shall pay or deny such claim or a portion of the claim unless the failure to pay is caused by factors beyond the control of the insurer. The insurer shall provide a reasonable explanation in writing to the policyholder of the basis in the insurance policy, in relation to the facts or applicable law, for the payment, denial, or partial denial of a claim. If the insurer's claim payment is less than specified in any insurer's detailed estimate of the amount of the loss, the insurer must provide a reasonable explanation in writing of the difference to the policyholder. Any payment of an initial or supplemental claim or portion of such claim made 60 days after the insurer receives notice of the claim, or made after the expiration of any additional timeframe provided to pay or deny a claim or a portion of a claim made pursuant to an order of the office finding factors beyond the control of the insurer, whichever is later, bears interest at the rate set forth in s. 55.03. Interest begins to accrue from the date the insurer receives notice of the claim. The provisions of this subsection may not be waived, voided, or nullified by the terms of the insurance policy. If there is a right to prejudgment interest, the insured must select whether to receive prejudgment interest or interest under this subsection. Interest is payable when the claim or portion of the claim is paid. Failure to comply with this subsection constitutes a violation of this code. However, failure to comply with this subsection does not form the sole basis for a private cause of action. 627.444(2)(a) Notwithstanding any other law, an insurer shall provide to an insured within 15 calendar days after an individual or entity designated by the insurer receives the insured's written request, either: A loss run statement; Reference to specific policy language: The violations alleged are statutorily based and do not rely on any specific policy language. "It is an accepted principle of law that when parties contract upon a matter which is the subject of statutory regulation, the parties are presumed to have entered into their agreement with reference to such statute, which becomes a part of the contract, unless the contract discloses a contrary intention." Westside EKG Assocs. v. Found. Health, 932 So. 2d 214, 216 (Fla. 4th DCA 2005), aff'd, 944 So. 2d 188 (Fla. 2006).
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

First Protective Insurance Company d/b/a Frontline Insurance (the "Insurer") has committed the following in handling the Insured's claim: 1) failure to act in due diligence and good faith to resolve claims; 2) placing the financial interest of Insurer before that of the policyholder and the Insured; 3) looking for ways to deny benefit payments and otherwise "low ball" or "stone wall" claims; 4) not adjusting the claims promptly and fairly; 5) not attempting in good faith to settle claims; 6) conducting inadequate investigations; 7) failing to employ policies and procedures to conduct adequate investigations; 8) shifting the burden of investigating the loss onto the Insured; 9) failing to render a claims determination within sixty (60) days; 10) requesting a re-inspection only after the Insured retained a public adjuster; 11) failing to acknowledge and act promptly upon communications with respect to claims; 12) failing to provide a loss run statement; and 13) misrepresenting the terms of the insurance policy. On or about September 18, 2024, while the subject policy was in full force and effect, the Insured's suffered a loss caused by wind. The areas impacted include but are not limited to the roofing system, exterior surfaces, bonus room closet, and bathroom. The Insured timely submitted a claim on September 26, 2024, to the Insurer for wind damage and the ensuing damage therefrom. Thereafter, the Insurer assigned claim number 01000117648 to the loss and sent a field adjuster to inspect the property on October 7, 2024. Given the scope and nature of the damage, the Insured retained a public adjuster. After assessing the damage and the true scope of repairs, the public adjuster prepared an estimate identifying $82,258.38 in covered damage to the dwelling. The foregoing estimate, photographs, and a letter of representation from the public adjuster were sent to the Insurer who subsequently re-inspected the property. The reinspection clearly demonstrates that the Insurer's initial inspection was inadequate and was only meant to provide a "low-ball" estimate to wait and see if that amount would be accepted. Furthermore, this shows that the Insurer has implemented policies and procedures that once a public adjuster has been retained, the Insurer will request a reinspection despite no changes occurring at the property, and that the Insurer treats represented Insureds differently than those who are unrepresented. It was not until January 14, 2025, one-hundred ten (110) days after the Insured reported their loss that the Insurer issued its coverage determination letter in which it notified the Insured that it was extending partial coverage for the loss. However, the Insurer wrongfully determined that it would only require $1,458.86 to restore the insured property to its pre-loss condition, which resulted in no payment being issued to the Insured as the amount of covered damage allegedly fell below the policy deductible. The Insurer's lowball estimate is that of a classic under scope and under value of the claim. The Insurer has placed obstacles to the Insured's ability to have the claim adjusted promptly to begin restoring the home by waiting more than sixty (60) days after receiving notice of the loss to make a claims determination. Under Fla. Stat. 627.70131(7)(a), "[w]ithin 60 days after an insurer receives notice of an initial, reopened, or supplemental property insurance claim from a policyholder, the insurer shall pay or deny such claim or a portion of the claim unless the failure to pay is caused by factors beyond the control of the insurer which reasonably prevent such payment." There were and are currently no factors outside of the Insurer's control. As the Insurer has failed to make a timely determination, it has violated this code. As such, in addition to the below requirements to cure this CRN, any payment made to the Insured must contain interest for the damage as a result of the loss from the date the Insurer received first notice of the loss. The Insurer misrepresented the loss and issued a wrongful partial denial. The Insurer denied coverage for damage sustained to the roofing system based on the rationale that the damage sustained was a result of " wear and tear, deterioration, faulty, inadequate, or defective: workmanship, repair, construction, materials used in repair or construction, and maintenance." Although the Insurer and Insured are in dispute about how the roof was damaged, the Insurer knows or should know that when independent perils converge and no single cause can be considered the sole or proximate cause, it is appropriate to apply the concurring cause doctrine. Sebo v. Am. Home Assurance Co., 208 So. 3d 694, 697 (Fla. 2016). The concurring cause doctrine states that coverage may exist where an insured risk constitutes a concurrent cause of the loss even when it is not the prime or efficient cause. Id. at 698. A covered peril that meets with an uncovered peril may still provide for coverage under a policy when the covered peril triggered the events that eventually led to the loss. Id. at 697. The claims determination letter failed to comply with Fla. Stat. 626.9541(1)(i)(3)(f) as it did not include a reasonable explanation of the basis in the insurance policy, in relation to the facts, for the denial. The letter simply copies several policy exclusions with no explanation. Upon receiving notice of the loss, the Insurer had the duty to provide the full benefits under the policy. This includes providing the Insured with a proper investigation and the funds necessary to return the home to its pre-loss condition. There may be further wrongful conduct which has not been made known to the Insured at this moment. Certain conduct or actions may be discovered throughout discovery or cannot be verified without a review of the Insurer's claim file and standards and procedures for the adjustment and investigation of claims. The Insurer also failed to allocate and pay for overhead and profit, pursuant to Florida Statute 627.7011(3)(a). Where the Insureds are reasonably likely to need a general contractor for the repairs, Florida Statute 626.7011(3) does not permit an Insurer to withhold overhead and profit pending the actual repair, unless absent a showing by the Insureds that it was likely to need a general contractor for the repairs. Trinidad v. Fla. Peninsula ins. Co., 121 So. 3d 433, 435 (Fla. 2013). The Insurer has implemented policies and procedures that are designed to wrongfully withhold costs associated with restoring the insured property to its pre-loss condition. This is an underhanded attempt by the Insurer to place its financial interest above those of the Insured. Additionally, Insurer shifted the burden and cost of investigating and insuring the loss onto the Insured. During their investigation, the insurer's adjuster did not use a moisture meter, despite the presence of interior water damage. A moisture meter can be purchased online from Amazon for around $40 before tax. The Insurer could purchase a moisture meter and assess thousands of properties with one meter. Instead, the Insurer would rather place its financial interests over those of the Insured by failing to provide the adjuster with the necessary tools to correctly inspect the loss. As a result of the inadequate investigation and surrounding circumstances it is apparent that the Insurer significantly underestimated the scope of the loss to the Insured's property. The Insurer and its adjuster have colluded to misrepresent the true scope of damages to the insured property and the true replacement costs of the damages. Furthermore, the Insurer and its agents failed to comply with Fla. Stat. 627.444 by not providing the Insured and the Insured's representatives with a loss run statement. On January 27, 2025, the Insured's legal counsel provided the Insurer with a letter of representation. Within the letter, legal counsel requested a copy of a loss run statement. The Insurer and its agents have not acknowledged the request for a loss run statement nor has a loss run statement been provided. Upon receiving a written request for a loss run statement, the Insurer is required, within fifteen (15) calendar days, to provide either a loss run statement or information on how to obtain a loss run statement at no charge through a consumer reporting agency. There has been no response within fifteen (15) calendar days of the Insured's written request and the Insurer has not provided information on how to obtain a loss run statement at no charge through a consumer reporting agency. This Insurer has breached its duty to settle claims in good faith when, under all the circumstances, it could and should have done so. The Insurer and its agents have not acted fairly and honestly toward the Insured and the Insured's representative and have moreover failed or refused to promptly acknowledge the Insured's communications in an attempt to frustrate and delay the resolution of the Insured's claim. In short, the Insurer is not acting with due regard for the Insured's interests or safety. In Florida the work of adjusting insurance claims engages the public trust. The Insurer has breached this trust and its duty to the Insured. The Insurer and its agents conducted cursory and inadequate investigations and wrongfully determined that it would only require $1,458.86 to restore the insured property to its pre-loss condition. Moreover, the Insurer has engaged in bad faith practices designed to delay claims and prevent the Insured from recovering what is rightfully owed under the subject policy of insurance. The Insurer's actions and inactions have continued to frustrate and delay the resolution of the Insured claim. The Insurer's actions amount to but are not limited to the following: 1. Claim delay 2. Not treating the Insured with good faith claims conduct 3. Looking for way to reduce recovery to the Insured 4. Looking for ways to deny recovery to the Insured 5. Not adjusting claims and evaluating loss properly, promptly and fairly to provide full and prompt indemnity to the Insured 6. Not training, supervising or managing adjusters properly so that prompt and full payments are made, but rather placing the company's interests before the Insured's interests 7. Placing the financial interest of the Insurer over that of the health and safety of the Insured 8. Shifting the burden of investigating onto the Insured 9. Conducting inadequate investigations 10. Failing to render a written claims determination to the Insured within 90 days pursuant to Florida Statute 627.70131 11. Requesting a re-inspection despite no changes to the above-referenced insured property 12. Treat represented and unrepresented Insured differently 13. Failing to provide a loss run statement 14. Making material misrepresentations Therefore, to cure the defects outlined in this civil remedy notice, the Insurer must: (1). Admit full coverage for the Insured's loss. (2). Tender full benefits owed to the Insured under the insurance contract. A copy of this form submitted to the FDFS has been sent via e-mail to the following parties providing them notice of the filing of the civil remedy notice. Please e-mail any response to this civil remedy notice to badfaith@krapflegal.com. Via E-mail: First Protective Insurance Company d/b/a Frontline Insurance P. O. Box 958405 Lake Mary, FL 32795 info@flhi.com
Comments
User Id Date Added Comment
grant@krapflegal.com 09-26-2025 The details herein have been amicably resolved between the parties; therefore, we withdraw this Civil Remedy Notice. This Civil Remedy Notice is hereby withdrawn.
dmontgomery@kelleykronenberg.com 04-04-2025 Dear Counsel Grant Krapf: We write on behalf of Frontline Insurance Unlimited Company (“Frontline Unlimited”) to respond to the Civil Remedy Notice of Insurer Violations (“CRN”), filed on behalf of complainant Stephen Jones (“the Insured”), dated February 12, 2025. At the outset, this Civil Remedy was filed upon Frontline Unlimited who did not issue a homeowners insurance policy to the Complainant, and at no time was there an insurer-insured relationship between them. Nor was a claim ever submitted to Frontline Insurance Unlimited Company by or on behalf of the Complainant. It appears that the Insured mistakenly named the wrong insurance carrier in the Civil Remedy Notice. As such, Frontline Unlimited requests the Insured immediately withdraw the Civil Remedy Notice. In the alternative, Frontline Unlimited respectfully requests the DFS to reject the Civil Remedy Notice. In addition to the fact that the Civil Remedy Notice names the wrong insurance carrier, the Notice is otherwise statutorily deficient. As stated by the Florida Supreme Court, the purpose of a Notice is to put the insurer on notice of an alleged violation, the circumstances surrounding same, and indicate the details of the alleged violation in order to provide an insurer with 60 days to “cure” the alleged claim defects. See Talat Enterprises, Inc. v. Aetna Casualty and Surety Co., 753 So.2d 1278 (Fla. 2000). The purpose of Fla. Stat. Section §624.155 is to provide the insurer with an opportunity to resolve a first-party coverage dispute and otherwise avoid litigation. See Talat Enterprises, Inc.; see also Lane v. Westfield Ins. Co., 862 So.2d 744 (Fla. 5th DCA 2003). The statute requires this notice to: [S]tate with specificity the following information . . . (1) the statutory provision, including the specific language of the statute, which the authorized insurer allegedly violated[;] (2) the facts and circumstances giving rise to such violation[;] (3) the name of any individual involved in the violation[;] (4) reference the specific policy language that is relevant to the violation, if any . . . [;] (5) a statement that the notice is given in order to perfect the right to pursue the civil remedy authorized by this section. Fla. Stat. § 624.155(3)(a). This statute has been interpreted to require that the Notice must be sufficiently specific to provide the insurer with an opportunity to cure the alleged violations. This would include i) identifying the specific policy provision(s) at issue, ii) citing the specific language of the statutory provision(s) the insurer allegedly violated, and iii) specifically identifying what actions the insurer must take to remedy the alleged violations. Rousso v. Liberty Surplus Ins. Corp., 2010 WL 7367059 (S.D. Fla. August 13, 2010); Heritage Corp. of S. Fla. v. Nat’l Union Fire Ins. Co. of Pittsburg, PA, 580 F. Supp. 2nd 1294, 1299-1300 (S.D. Fla. 2008). In addition, providing vague reference to the policy is insufficient to put the insurer on notice of its alleged policy violation. See Julien v. United Prop. & Casualty Ins. Co., 311 So. 3d 875, 879 (Fla. 4th DCA 2021). In contravention of these requirements, the subject Notice is vague and lacks fundamental information to allow Frontline to respond. Specifically, the CRN contains "cures" that are improper pursuant to Florida case law. Talat provides the scope of what can be "cured" is limited to the alleged non-payment of the contractual amounts due to an insured holding "the contractual amount due the insured is the amount owed pursuant to the express terms and conditions of the policy after all of the conditions precedent of the insurance policy in respect to payment are fulfilled..." Here, the Insured demands Frontline: 1. Frontline must admit full coverage for the Insured’s loss. 2. Frontline must tender full benefits owed to the Insured under the insurance contract. This is squarely what the Supreme Court of Florida rejected in Talat. 753 So.2d at 1284. According to Talat, the only amount properly sought within the remedy is the contractual amount due. Id. at 1283. Insured requests that Frontline admit full coverage for the loss, whether it is covered under the policy or not. Insured then demand the tender of full amounts owed but does not expressly state the amount. While the civil remedy does refer to an estimate prepared by a public adjuster retained by the Insured, it does not provide a value or method for determining the value that the Insured believes he is owed and will cure the alleged civil remedy violation. Accordingly, the Department should strike the Notice and consider it a nullity for failing to comply with §624.155. There is no specific cure pursuant to the terms and conditions of the policy. Second, the CRN alleges eight statutory violations without clearly stating or explaining how any of those alleged violations apply to the instant facts. Relatedly, the CRN cites to functionally every provision of policy coverage but does also does not explain how those provisions support the allegations of bad faith. Courts have struck down CRNs such as this one that are broad in scope because they “fail[] to satisfy the requirement that the insured identify the specific statute and specific policy provision relevant to [the Insurer’s] alleged violation.” Julien v. United Prop. & Casualty Ins. Co., 311 So. 3d 875, 879 (Fla. 4th DCA 2021). The CRN also fails on the merits. Insured alleges numerous statutory violations that Frontline denies individually as follows: Fla. Stat. §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. Response: Denied. Insured does not specifically allege what the failure was. Insured only makes conclusory assertions without setting forth how the facts and circumstances demonstrate Frontline acted in bad faith towards the Insured by finding policy exclusionary language applied to the case without sufficient allegations on who the concurrent causation doctrine didn’t apply. Frontline expressly advised its findings via the coverage determination letter, which did not find a covered peril caused damage. A disagreement on coverage is not bad faith and Insured does not set forth facts sufficient to support a claim of bad faith towards the handling of the claim. The allegation is unsupported by the facts of this case. Frontline, in good faith, acted fairly and honestly towards the Insured. Frontline thoroughly investigated the claim, including conducting an inspection with a competent field adjuster, and an engineer. Frontline denied coverage based upon the facts and circumstances available to it during the investigation. Fla. Stat. §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. Response: Denied. The allegation is unsupported by the facts of this case. Insured does not specifically assert how Frontline attempted to influence settlement of one portion of the claim to influence another. There is no specific allegation and this claim is wholly conclusory. Further, this is contradicted by the allegations of Insured given the denial of the claim. Fla. Stat. 626.9541(1)(i)(2): A material misrepresentation made to an insured or any other person having an interest in the proceeds payable under such contract or policy, for the purpose and with the intent of effecting settlement of such claims, loss, or damage under such contract or policy on less favorable terms than those provided in, and contemplated by, such contract or policy. Response: Denied. The allegation is unsupported by the facts of this case. There is no specific allegation as to what Frontline specifically mispresented. Insured makes a generalized assertion that the denial of the claim as a whole was a misrepresentation of the terms of the policy. This allegation is deficient as it provides no factual basis to support the same.. Indeed, Frontline consistently quoted the policy language and reasonably applied to the claims facts, exemplified by the coverage determination letters and other correspondences. Insured’s disagreement with the policy language, the claim determination, or the valuation, does not transform the disagreement into a claim for bad faith. Fla. Stat. §626.9541(1)(i)(3)(a): Failing to adopt and implement standards for the proper investigation of claims. Response: Denied. This allegation is unsupported by the facts of this case. The standards and methods utilized by Frontline in examining its claims have met and exceeded its obligations and industry standards. Frontline has conducted the handling of this claim according to such standards. Furthermore, Insured fails to allege any factual support or offer any evidence that Frontline has failed to adopt and implement standards for the proper investigation of claims, but instead simply resorts to merely including a recitation of the statutory language he alleges were violated. This type of allegation is deficient as a matter of law. Fla. Stat. §626.9541(1)(i)(3)(c): Failing to acknowledge and act promptly upon communications with respect to claims. Response: Denied. This allegation is unsupported by the facts of this case, nor does the Insured assert a specific allegation of a failure to promptly act. Insured’s allegation is limited a generalized assertion of delay without any factual support. At no time did Frontline fail to acknowledge and act promptly upon communications with respect to the claim. As soon as the claim was submitted, Frontline began the investigation process, including consistent communications with the Insured and his agents. Frontline issued a reservation of rights and promptly advised the Insured of the need for an engineer inspection after the field adjuster inspection. Fla. Stat. §626.9541(1)(i)(3)(d): Denying claims without conducting reasonable investigations based upon available information. Response: Denied. This allegation is unsupported by the facts of this case, nor does Insured provide a specific basis for how Frontline violated this provision. Frontline conducted a reasonable property inspection with a competent field adjuster and engineer to investigate the claim. Frontline notes again that disagreement regarding the claim decision is not a valid basis for asserting a violation of this statute. Fla. Stat. §627.70131(7)(a): Within 60 days after an insurer receives notice of an initial, reopened, or supplemental property insurance claim from a policyholder, the insurer shall pay or deny such claim or a portion of the claim unless the failure to pay is caused by factors beyond the control of the insurer. The insurer shall provide a reasonable explanation in writing to the policyholder of the basis in the insurance policy, in relation to the facts or applicable law, for the payment, denial, or partial denial of a claim. If the insurer’s claim payment is less than specified in any insurer’s detailed estimate of the amount of the loss, the insurer must provide a reasonable explanation in writing of the difference to the policyholder. Any payment of an initial or supplemental claim or portion of such claim made 60 days after the insurer receives notice of the claim, or made after the expiration of any additional timeframe provided to pay or deny a claim or a portion of a claim made pursuant to an order of the office finding factors beyond the control of the insurer, whichever is later, bears interest at the rate set forth in s. 55.03. Interest begins to accrue from the date the insurer receives notice of the claim. The provisions of this subsection may not be waived, voided, or nullified by the terms of the insurance policy. If there is a right to prejudgment interest, the insured must select whether to receive prejudgment interest or interest under this subsection. Interest is payable when the claim or portion of the claim is paid. Failure to comply with this subsection constitutes a violation of this code. However, failure to comply with this subsection does not form the sole basis for a private cause of action. Response: Denied. This allegation is unsupported by the facts of this case. Frontline initially conducted an inspection by a licensed field adjuster. During the investigation, Frontline issued a reservation of rights letter based upon the delayed report and need for an engineer inspection. An engineer inspection occurred within 60-days of the report of loss. Within 120 days, Frontline issued a claim determination, including a finding of covered damage, albeit less than the policy deductible. The statute expressly sets forth factors beyond the control of the insurer as a basis to issue a determination beyond the 60-day timeline. Fla. Stat. §627.444(2)(a): Notwithstanding any other law, an insurer shall provide to an insured within 15 calendar days after an individual or entity designated by the insurer receives the insured’s written request, either…(a) A loss run statement. Response: Frontline has disclosed the loss run statement to Insured in response to this allegation. As can be seen from the facts of this claim, the allegations in the CRN are baseless and wholly without merit. Thus, the CRN is purposely drafted in a manner that does not allow Frontline proper notice of the allegations or any meaningful opportunity to respond and/or evaluate the asserted claims. Based on the foregoing, the CRN is insufficient on its face and should be rejected. Talat Enterprises Inc. vs. Aetna Cas. & Sur. Co., 753 So. 2d 1278 (Fla. 2000); Lane v. Westfield Ins. Company, 862 So. 2d 744 (Fla. 5th DCA 2003). In closing, Frontline's actions in handling the Insured's claim were prompt, thorough, conducted in accordance with the Policy and Florida law, and most importantly, in good faith. Furthermore, Frontline complied with all obligations under the Policy and the Florida Statutes. Therefore, Frontline denies each and every allegation contained in the Notice. We trust this response adequately addresses the allegations of violation in the CRN. In addition, you will find a copy of the response submitted to the Florida Department of Financial Services on its website. Please do not hesitate to contact the undersigned if you have any questions regarding this matter or need anything further. Sincerely, By: /s/ Daniel S. Montgomery Daniel S. Montgomery
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