Civil Remedy Notice of Insurer Violations
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Filing Number:     806600
Filing Accepted:  2/12/2025
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Complainant
Last/Business Name *  
GOMEZ   First Name   VICTOR
Street Address * 1136 BRENTON MANOR DRIVE
City, State Zip * WINTER HAVEN, FL 33881
Email Address * RL@WEKLAW.COM
Complainant Type: * Insured
Insured
Last/Business Name*   GOMEZ   First Name   VICTOR
Policy # * P004292246 Claim #* 244685
Attorney
Attorney is Applicable
Last Name* LEWIS First Name * REBECCA Initial
Street Address* 708 E. COLONIAL DR., SUITE 103
City, State Zip* ORLANDO , FL 32803
Email Address * RL@WEKLAW.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   SECURITY FIRST INSURANCE COMPANY
NAIC Company Code 10117
 
Name of individual responsible for violation (if any):* UNKNOWN
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)(f) Failing to promptly provide a reasonable explanation in writing to the insured of the basis in the insurance policy, in relation to the facts or applicable law, for denial of a claim or for the offer of a compromise settlement.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

AGREEMENT In reliance on the information you have given us, we agree to provide the insurance coverages indicated in the Policy Declarations. In return, you must pay the premium when due and comply with the policy terms and conditions and inform us within 60 days of any change of ownership, title, use or occupancy of the “residence premises.” DEFINITIONS *** 4. "Insured location" means: a. The "residence premises"; b. The part of other premises, other structures and grounds used by you as a residence and: (1) Which is shown in the Declarations; or (2) Which is acquired by you during the policy period for your use as a residence; *** 5. "Occurrence" means an accident, including continuous or repeated exposure to substantially the same general harmful conditions, which results, during the policy period, in: a. "Bodily injury"; or b. "Property damage." 6. "Property damage" means physical injury to, destruction of, or loss of use of tangible property. SECTION I – PROPERTY COVERAGES COVERAGE A– Dwelling We cover: 1. The dwelling on the "residence premises" used mainly as your private residence, including attached structures and attached wall-to-wall carpeting if damage to the dwelling is caused by a covered loss; and 2. 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." This coverage does not apply to land, including land on which the dwelling is located. COVERAGE B – Other Structures 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. This coverage does not apply to land, including land on which the other structures are located. We do not cover other structures: 1. Used in whole or in part for “business”; or 2. Rented or held for rental to any person not a tenant of the dwelling, unless used solely as a private garage. The limit of liability for this coverage will not be more than the limit shown on the Declarations page for Coverage B. Use of this coverage does not reduce the Coverage A limit of liability. SECTION I – PERILS INSURED AGAINST COVERAGE A – DWELLING and COVERAGE B – OTHER STRUCTURES We insure against risk of direct loss to property described in Coverages A and B only if that loss is a physical loss to property. ADDITIONAL COVERAGES 2. Reasonable Emergency Measures. a. We will pay up to the greater of $3,000 or 1% of your Coverage A limit of liability for the reasonable costs incurred by you for necessary measures taken solely to protect covered property from further damage, when the damage or loss is caused by a Peril Insured Against. b. We will not pay more than the amount in a. above, unless we provide you with approval within 48 hours of your request to us to exceed the limit in a. above. In such circumstance, we will pay only up to the additional amount for the measures we authorize. c. If we fail to respond to you within 48 hours of your request to us and the damage or loss is caused by a Peril Insured Against, you may exceed the amount in a. above only up to the cost incurred by you for the reasonable emergency measures taken solely to protect the covered property from further damage. d. If however, your policy includes coverage for “hurricane loss” and a covered loss occurs during a hurricane that causes damage to your covered property, the amount we pay under this additional coverage will be the reasonable cost incurred by you for necessary measures taken solely to protect the property from further damage and is not limited to the amount in a. above. Includes copyrighted material of Insurance Services Office, Inc., with its permission. e. A reasonable measure under this Additional Coverage 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 our inspection, testing, and analysis. For purposes of this Additional Coverage, the cost of testing of air or property to confirm the absence, presence or level of fungi, mold, wet or dry rot, or bacteria is not considered a Reasonable Emergency Measure . This coverage does not relieve you of your duties, in case of a loss to covered property, as set forth in Section I – Condition 2.d. This coverage does not increase the limit of liability applying to the damaged covered property. 13. “Fungi”, Mold, Wet or Dry Rot, Or Bacteria a. We will pay up to the amount stated in the Declarations for Limit of Liability for “Fungi” Coverage for: (1) The total of all loss payable under Section I – Property Coverages caused by or resulting directly or indirectly from “fungi”, mold, wet or dry rot, or bacteria; (2) The cost to remove “fungi”, mold, wet or dry rot, or bacteria from property covered under Section I – Property Coverages; (3) The cost to tear out and replace any part of the building or other covered property as needed to gain access to the “fungi”, mold, wet or dry rot, or bacteria; and (4) The cost of testing of air or property to confirm the absence, presence or level of “fungi”, mold, wet or dry rot, or bacteria whether performed prior to, during or after removal, repair, restoration or replacement. The cost of such testing will be provided only to the extent that there is a reason to believe that there is the presence of “fungi”, mold, wet or dry rot, or bacteria. b. The coverage described in a. above only applies when such loss or costs are a result of a Peril Insured Against that occurs during the policy period and only if all reasonable means were used to save and preserve the property from further damage at and after the time the Peril Insured Against occurred. c. The Each Covered Loss amount shown on the declarations for this coverage is the most we will pay for the total of all loss or costs payable under this Additional Coverage resulting from any one covered loss; and The Policy Aggregate amount shown on the declarations for this coverage is the most we will pay for the total of all loss or costs payable under this Additional Coverage for all covered losses, regardless of the number of locations insured under this policy or number of claims made. d. If there is covered loss or damage to covered property, not caused, in whole or in part, by “fungi”, mold, wet or dry rot, or bacteria, loss payment will not be limited by the terms of this Additional Coverage, except to the extent that “fungi”, mold, wet or dry rot or bacteria causes an increase in the loss. Any such increase in the loss will be subject to the terms of this Additional Coverage. This coverage does not increase the limit of liability that applies to the damaged property. 10. Loss Payment. We will adjust all losses with you. We will pay you unless some other person is named in the policy or is legally entitled to receive payment. Loss will be paid upon the earliest of the following: a. 20 days after we receive your written proof of loss and reach a written executed agreement of settlement with you according to the terms of the written agreement; or b. 60 days after we receive your written proof of loss and: (1) There is an entry of a final judgment or, in the case of an appeal from such judgment, within60 days from and after the affirmance of the same by the appellate court; or (2) There is a written executed mediation settlement agreement with you according to the terms of the written mediation settlement; or c. Within 90 days after we receive written notice of an initial claim, “reopened claim” or “supplemental claim” from you, we will pay or deny such claim or a portion of the claim unless the failure to pay such claim or portion of claim is caused by factors beyond our control which reasonably prevent such payment.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

Maribel Gomez and Victor Gomez ("Insureds") purchased an insurance policy ("Policy") from Security First Insurance Company ("Security First" or “Carrier”) with effective coverage on the date of loss, on or about September 27, 2022, and Policy number P004292246 to insure their property located 1136 Brenton Manor Dr., Winter Haven, FL 33881(the "Property"). ?? On or about December 16, 2022, the Property suffered from extensive damages due to a sudden and accidental water loss ("Loss"). Security First was notified of the Loss immediately upon discovery and was granted access to the property in order to complete their inspection. Security First acknowledged the claim and assigned claim 244685 ("Claim") to the Loss. After receiving notice of the Loss, Security First assigned an adjuster to investigate the loss. As a result of the adjuster’s inspection, on February 6, 2023, Security First issued its claims decision for the Loss. As evidenced by an estimate sent to the Insureds, dated February 3, 2023, Security First determined the total value of the loss was $ 9,676.45. At the same time, the Insureds through their representatives obtained an estimate for the necessary repairs related to the loss, and that estimate totaled $33,880.50. The Insureds, realizing that the adjustment offered by Security First was not an accurate representation of the damage, reached out to Security First in order to have it reconsider its position. Despite being provided plenty of evidence (including photographs, repair estimates, a sworn proof of loss, and near immediate access to the property upon discovery of the loss) showing that the scope and the costs of the repairs exceeded Security First’s valuation of the claim, Security First refused to change its position. Further, the Insureds hired companies to perform services to protect the property from further damage water mitigation, and mold testing and remediation, and Security First has refused to make payment pursuant to the terms of the Policy. Security First’s adjustment of the loss was not a fair or an honest adjustment of the loss. Security First’s adjustment of the loss was intended to provide the illusion of a fair adjustment, to avoid full payment to the Insureds. Security First knows or should know that its adjustment of the Loss is not a fair or honest assessment of the Loss, yet Security First has refused to attempt to settle the Loss with the Insureds and their representatives. Security First has made the practice of undervaluing claims to avoid having to fairly and honestly adjust and pay for losses. Further, Security First failed to assign an adequate adjusting team (field adjuster, contractor consultants, and desk adjusters) to handle the size and scope of the loss. Security First does not have appropriate standards in place to be able to investigate claims such as the Loss at the Insureds’ Property. Security First’s failure to have appropriate standards led to the assignment of an inadequate adjusting team, which ultimately led to Security First’s unfair and dishonest adjustment of the Loss. The Insureds, at their own expense, retained a qualified adjusting team to investigate the Loss. The experienced adjusting team arrived at a drastically different conclusion than Security First’s inadequate adjustment team – specifically, Security First determined the total value of the loss to be $9,676.45, whereas the experienced and qualified adjusting team retained by the Insureds determined the total value of the Loss to be $33,880.50. To date, Security First has failed to accept and fully perform its obligations under the operable insurance contract. The Property remains damaged because the Insureds have not been paid the necessary, covered insurance proceeds sufficient to return the Property to its pre-loss condition. By stating the above detailed facts, it is clear that Security First has violated the following Florida statutes: • 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 Insureds and with due regard for their interest; • 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, by failing to respond to the Insureds’ public adjuster, and Insureds’ counsel with respect to supplemental requests for payments; • 626.9541(1)(i)(3)(f) Failing to promptly provide a reasonable explanation in writing to the Insureds and/or their public adjuster of the basis in the insurance policy, in relation to the facts or applicable law, for the offer of a compromise settlement; In total, and has exhibited above, Security First has implemented a strategy and approach to the Loss that is unfair, and Security First is unfairly attempting to settle the Loss. This notice is given to perfect the right to pursue the civil remedy authorized by Section 624.155, Florida Statutes, should Security First fail to cure the violations set forth in this Civil Remedy Notice within the given cure period. Therefore, to cure the defects outlined in this Civil Remedy Notice, Security First must: (1) Immediately tender all proceeds due and owing to the Insured that are fairly owed to the Insured under the insurance policy that would reasonably compensate the Insured in order to put the loss property back to its pre-loss condition in the sum of $33,880.50 (minus any prior payment and the deductible); (2) Agree to reimburse the Insured's reasonable attorneys’ fees and costs for having to become involved to resolve the claim; and (3) Agree to reimburse the Insured for interest on the amount of benefits that was found to be due and owing to the Insured, relating back to the date of loss.
Comments
User Id Date Added Comment
rl@weklaw.com 04-11-2025 Complainant, through their attorney below, provides notice that this matter has been resolved and hereby withdraws this civil remedy notice.
anthony.crylen@securityfirstflorida.com 04-07-2025 Via Electronic Filing: Florida Department of Financial Services Bureau of Consumer Assistance c/o: Civil Remedy Section Larson Building 200 East Gaines Street Tallahassee, Florida 32399-0322 Via Email: Rebecca Lewis 708 E. Colonial Dr., Ste 103 Orlando, FL. 32803 RL@WEKLAW.COM Re: CIVIL REMEDY NOTICE OF INSURER VIOLATION Filing No.: 806600 Insured: Victor Gomez and Maribel Gomez Insurer: Security First Insurance Company Claim No.:244685 Policy No.: P004292246 Date of Loss: 12/16/2022 Dear Sir or Madam: This correspondence is in response to the Civil Remedy Notice of Insurer Violations (hereinafter referred to as the “CRN”) was filed by Rebecca Lewis on behalf of her client, Victor Gomez and Maribel Gomez hereinafter referred to as “Insured”). Please be advised that the undersigned represents the interests of Security First Insurance Company (hereinafter referred to as “Security First”) with respect to the above-referenced matter. The Florida Department of Financial Services (hereinafter referred to as “Department”) assigned this CRN an acceptance date of 2/12/2025 and DFS File No.:806600 This matter concerns a property damage claim made by the Insured pursuant to a homeowners’ insurance policy provided by Security First Policy No. P004292246 and assigned Claim No. 244685. As the basis for filing the CRN against Security First, Victor Gomez and Maribel Gomez asserts in the “Reasons for Notice” section violations such as, Claim Denial, Claim Delay, Unsatisfactory Settlement Offer, Unfair Trade Practice along with the following statutory violations: 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)(b) Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue. 626.9541(1)(i)(3)(c) Failing to acknowledge and act promptly upon communications with respect to claims, by failing to respond to the Insureds’ public adjuster, and Insureds’ counsel with respect to supplemental requests for payments; 626.9541(1)(i)(3)(f) Failing to promptly provide a reasonable explanation in writing to the Insureds and/or their public adjuster of the basis in the insurance policy, in relation to the facts or applicable law, for the offer of a compromise settlement. 626.9541(1)(i)(3)(i) Failing to pay personal injury protection insurance claims within the time periods required by s. 627.736(4)(b). Security First welcomes this opportunity to respond to the CRN and denies each allegation contained therein. The allegations made in the CRN are premature, as the insureds have failed to perfect the claim for bad faith and the CRN does not meet the specificity requirement of Section 624.155, Florida Statutes. This CRN does not sufficiently support the allegations stated above. As is standard procedure, upon the first notice of the claim, the subject property was dutifully inspected by Security First’s representatives, which was documented through photographs. Security First received notice on January 5, 2023, for the loss that allegedly occurred on December 16, 2022. The subject property was timely inspected on January 11, 2023, by Security First’s field adjuster and by vendor Hydro Scout. The property was further inspected and an estimate of repairs was provided by BluSky Restoration Contractors on February 3, 2023. After the inspection, it was determined that failure of a kitchen plumbing system caused damage estimated by BluSky Restoration Contractors in the amount of $9,676.45. After application of $1,000.00 deductible, a coverage letter and payment of $8,676.45 was sent to the insured’s attorney WEISSER & ELAZAR & KANTOR, PLLC Trust Account The insured then filed suit on July 7, 2023. I. Perfecting a Claim for Bad Faith Security First specifically denies all allegations set forth in the Notice. Security First contends that the Notice should be rejected and returned by the Department of Financial Services as it is premature. Pursuant to statute, there is no potential violation until a breach of contract is established. § 624.1551, Florida Statutes. Accordingly, any Notice filed prior to a finding that Security First has breached the terms of the policy, is not ripe and is premature and thus fails to perfect the Insureds’ rights to pursue civil remedies under Florida Statutes. II. Specificity Requirement The Insured’s CRN violates multiple requirements set forth in the Florida courts’ jurisprudence for Civil Remedy Notices. In addition, it fails to meet even the most basic requirements of the Statute. Pursuant to the terms of the statute, (3)(a) As a condition precedent to bringing an action under this section, the department and the authorized insurer must have been given 60 days’ written notice of the violations. Notice to the authorized insurer must be provided by the department to the e-mail address designated by the insurer under s. 624.422. a. The notice shall be on a form provided by the department and shall state with specificity the following information, and such other information as the department may require (emphasis added): b. (3)(a) As a condition precedent to bringing an action under this section, the department and the authorized insurer must have been given 60 days’ written notice of the violations. Notice to the authorized insurer must be provided by the department to the e-mail address designated by the insurer under s. 624.422. i. The statutory provision, including the specific language of the statute, which the authorized insurer allegedly violated. ii. The facts and circumstances giving rise to the violation. iii. The name of any individual involved in the violation. iv. Reference to specific policy language that is relevant to the violation, if any. If the person bringing the civil action is a third-party claimant, she or he shall not be required to reference the specific policy language if the authorized insurer has not provided a copy of the policy to the third-party claimant pursuant to written request. v. A statement that the notice is given in order to perfect the right to pursue the civil remedy authorized by this section. In interpreting this statute, courts have emphasized the importance of filing specific civil remedy notices. The civil remedy notice is “crucial to the procedural integrity of an action” under the Statute. Allstate Ins. Co. v. Clohessy, 32 F.Supp.2d 1328, 1333 (M.D. Fla. 1998). “It is, without a doubt, a condition that must be satisfied in order for one to perfect the right to sue under the statute.” Id. “In creating this statutory remedy for bad- faith actions, the Legislature provided this sixty-day window as a last opportunity for insurers to comply with their claim-handling obligations when a good-faith decision by the insurer would indicate that contractual benefits are owed.” Talat Enterprises, Inc. v. Aetna Cas. & Sur. Co., 753 So. 2d 1284 (Fla. 2000). Thus, the Notice cannot be “vague and ‘shotgun’ in nature,” rather than “the type of specific notice required by the statute that would allow [the insurer] an opportunity to cure.” Heritage Corp. of South Florida v. National Union Fire Ins. Co. of Pittsburgh, PA, 580 F. Supp. 2d 1294, 1299 (S.D. Fla. 2008). Because it is in derogation of the common law, Section 624.155(1)(b), Florida Statutes must be strictly construed. Talat, 753 So. 2d at 1283 (citing Baxter v. Royal Indem. Co., 285 So. 2d 652 (Fla. 1st DCA 1973). To perfect the right to sue under the statute, an insured must specifically notify the insurer of any and all alleged violations claimed. Talat Enterprises, Inc. v. Aetna Casualty & Surety Co., 952 F.Supp. 773, 776 (M.D. Fla. 1996) (“Talat I”) See Fox v. Starr Indem. & Liab. Co., No. 8:16-CV-3254-T-23MAP, 2017 WL 1541294, at *2 (M.D. Fla. Apr. 28, 2017) (sufficiency means specificity). In Junior Julien v. United Property and Casualty Insurance Company, 311 So.3d 875, 879 (Fla. 4th DCA 2021), the Honorable Court stated: The Middle District of Florida was confronted with a civil remedy notice that was similarly broad in scope and concluded that listing nearly all policy provisions on the notice did not satisfy the statute. Fox v. Starr Indem. & Liab. Co., No. 8:16-CV-3254-T-23MAP, 2017 WL 1541294, at *2 (M.D. Fla. Apr. 28, 2017). The court explained that “[i]f the statute contained no specificity requirement, [then] the [insureds’] casual ‘reference’ to the entire insurance policy undoubtedly would suffice.” Id. But, the court continued, “the Legislature included ‘specific’ or a variant not once but twice in the statute.” Id. As a result, the insureds’ listing of whole sections of the insurance policy “appear[ed] to lack specificity.” Id. In Valenti, the District Court for the Middle District of Florida considered the practical consequences of an insured’s non-specific civil remedy notice. Valenti v. Unum Life Ins. Co. of America, 2006 WL 1627276 (M.D. Fla. 2006). The plaintiff’s civil remedy notice included allegations that the defendant conducted an inadequate investigation. The plaintiff, however, failed to identify with the requisite specificity the defendant’s actions that were inadequate. The Middle District held that the plaintiff’s civil remedy notice was insufficient, and stated the following: [T]he civil remedy notice must be specific enough to provide insurers notice of the wrongdoing so the insurer can cure the same within sixty days. … Plaintiffs’ counsel, during the hearing in this matter, argued a civil remedy notice that states “you denied my claim” should be sufficient to place the insurer on notice of what was needed to be cured. Plaintiffs’ counsel further argued that it was up to the insurer, as the insurance expert, to decipher what actions needed to be cured. This argument, in this Court's estimation, is illogical and is counter to the purpose of the civil remedy notice. If a simple “you denied my claim” was sufficient to put insurers on notice, the sixty-day cure period would be little more than a guessing game with the insurer attempting to correctly guess what errors the insured claimed it made in the claims handling process, or risk defending a bad faith action. This surely is not what the legislature had in mind when it created the civil remedy notice. Accordingly, this Court finds that Plaintiffs allegation that Defendant failed to conduct an adequate investigation is insufficient to provide Defendant an opportunity to cure. Id. at *2. The guidance for an insured could not be clearer. “The purpose of the civil remedy notice is to give the insurer one last chance to settle a claim with its insured and avoid unnecessary bad faith litigation.” Lane v. Westfield Insurance Co., 862 So. 2d 774, 779 (Fla. 5th DCA 2004). Its purpose is not “to give the insured a right of action to proceed against the insurer even after the insured’s claim has been paid or resolved.” Id. Ultimately, conclusory allegations without facts fail to perfect a statutory bad faith claim. Merely alleging the bare minimum allegations is insufficient pursuant to Florida courts’ interpretations of Section 624.155, Florida Statutes. III. Validity of allegations made by Rebecca Lewis on behalf of her clients, Victor Gomez and Maribel Gomez The allegations made by Rebecca Lewis on behalf of her clients, Victor Gomez and Maribel Gomez lacks factual support and are untrue. Security First elects to use this section to respond to Counsel’s allegations that the following statutory provisions have been violated: Counsel and the insureds have alleged that Security First violated “Fla. Sta. 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.” This allegation is without basis, and therefore denied, as Security First conducted a prompt and thorough investigation in good faith. Security First received notice on January 5, 2023, for the loss that allegedly occurred on December 16, 2022. The subject property was timely inspected and coverage was afforded for interior damage to the kitchen area. A coverage determination letter was sent to the insured advising “Inspections of the property revealed that the observed damages are attributed to water leaking from a p-trap under the kitchen sink. Sudden and accidental discharge or overflow of water from within a plumbing system is covered under the policy. There is no coverage to the system from which the water escaped.” Counsel and the insureds have alleged that Security First violated “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.” This allegation is without basis, and therefore denied, as Security First conducted a prompt and thorough investigation in good faith. Security First received notice on January 5, 2023, for the loss that allegedly occurred on December 16, 2022. The subject property was timely inspected on January 11, 2023, by Security First’s field adjuster and by vendor Hydro Scout. The property was further inspected and an estimate of repairs was provided by BluSky Restoration Contractors on February 3, 2023. Counsel and the insureds have alleged that Security First violated “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.” This allegation is without basis, and therefore denied, as Security First conducted a prompt and thorough investigation in good faith. Security First received notice on January 5, 2023, for the loss that allegedly occurred on December 16, 2022. The subject property was timely inspected by Security First’s January 11, 2023. On February 6, 2023 a conclusive coverage determination letter and payment was sent to the insured. Counsel and the insureds have alleged that Security First violated “Fla. Stat. 626.9541(1)(i)(3)(a): Failing to adopt and implement standards for the proper investigation of claims.” This allegation is without basis, and therefore denied, as Security First conducted a prompt and thorough investigation in good faith and On February 6, 2023 a conclusive coverage determination letter and payment was sent to the insured.. Counsel and the insureds have alleged that Security First violated “Fla. Stat. 626.9541(1)(i)(3)(b): Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue.” This allegation is without basis, and therefore denied, as Security First conducted a prompt and thorough investigation in good faith. Security First received notice on January 5, 2023, for the loss that allegedly occurred on December 16, 2022. The subject property was timely inspected on January 11, 2023, by Security First’s field adjuster and by vendor Hydro Scout. The property was further inspected and an estimate of repairs was provided by BluSky Restoration Contractors on February 3, 2023. IV. Conclusion At all times, Security First has acted in good faith in its handling of the claim, and it has acted fairly, honestly, and with due regard for the Insureds’ interest and in determining obligations to Insureds. Specifically, Security First has complied with its obligations under the applicable Florida Statutes and the applicable Security First Insurance policy. Security First specifically denies any claim for bad faith and argues that the insureds’ claim for bad faith is premature. Security First continues to reserve all its rights under the policy, at law and in equity. Regardless, Insureds’ conclusory allegations fail to place Security First on notice of any purported violations. Furthermore, the Civil Remedy Notice fails to properly identify, in good faith, how to cure the allegations set forth. The allegations are without basis. It is clear Security First properly handled and adequately investigated the claim. We hope that this response has answered any concerns regarding this matter. If the Department has any question concerning this matter, please do not hesitate to contact me. Sincerely, Anthony Crylen Examiner/Litigation Specialist Adjuster License # P012449 Security First Insurance Company 1001 Broadway Avenue Ormond Beach, Florida 32714 Anthony.Crylen@securityfirstflorida.com Telephone Number: 386 868 1172
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