Civil Remedy Notice of Insurer Violations
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Filing Number:     806721
Filing Accepted:  2/13/2025
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Complainant
Last/Business Name *  
PATAKY   First Name   LESLIE
Street Address * 4408 SW 20TH AVENUE
City, State Zip * CAPE CORAL, FL 33914
Email Address * WITHHELD
Complainant Type: * Insured
Insured
Last/Business Name*   PATAKY   First Name   LESLIE
Policy # * SJ30356084 Claim #* SL22217701
Attorney
Attorney is Applicable
Last Name* GRICHENER First Name * ULYANA Initial
Street Address* 800 E BROWARD BLVD, SUITE 510
City, State Zip* HOLLYWOOD , FLORIDA 33001
Email Address * UG@WEKLAW.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   SLIDE INSURANCE COMPANY
NAIC Company Code 17227
 
Name of individual responsible for violation (if any):* PAUL GUNDERSON, MATTHEW ALSTON, ZACHARY MARSTON, KYLE WILLIE
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)(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.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

SECTION I – PERILS INSURED AGAINST A. Coverage A – Dwelling And Coverage B – Other Structures 2. We do not insure, however, for loss: c. Caused by: (6) Any of the following: (a) Wear and tear, marring, deterioration; SECTION I – PERILS INSURED AGAINST A. Coverage A – Dwelling And Coverage B – Other Structures 2. We do not insure, however, for loss: c. Caused by: (6) Any of the following: (f) Settling, shrinking, bulging or expansion, including resultant cracking, of bulkheads, pavements, patios, footings, foundations, walls, floors, roofs or ceilings; B. We do not insure for loss to property described in Coverages A and B caused by any of the following. However, any ensuing loss to property described in Coverages A and B not precluded by any other provision in this policy is covered. 3. Faulty, inadequate or defective: b. Design, specifications, workmanship, repair, construction, renovation, remodeling, grading, compaction; d. Maintenance EXISTING DAMAGE EXCLUSION ENDORSEMENT It is understood and agreed that this policy is not intended to and does not provide coverage for any damages which occurred prior to policy inception. It is also understood and agreed that this policy is not intended to and does not provide coverage for any claims or damages arising out of workmanship, repairs and/or lack of repairs arising from damage which occurred prior to policy inception. It is understood and agreed that this policy does not provide coverage for any stated amount until and unless all structures covered by your previous policy have been fully and completely repaired. Prior to the completion of such repairs, coverage will be limited to the greater of: 1) the actual cash value of the property at the time of a covered loss occurring during this policy period; or (2) the cost of repairing the property to the state at which it existed at the time of a covered loss, provided that such repairs have been made.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

Leslie Pataky (the "Insured") purchased an insurance policy ("Policy") from Slide Insurance ("Slide"), with effective coverage on the date of the loss, on or about September 27, 2022, and policy number SJ30356084 effective from March 1, 2022 to December 21, 2022, to insure his home located at 4408 SW 20th Avenue, Cape Coral Florida 33914 (the "Property"). On or about September 27, 2022, the Property suffered damage as the result of a Hurricane Ian, which caused ensuing damage to the Property, including but not limited to the roof, exterior and interior of the property. The Insured was not at the property during Hurricane Ian but had the property checked out. Roof damage was located and it was immediately repaired for about $600.00. Upon returning to Florida and inspecting the property himself, the Insured realized it was a bigger issue and promptly reported a claim to Slide. Slide acknowledged receipt of the claim on January 28, 2023 by generating claim number SL22217701. On February 2, 2023, Slide had Paul Gunderson, a field adjuster inspect the property. Mr. Gunderson identified Hurricane Ian related damages, took photographs of the property and generated an estimate in the amount of $8,326.48 in Replacement Cost Value / $7,309.73 in Actual Cash Value. Pursuant to a February 4, 2023, final report, Mr. Gunderson did not even get on the roof. The report states verbatim “We inspected the roof from the ladder as best we could, to avoid creating damage to the roof tile.” On February 11, 2023, Slide sent out Matthew Alston of Precision Claim Solutions to inspect the property. Without waiting for Precision Claim Solutions to provide their findings, on February 14, 2023, Slide sent a letter to the Insured opening coverage and making payment for $383.48 (based upon Mr. Gunderson’s estimate of $8,326.48 subject to the policy deductible of $7,943.00). Precision Claim Solutions provided its report to Slide on February 16, 2023. Precision Claim Solutions provided a sourcing report on February 20, 2023 some graveyard/warehouse where one might find replacement tiles for the damaged tiles on the roof. On March 3, 2023, Slide’s estimate with Mr. Gunderson’s name on it was revised by someone to include resetting five trim tiles, not even replacing them. The change to Mr. Gunderson’s estimate went from his initial $8,326.48 in Replacement Cost Value, to $8,696.24. On March 10, 2023, Slide sent a Partial Denial Letter to the Insured. A new payment was being made on the claim for a whopping $969.76. However, Slide was denying “coverage to damaged roof tiles that it asserted were not damaged due to a one-time storm event.” The Insured disagreed with this scope. On March 14, 2023, Slide’s estimate with Mr. Gunderson’s name on it was revised yet again by someone to include the temp roof repair the Insured had completed right after the passing of the Hurricane. The change to Mr. Gunderson’s estimate went from his revised estimate $8,696.24 in Replacement Cost Value, to $9,296.24. No supplemental payment was sent on this yet again revised estimate. Due to Slide’s gross underpayment of the claim, the Insured had no choice but to retain the services of a public adjuster. Guardian Group Claims Consulting LLC submitted their letter of representation, and Slide sent a letter on March 17, 2023, acknowledging receipt of same and requesting an estimate with photos. Guardian Group Claims Consulting LLC promptly provided Slide with an estimate of damages in the amount of $194,779.14, along with photographs of damages and sketches of the property. On April 3, 2023, Slide requested from its TPA Eberl Claims Service LLC to send out a “seasoned” independent adjuster to re-inspect the property based upon the Insured’s public adjuster’s estimate of damages. Thereafter, on or about April 28, 2023, Zachary Marston was sent to inspect the property. Mr. Marston obtained his Texas adjusters license on September 30, 2022 and his non-resident Florida adjuster license also on September 30, 2022. Mr. Marston is the “seasoned” independent adjuster that was entrusted with reviewing a six figure claim. Mr. Marston prepared an estimate with a Replacement Cost Value of $16,606.13. Double the amount of the first (3) THREE estimates prepared by Mr. Gunderson. On May 2, 2023, Slide sent two letters, one denying damage to the roof and one with yet another embarrassing low payment was being made, in the amount of $4,198.74 explanation. As of May 2, 2023 – FIVE MONTHS into Slide’s investigation of the claim, Slide had made a whopping total of $5,551.98 in payments to the Insured. Due to Slide’s continued gross underpayment of the claim, the Insured had no choice but to retain legal counsel and submit a Notice of Intent to Litigate on January 4, 2024. It was not until the Insured put Slide on notice that he will be seeking legal action that Slide on January 15, 2024 sent out a request to Precision Claim Solutions for a comparative roof replacement estimate. It was also the first time that Slide ran a wind report which confirmed 110mph winds at the property. On January 16, 2024, Slide obtained a comparative roof estimate from Precision Claim Solutions but it was not for a roof replacement, it was yet again for 5 tiles. This “comparative was for $2,983.84 – a big difference from the amount Slide had actually paid (Marston’s last estimate allocated $99.22 for those same 5 tiles). This is information Slide had the ability to have before they made the first coverage decision but they chose not to ask Precision for this information when they first retained them. It was at this point that Slide for the very first time sent out a Reservation of Rights Letter, requested documents never asked for before and sought yet another inspection of the property. On February 22, 2024, Slide sent out Lynn Edwards, a general contactor well known for providing expert services primarily only to insurance companies, who then prepared an estimate in the amount of $33,571.93 in Replacement Cost Value. Mr. Edwards’ assignment specifically excluded the roof. This is now double the estimate prepared by Mr. Marston in April 2023. The pattern is clear. Slide had to be pushed and pushed and pushed by its Insured who had dutifully being paying his premiums on time, only to be met with ridiculous coverage amounts of a few hundred to a few thousand at each step his single claim. Each time the Insured pushed back, Slide did a little more investigation and each time Slide found that they underpaid the last time. On February 27, 2024, Slide’s estimate with Mr. Marston’s name on it was revised to include the bid items from Mr. Edwards estimate and the bid amount of roof repair from Precision Claim Solutions. The change in the estimate went from Mr. Marston’s $16,606.13 in Replacement Cost Value, to $43,560.83. When taking into account the deductible of $7,943 and the prior payments of $5,551.98, what was left was $30,065.85. Thereinafter, in mid-March 2024, with explanation or letter of any sort, Slide instead of issuing a supplemental payment on the Replacement Cost Value of $30,065.85, for the first time in its 4th payment to the Insured, Slide chose to now withhold recoverable depreciation of $7,260.05. Recoverable depreciation was not withheld in its prior three minuscule payments. As a result, Slide issued a payment of $22,805.80 after applying the policy deductible of $7,943.00, prior payments of $5,551.98 and recoverable depreciation of $7,260.05. However, this was still only a quarter of the damages the Insured had presented to Slide through his public adjuster. Left with no choice, the Insured filed suit. It is clear through Slide’s handling of this claim, Slide was trying to reduce their contractual obligation by undervaluing the damage to the Insured’s Property from the start, even though the Insured actively provided all proof of claim needed to have his claim evaluated fairly. Slide’s dramatically insufficient coverage decision has resulted in further damages to the Insured by preventing him from returning his property to its pre-loss condition, rather than participating in the settlement process in good faith. As a direct consequence of Slide’s failure to adjust this loss in good faith and pay what it owed under the policy, the Insured is continuing to sustain considerable hardship. Upon information and belief, Slide, as part of its general business practice, initially low-balls its policyholders (as is made evident by the drastic difference between its own adjusters’ first and final estimates). It appears that Slide trains its claim adjusters to overlook and/or turn a blind eye to a number of routine costs that Slide knows most policyholders generally would not know to request but are actually covered under the insureds policy. Moreover, as part of this scheme, after Slide’s one initial low-ball payment – Slide stalls and intentionally delays the claim, changing adjusters, all under the false pretense that it’s “investigating” the claim. Slide has violated Florida Statute § 624.155(1)(b)(1) by continuously not attempting in good faith to settle this claim when it should have done so if it had acted fairly and honestly towards its Insureds. Slide has also violated Florida Statute § 624.155(1)(b)(3) by failing to promptly settle this obviously covered claim to influence settlement in its favor. Despite being presented all the indisputable evidence of the amount of damage sustained by this Property, it is a disgrace that the Insured has been treated in this manner by his insurance company after sustaining an obviously covered loss, submitting to every demand of Slide, and Slide failing to attempt to make a good faith effort to amicably come to a fair resolution. Slide violated Florida Statutes § 626.9541(1)(i)(2) and § 626.9541(1)(i)(3)(b) by Slide making material misrepresentations to the Insured for the purpose and with the intent to settle the claim on less favorable terms than those provided and contemplated by the policy. Slide was informed multiple times of the discrepancies and inconsistencies of the low-ball payments issued to the Insured. While Slide was made aware of this information for the purpose of obtaining the money contractually owed to the Insured under its insurance policy to attempt to return his home to its pre-loss condition in a timely fashion, Slide accepted that information and has used it to play the delay game with the Insured, knowing all too well the additional damage and hardship that was being placed on the Insured by its actions. Slide violated § 626.9541(1)(i)(3)(a) when it failed to adopt and implement standards for the proper investigations of claims. Under no circumstances is there an excuse for the lack of a proper investigation in this case. Slide and their representatives are willfully blind and grossly underqualified to handle a loss such as the one sustained by the Insured. As is evident by the various adjusters sent out who at each turn would add a little bit more damage to their estimates. In addition, after being placed on notice as to the blatant underpayment of the Insured’s claim, Slide has yet to rectify their actions and do right by the Insured by paying the money that he is contractually owed. Slide violated § 626.9541(1)(i)(3)(c) by failing to acknowledge and act promptly upon the communications with respect to the claim. A number of letters were sent to the Insured advising that an estimate was attached, however not all letters attached said referenced estimates. There has yet to be significant action taken by Slide to this date, despite Slide being presented with the flawed rationale behind their underpayment of the Insured’s claim. The Insured has more than complied with each and every request and there has still been no action by Slide. In the event Slide needs additional information, they have failed to promptly notify the Insured in a timely manner. This pattern of behavior is perpetuated by Slide and their representatives undeterred by the Ethical Requirements that are imposed by law on all Adjusters. Fla. Admin. Code Ann. R. (3) explicitly states the adjustment of insurance claims engage the trust of the public, and therefore, an adjuster has a duty of fair and honest treatment of the Insured throughout the insurance claim process. Several duties and responsibilities to the Insureds were violated in the handling of this claim, which are specifically listed responsibilities of an Adjuster in the Florida Administrative Code. These breached duties and responsibilities include adjusters from Slide approaching the investigation and settlement in a manner prejudicial to the Insured, failing to allow a fair settlement with the Insured, and acting with due diligence in achieving a proper disposition of the claim. In contrast to the legislative intent motivating the enumeration of an Adjuster’s responsibilities outlined in the Administrative Code, the Insureds were not afforded the professional duties entrusted on Slide by the public. To date, Slide has failed to adequately compensate the Insured for the damage that occurred on September 27, 2022. As a direct result of Slide’s delay, the Insured was forced to seek the help of legal counsel to assist him. Due to the amount of time that has passed since the date of loss, this acknowledgement is evidence that Slide knowingly and intentionally are delaying the claims process to further disadvantage the Insureds. The financial detriment caused to the Insureds is a direct result of Slide’s reckless delay of the claim process. The Insured is a dutiful customers who made it a priority to pay his insurance premiums to ensure that in such an event as this devastating incident, his home would be covered. The Insured timely filed his claim and fulfilled all of his post-loss obligations. All requested information and documentation have been turned over to Slide and their representatives promptly by the Insured. However, Slide failed at every step of the process to adequately establish or identify the basis of its gross mismanagement of the claim, failed to inform the Insureds how they may remedy any deficiencies in their claim, and failed to provide them with qualified representatives to ensure the claim was initially adjusted, evaluated, and estimated properly. To deny the Insured the benefit of his bargain after he has satisfied all of his obligations is morally and ethically reprehensible, and reeks of Unfair Trade Practice. Upon information and belief, the aforementioned actions complained of, among others, were made by Slide so often as to constitute a general business practice, evidencing a motive to enhance Slide’s profits, and designed to cause a detrimental effect to its policy holders. Slide was aware that the Insured damages were covered and took advantage of its Insured in an attempt to force him into an irreparably disadvantaged position, which they hope will force the Insured to settle for less coverage than he is contractually entitled to under the policy. This notice is given to perfect the right to pursue the civil remedy authorized by Section 624.155, Florida Statutes, should Slide 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, Slide must: (1) Immediately tender all insurance proceeds due and owing to the Insureds that are fairly owed to the Insureds under the insurance policy that would reasonably place the Insureds back to a pre-loss condition ($194,779.14 subject to policy deductible and prior payments); (2) Agree to reimburse the Insured’s reasonable attorney’s fees and costs for having to become involved to resolve the claim; (3) Agree to reimburse the Insured for interest on the amount of benefits that was found to be due and owing to the Insureds, relating back to the date of loss; (4) Although the Insured has made a demand herein and has previously provided Slide with all the necessary estimates, invoices, receipts, etc. in support thereof, the Insured is still willing to consider and to potentially accept any reasonable counter-offer made by Slide. Therefore, if Slide is not in agreement with the Insured’s reasonable demand for payment of his rightfully owed insurance benefits being submitted at this time, the Insureds hereby requests that Slide now make a reasonable counteroffer before the expiration of the cure period.
Comments
User Id Date Added Comment
lbalik@slideinsurance.com 04-01-2025 Via E-mail & Posting on DFS Website Ulyana Grichener, Esq. Weisser Elazar & Kantor 800 E Broward Blvd., Suite 510 Fort Lauderdale, Florida 33301 ug@weklaw.com RE: Insured: Leslie Pataky Claim No: SL22217701 Policy No: SJ30356084 Date of loss: 9/27/2022 CRN Filing No.: 806721 Dear Ms. Grichener: Please allow this correspondence to serve as Slide Insurance Company’s (“Slide”) response to the Civil Remedy Notice (“CRN”) that was filed on behalf of Leslie Pataky (“Insured”). Herein, we include a brief factual history of the underlying claim and actions by Slide which reveals it has acted properly in responding to the underlying claim and in compliance with its contractual and legal obligations. Slide denies each and every allegation brought forth in the CRN and denies any wrongdoing in the handling of the underlying claim. Additionally, Slide denies violating any Florida Statute or Administrative Code as set forth more specifically herein. Moreover, Slide denies violating any provisions or duties set forth in the applicable policy of insurance. Slide further states that the facts and circumstances that are set forth in the CRN, while incomplete and misleading, do not give rise to any violation of any statute or policy provision referenced in the Notice. Furthermore, Slide challenges the validity of the CRN for not identifying the specific policy language they claim Slide failed to follow. See, e.g., Julien v. United Prop. & Cas. Ins. Co., 311 So.3d 875, 879 (Fla. 4th DCA 2021) (affirming dismissal for civil remedy notice’s failure to either strictly, or substantially, comply with statutory specificity requirement); Demase v. State Farm Florida Insurance Company, 351 So.3d 136, 138-39 (Fla. 5th DCA 2022) (holding that the trial court properly determined that a CRN that failed to state with specificity the relevant policy language was legally insufficient). Finally, the Notice is improper as the Insured failed to establish that Slide breached the policy of insurance, as required by Fla. Stat. § 624.1551. CLAIM FACTS The underlying claim was reported on January 27, 2023 as a claim for damages from Hurricane Ian occurring on September 27, 2022. On February 2, 2023, Slide sent Independent Adjuster Paul Gunderson to inspect the insured property. Based on Slide’s investigation and evaluation of the claim, Slide issued its determination letter, accepting partial coverage for the claim, tendering $383.48 to the Insured. On February 11, 2023, Matthew Alston of Precision Claims Solutions (“PCS”) inspected the roof on behalf of Slide. Wind damage was not found. There were five (5) displaced trim tiles, which were noted to be able to be reset. No damage consistent with wind-borne debris impact was observed. On March 10, 2023, following the inspection by PCS, Slide made a supplement payment to the Insured in the amount of $969.76. On May 2, 2023, Slide made a third payment to the Insured totaling $4,198.74 under Coverage A. On January 4, 2024, the Insured, through their counsel, filed their Notice of Intent to Initiate Litigation (“NOIL”). The NOIL provided an estimate of damages of $186,284.00. In response to the NOIL, Slide invoked mediation. On January 26, 2024, Plaintiff executed a Sworn Proof of Loss (“SPOL”), seeking $194,779.14. On February 16, 2024, Slide made its final payment to the Plaintiff, totaling $22,805.80. The final FA estimate allowed for repairs to the 5 displaced roof tiles, repairs to the exterior and elevations, as well as interior repairs to the dining room, entry/foyer, living room, kitchen, nook, master entry, garage, hallway, and lanai. The estimate totaled RCV $43,560.83. Thereafter, suit was filed. Thus, Slide maintains that it has acted in accordance with the terms of the subject insurance policy, and the law, and has acted in good faith towards the Insured. Slide denies that it violated any statutes or committed the acts asserted in the CRN. Slide neither waives nor is estopped from asserting any and all rights that it may have in law or under the terms of the policy. Slide expressly reserves all such rights without exception or limitation. REASONS FOR THE NOTICE The CRN alleges multiple reasons for the filing of the Notice. However, no specific facts or circumstances are provided to support these allegations. Notwithstanding, Slide denies each and every allegation individually as follows: 1. Claim Delay: Slide denies any delay in the claims handling process of the underlying loss as is evident from the facts outlined above. Slide promptly acknowledged the claim and timely initiated its investigation of the loss including an inspection of the subject property. Slide acted in accordance with its duties and obligations pursuant to the policy of insurance and responded appropriately to information and documentation that was provided. Thus, Slide asserts that this allegation is without basis and therefore denied. 2. Unsatisfactory Settlement Offer: Slide denies that it extended any unsatisfactory settlement offers to the Insured, including multiple payments made to the Insured, prior to suit being filed. Nonetheless, Slide asserts that it has acted in good faith towards its Insured at all times. Thus, this allegation is without basis and therefore denied. 3. Unfair Trade Practice: There is no basis for this allegation, thus it is wholly denied. The Insured has submitted no facts or circumstances to support this allegation. The handling and administration of this claim occurred with the expediency and timeliness allowed by the statutory requirements imposed upon Slide. At no time did Slide, its agents, or its employees delay the handling, administration, or disposition of this claim. The facts show that Slide acted promptly with respect to the investigation of the underlying claim and made communications as necessary to adjust the claim in a prompt and appropriate manner. Information necessary and relevant to the proceeding of the claim was communicated to the Insured or their representatives in an appropriate and timely manner. ALLEGED STATUTORY VIOLATIONS The CRN alleges six (6) statutory violations. However, no specific facts or circumstances are provided to support these allegations. Notwithstanding, Slide denies each and every allegation of statutory violation individually as follows: 1. 624.155(1)(b)(1): Denied. The underlying claim was investigated and adjusted in as thorough and expedient a manner as possible. Following the investigation and evaluation of the underlying claim, multiple payments were tendered to the Insured. Moreover, the Insured has submitted absolutely no facts or circumstances supporting this allegation. 2. 624.155(1)(b)(3): Denied. Slide has not failed to promptly settle the underlying claim. The underlying claim was investigated and adjusted in as thorough and expedient a manner as possible. Accordingly, Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Moreover, the Insured has submitted absolutely no facts or circumstances supporting this allegation. 3. 626.9541(1)(i)(2): Denied. Slide has not made any material misrepresentations to the Insured or any other person having an interest in the proceeds payable under the subject policy for insurance. The underlying claim has been investigated and adjusted in as thorough and expedient a manner as possible. Slide routinely communicated relevant information to the Insureds and/or their representatives. Thus, any such allegation is without merit and unsupported by the facts of the underlying claim. Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Finally, the Insureds have submitted absolutely no facts or circumstances supporting this allegation. 4. 626.9541(1)(i)(3)(a): Denied. This allegation is without basis. Slide has adopted and implemented standards for the proper investigation of claims at all times during the investigation of the subject matter. The aforementioned facts demonstrate that Slide employed proper and customary claims practices in the investigation and adjustment of this claim including, but not limited to, a prompt inspection of the insured property and timely communications with the Insured and their representatives. Accordingly, Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Finally, the Insureds have submitted absolutely no facts or circumstances supporting this allegation. 5. 626.9541(1)(i)(3)(b): Denied The allegation that Slide has misrepresented facts or coverage terms under §626.9541(1)(i)(3)(b) is entirely without merit and basis in fact; the Insureds were fully informed of Slide’s coverage determination(s). Further, this is not pertinent to the claim at hand as no facts have been alleged to support this allegation. This could not be further from the truth. Furthermore, such baseless allegations should be stricken. Slide therefore denies any violation of §626.9541(1)(i)(3)(b). 6. 626.9541(1)(i)(3)(c): Denied. This allegation is without basis. The underlying claim was properly investigated by Slide based upon available information and in a timely manner. Following the findings from its investigation, Slide provided a written explanation of the coverage decision based on the opinions of a hired expert and the limited information provided by the Insured to substantiate their claim, and including the relevant information and policy provisions. The Insured has submitted absolutely no facts or circumstances supporting this allegation. ALLEGED VIOLATIONS OF THE INSURANCE POLICY The CRN fails to allege specific violations of the insurance policy and provides no specific facts or circumstances of wrongdoing. The boilerplate CRN merely sets forth blanket allegations of wrongdoing, without further information. As such, the CRN is defective, as it failed to specifically identify the policy language that is the subject of the alleged violation and further failed to include sufficient facts to put Slide on notice of the alleged violations. Notwithstanding, Slide denies any and all allegations of policy violations. All actions by Slide were done in compliance with the applicable Policy. As indicated above, Slide thoroughly investigated the reported loss including inspection of the Insured’s property. Thus, it is clear that Slide has acted in compliance with the Policy. Slide asserts that it has at all times complied with the terms of the Policy and has complied with all applicable provisions of the Policy and Florida Statutes in the handling of this matter. STATEMENTS AS TO CURING THE DEFECTS OUTLINED IN THE NOTICE The CRN asserts that Slide must “provide a reasonable counteroffer before the expiration of the cure period.” Nevertheless, the method for curing violations alleged in a Civil Remedy Notice is not determined by the Insured. Talat Enterprises, Inc. v. Aetna Casualty Surety Co., 753 So. 2d So. 2d 1278 (Fla. 2000). Accordingly, Florida Statutes Section 624.155 does not impose on an insurer the obligation to pay whatever the Insured’s demand. Section 624.155(2)(d) would have no effect or purpose under such an interpretation. Thus, Slide reasserts that it has acted in good faith towards its Insured at all times. Slide references to all the facts herein, which unequivocally demonstrate Slide’s expedient and timely administration of the Insured’s claim. Slide further asserts its full and strict compliance with the Policy and reiterates that it has acted properly in responding to the underlying claim in compliance with its contractual and legal obligations. Slide denies any wrongdoing in the handling of the underlying claim. Additionally, Slide denies violating any Florida Statute, Administrative Code, or code of ethics. CONCLUSION In conclusion, the documented facts of this claim establish that Slide acted diligently in its claims response and adequately performed its obligations under the policy of insurance and Florida law. Thus, the facts contradict all allegations that Slide has in any manner acted improperly or contrary to its contractual obligations to the Insured in this claim. Herein, Slide has attempted to fully and adequately respond to the allegations the Insured allege in the Civil Remedy Notice of Insurer Violation filed with the Department. Should there be any questions or further inquiry with respect to this matter, please contact the undersigned at (720) 712-0492 or at lbalik@slideinsurance.com. Sincerely, /s/ Lilli S. Balik Lilli S. Balik, Esq. Staff Counsel
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