Civil Remedy Notice of Insurer Violations
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Filing Number:     806760
Filing Accepted:  2/13/2025
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Complainant
Last/Business Name *  
DOUGLAS BROWN   First Name   LYNN BROWN AND
Street Address * 3706 WHIPPOORWILL BOULEVARD
City, State Zip * PUNTA GORDA, FL 33950
Email Address * LYNNBROWN321@GMAIL.COM
Complainant Type: * Insured
Insured
Last/Business Name*   DOUGLAS BROWN   First Name   LYNN BROWN AND
Policy # * 2880849769 Claim #* 01000086890
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*   FIRST PROTECTIVE INSURANCE COMPANY
NAIC Company Code 10897
 
Name of individual responsible for violation (if any):* CHRISTOPHER WYCHE, JAMES KELLER, HERBERT WASHINGTON, GRACE SIMONCA, ROBERT CARRILLO, GRACE SAPP, 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
Unsatisfactory Settlement Offer
Unfair Trade Practice
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 : Intentionally misstating the terms, conditions, and benefits of the insurance policy 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.
626.9541(1)(i)(3)(a) Failing to adopt and implement standards for the proper investigation of 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.

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. 627.4137(1)(e) - Each insurer which does or may provide liability insurance coverage to pay all or a portion of any claim which might be made shall provide, within 30 days of the written request of the claimant, a statement, under oath, of a corporate officer or the insurer's claims manager or superintendent setting forth the following information with regard to each known policy of insurance, including excess or umbrella insurance: a copy of the policy. _____________________________________________________________________________ Reference to specific policy language The violations alleged are statutorily based and do not rely on any specific policy language.
 
* 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 ("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) failing to provide an estimate that complies with the Florida Building Codes; 9) failing to provide a loss run statement; and 10) failing to provide a copy of the insurance policy within 30 days. On or about September 28, 2022, while the subject policy was in full force and effect, the Insured's property was severely damaged by Hurricane Ian. The areas impacted include but are not limited to the roofing system and screen enclosure. The Insured timely submitted a claim on October 30, 2022, to the Insurer for hurricane damage and the ensuing damage therefrom. Thereafter, the Insurer assigned claim number 01000086890 to the loss and sent a field adjuster to inspect the property on November 5, 2022. Then in a letter dated November 8, 2022, the Insurer notified the Insured that it was extending coverage for the loss. However, the Insurer wrongfully determined that it would only require $8,990.28 to restore the insured property to its pre-loss condition. The Insurer's lowball estimate is that of a classic under scope and under value of the claim. Given the vastly underestimated cost of repairs, the Insured's disagreement with the coverage decision, and the scope and nature of the damage resulting from Hurricane Ian, the Insured retained a roofing contractor. After assessing the damage and the true scope of repairs, the roofing contractor produced an estimate identifying $71,722.70 for just a roof replacement. The foregoing estimate and photographs were sent to the Insurer. The Insurer continues to undervalue the loss claiming the Insured's roof simply requires a few replaced tiles rather than a roof replacement. 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. However, when the Insurer conducted its inspection of the insured property, the Insurer's adjuster failed to conduct a thorough and adequate investigation, or the adjuster intentionally ignored the damage observed and failed to make truthful and unbiased reports of the facts after investigating. As a result, the Insurer breached the policy by failing to fully indemnify the Insured for the covered loss. Rather than the Insurer pay for a roof replacement consistent with all laws and ordinances, the Insurer contends the roof is repairable which is not true. All repairs to the roofing system must be done in accordance with applicable Florida Building Codes which require all repairs be done consistent with the manufacturer's specifications and warranties which this Insurer clearly did not account for. The Insurer continued to delay and frustrated the Insured's ability to have his claim adjusted promptly to begin restoring his property by failing to timely provide the Insured with the policy after requested by the Insured through his representatives. The Insured, through his representatives, first requested the policy on January 12, 2023, and sent several follow-up emails to no avail. The policy was not received within 30 days of the first written request of the Insured. Each Insurer which does or may provide liability insurance coverage to pay all or a portion of any claim which might be made shall provide, within 30 days of the written request of the Insured, a statement, under oath, of a corporate officer or the insurer's claims manager or superintendent, a copy of the policy. Fla. Stat. Ann. 627.4137(1)(e). Lastly, 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 12, 2023, 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 an Insurer 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 representatives. Lastly, the Insurer has failed or refused to promptly acknowledge the Insured's communications in an attempt to frustrate and delay the resolution of the Insured's claim. 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. 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 $8,990.28 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. Failing to provide an estimate that complies with the Florida Building Codes 9. Shifting the burden of investigating onto the Insured 10. Conducting inadequate investigations 11. Failing to provide a loss run statement 12. Failing to provide a copy of the insurance policy within 30 days 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 Electronic Mail to the following parties providing them notice of the filing of the civil remedy notice. Please email any response to this civil remedy notice to badfaith@krapflegal.com Via Electronic Mail: Attorney for First Protective Insurance Company d/b/a Frontline Insurance Michael J. Kranzler, Esquire mkranzler@chartwelllaw.com
Comments
User Id Date Added Comment
mkranzler@chartwelllaw.com 02-25-2025 February 25, 2025 VIA E-MAIL: grant@krapflegal.com Douglas Brown c/o Grant W Krapf 2790 Sunset Point Rd Clearwater, FL 33759 Re: Insurer: First Protective Insurance Company Insured: Douglas Brown DFS Filing Number: 806760 Filing Accepted Date: February 13, 2025 Policy Number: 2880849769 Claim Number: 01000086890 To Whom it May Concern: This firm represents First Protective Insurance Company (hereinafter “Frontline”) in connection with a claim submitted by Douglas Brown (hereinafter the “Insured”), following a purported hurricane loss said to have occurred on or about September 28, 2022, as reported to Frontline on or around October 30, 2022. This correspondence shall serve as a formal response by Frontline to the Civil Remedy Notice of Insurer Violation (hereinafter “CRN”), filing number 806760, and associated with policy number 2880849769. Frontline denies each and every allegation brought forth in the CRN and denies any wrongdoing in the handling of this matter. Below, we include a detailed factual history of the claim handling and actions by Frontline which clearly reveals Frontline acted properly in responding to the claim and is in compliance with both its contractual and legal obligations. Frontline would further state that the Complainant’s CRN is defective as it fails to comply with the strict governing requirements contained within Florida Statute Section 624.155. Namely, the statute requires that a CRN shall “state with specificity . . . [t]he facts and circumstances giving rise to the violation.” Fla. Stat. § 624.155(3)(b)2. Under Florida law, a civil remedy notice must state the facts and circumstances that give rise to an alleged violation with such specificity sufficient to allow an insurer to cure any alleged violation within the 60-day statutory period. See Lane v. Westfield Insurance Company, 862 So. 2d 774 (Fla. 5th DCA 2003). The Complainant’s CRN is deficient as the limited self-serving facts and circumstances set forth therein are incomplete and misleading. Additionally, the CRN includes a blanket list of statutory provisions alleged to have been violated. The referenced statutes, however, do not appear to be pertinent to the subject claim, and the CRN fails to specify each statutes’ relative applicability. Further, the CRN does not contain facts addressing and supporting each of the alleged statutory violations against Frontline, but rather sets forth conclusory allegations of purported bad faith. For these reasons alone, the CRN is defective on its face. Furthermore, Frontline notes that this is the fourth CRN filed in this matter, the Insureds’ counsel having previously filed three others with substantially the same allegations. This is notable because it is a pattern and practice of the Insureds’ counsel to file multiple duplicative CRNs, in a clear bad-faith effort to manufacture a basis for a bad faith lawsuit, by hoping that the carrier fails to respond to one of the duplicative CRNs. Frontline would encourage the Department to consider using this particular counsel’s tactic as a guideline for issuing new rules barring this sort of behavior, which is clearly done in bad faith and for no other reason than to attempt to bait the carrier into missing one of the deluge of duplicative CRNs in an effort to manufacture a basis for bad faith litigation. This is a clear abuse of the Department’s resources which requires investigation and intervention. In light of the incomplete, misleading, and/or false allegations set forth in the CRN, Frontline hereby provides the Department of Financial Services with the following facts of the claim that, in and of themselves, disprove all of the allegations brought forth in the CRN. Frontline hereby asserts that all actions taken in the handling of this claim were done so in good faith for the purpose of fair and timely disposition of this matter. CLAIM FACTS The Insured’s property is located at 3706 Whippoorwill Blvd, Punta Gorda, FL 33950-7677. Frontline issued a property insurance policy bearing policy number FPH3-000127320 to the Insured, with effective dates of January 17, 2022 through January 17, 2023. This loss was first reported to Frontline on or about October 30, 2022, as windstorm damage having occurred on or around September 28, 2022 as a result of Hurricane Ian. Frontline immediately acknowledged the claim and began its investigation. An Independent Adjuster inspected the subject property on November 5, 2022, at which time the Independent Adjuster noted a total of 5 damaged shingles across the entirety of the Insured’s roof, as well as minimal damage to the exterior elevations and some interior water damage to the kitchen. The Insured declined to permit an interior inspection to other portions of the subject property. Accordingly, the Independent Adjuster prepared an estimate of covered damages. Based upon the Independent Adjuster’s investigation, Frontline afforded coverage for the loss in the total amount of $8,990.28 in a correspondence dated November 8, 2022, resulting in an ultimate payment to the Insured in the total amount of $1,390.28 after application of the Insured’s $7,600 Hurricane Deductible. In a correspondence to Frontline, the Insureds outright admitted that the roof had minimal damage (in their estimation, “8 tiles to replace and more to be repaired”), but that they were struggling to find matching shingles due to their specific shingles having been discontinued. They subsequently provided an estimate from Mark Kaufman Roofing to replace the entire roof at a cost of $64,350.00. On January 12, 2023, Frontline received a Letter of Representation demanding documentation relating to the Insured’s claim. Frontline immediately acknowledged receipt of the Letter of Representation and advised that it would continue its investigation and adjustment of the claim. In response, the Insured’s counsel first filed a CRN on behalf of the Complainant, and subsequently filed a duplicate CRN on behalf of the Complainant’s wife, Lynn Brown, in a calculated, bad-faith effort to bait Frontline into forgetting to respond to the same allegations a second time and manufacture a basis for litigation. The matter then went into litigation, at which time Frontline filed a Motion for Summary Judgment on the bases that: 1) the insureds failed to present a valid dispute over the actual cash value of the loss; and 2) the insureds failed to demonstrate that they had spent monies and/or incurred expenses in excess of the coverage previously afforded before filing suit. Frontline also served the Insureds with statutory notice of a potential Motion for Sanctions due to these clear violations of Florida law, in response to which the Insureds, through their counsel, voluntarily dismissed the lawsuit without prejudice. The insureds then sought to re-initiate litigation, with the only change being that the insureds submitted a new repair estimate which actually included the Actual Cash Value of the alleged damages, whereas the prior estimate was solely presented on a Replacement Cost Value basis. However, the insureds still failed to provide any documentation as to work performed and/or expenses incurred in excess of the prior coverage afforded before once again initiating litigation. The Insureds’ dispute remains premature, as the insureds’ by and through their counsel (who has engaged in a reckless disregard of the facts of this claim and the legal applicability of same, despite multiple efforts by Frontline to educate her accordingly), have still failed to follow the most basic legal requirements for the presentation of a supplemental claim. The Insureds have recently replaced their roof, but did so during the course of litigation, and pursuant to a contract wherein the scope of the work was supposed to be restricted to that amount which the carrier agreed to. Notably, on September 20, 2024, undersigned counsel spoke on the telephone with counsel for the Insureds, Jessica Fletcher, Esq.. At that time, Ms. Fletcher outright admitted that she knew her lawsuit to be procedurally improper and that it necessitated dismissal but that she could not do so because she had already dismissed the matter once, and a second dismissal would operate as an adjudication on the merits. By the explicit admission of counsel for the Insureds, she knows this lawsuit to be wholly improper, but refuses to perform appropriately merely out of self preservation. There is bad faith in this matter, but it is solely on the part of counsel for the Insureds. The Insureds subsequently filed this CRN, the fourth in this matter. ALLEGED REASONS FOR NOTICE Claim Delay: Frontline denies any claim of claim delay. Frontline promptly and thoroughly evaluated the Insured’s claim, including an in-person inspection of the property by an Independent Adjuster, and prompt evaluation of additional documentation submitted by the Insureds and their representatives and agents. As outlined above, the facts of this claim set forth herein evidence expedient and timely administration of this claim and full and strict compliance with the statutory and contractual requirements imposed upon Frontline. Unsatisfactory Settlement Offer: There is no basis for this allegation, thus it is denied. The Insured submits no facts or circumstances to support this allegation. The handling and administration of this claim occurred with the utmost expediency and timeliness allowed by the statutory and contractual requirements imposed upon Frontline. At no time did Frontline, its agents, or its employees act improperly in the handling, administration, or disposition of this claim. The facts show that Frontline acted promptly with respect to the investigation of the underlying claim. Frontline made all communications required to adjust this claim in a prompt and appropriate matter. Frontline afforded coverage for the actual cash value of direct physical damages observed, and invited the Insureds to follow the legal and contractual processes for submitting a supplemental claim, a process which the Insureds chose to ignore. As outlined above, the facts of this claim set forth herein evidence expedient and timely administration of this claim and full and strict compliance with the statutory and contractual requirements imposed upon Frontline. Unfair Trade Practice: There is no basis for this allegation, thus it is denied. The Insured submits no facts or circumstances to support this allegation. The handling and administration of this claim occurred with the utmost expediency and timeliness allowed by the statutory and contractual requirements imposed upon Frontline. At no time did Frontline, its agents, or its employees act improperly in the handling, administration, or disposition of this claim. The facts show that Frontline acted promptly with respect to the investigation of the underlying claim. Frontline made all communications required to adjust this claim in a prompt and appropriate matter. Rather, the Insureds, by and through their counsel, have repeatedly chosen to ignore Florida law and the plain language of their contract by alleging a dispute which does not yet exist. As outlined above, the facts of this claim set forth herein evidence expedient and timely administration of this claim and full and strict compliance with the statutory and contractual requirements imposed upon Frontline. Not treating the insured with good faith claims conduct: There is no basis for this allegation, thus it is denied. The Insured submits no facts or circumstances to support this allegation. The handling and administration of this claim occurred with the utmost expediency and timeliness allowed by the statutory and contractual requirements imposed upon Frontline. At no time did Frontline, its agents, or its employees act improperly in the handling, administration, or disposition of this claim. The facts show that Frontline acted promptly with respect to the investigation of the underlying claim. Frontline made all communications required to adjust this claim in a prompt and appropriate matter. As outlined above, the facts of this claim set forth herein evidence expedient and timely administration of this claim and full and strict compliance with the statutory and contractual requirements imposed upon Frontline. Looking for ways to deny full recovery to the Insured: There is no basis for this allegation, thus it is denied. The Insured submits no facts or circumstances to support this allegation. The handling and administration of this claim occurred with the utmost expediency and timeliness allowed by the statutory and contractual requirements imposed upon Frontline. At no time did Frontline, its agents, or its employees act improperly in the handling, administration, or disposition of this claim. The facts show that Frontline acted promptly with respect to the investigation of the underlying claim. Frontline made all communications required to adjust this claim in a prompt and appropriate matter. As outlined above, the facts of this claim set forth herein evidence expedient and timely administration of this claim and full and strict compliance with the statutory and contractual requirements imposed upon Frontline. Looking for ways to delay full recovery to the Insured: Frontline denies any claim of claim delay. Frontline promptly and thoroughly evaluated the Insured’s claim, including an in-person inspection of the property by an Independent Adjuster, and prompt evaluation of additional documentation submitted by the Insureds and their representatives and agents. As outlined above, the facts of this claim set forth herein evidence expedient and timely administration of this claim and full and strict compliance with the statutory and contractual requirements imposed upon Frontline. Failing to properly investigate the Insured’s loss: There is no basis for this allegation, thus it is denied. The Insured submits no facts or circumstances to support this allegation. The handling and administration of this claim occurred with the utmost expediency and timeliness allowed by the statutory and contractual requirements imposed upon Frontline. At no time did Frontline, its agents, or its employees act improperly in the handling, administration, or disposition of this claim. The facts show that Frontline acted promptly with respect to the investigation of the underlying claim. Frontline made all communications required to adjust this claim in a prompt and appropriate matter. As outlined above, the facts of this claim set forth herein evidence expedient and timely administration of this claim and full and strict compliance with the statutory and contractual requirements imposed upon Frontline. Failing to provide the Insured with the full benefits awarded under the contract of insurance in a t [sic]: There is no basis for this allegation, thus it is denied. The Insured submits no facts or circumstances to support this allegation. The handling and administration of this claim occurred with the utmost expediency and timeliness allowed by the statutory and contractual requirements imposed upon Frontline. At no time did Frontline, its agents, or its employees act improperly in the handling, administration, or disposition of this claim. The facts show that Frontline acted promptly with respect to the investigation of the underlying claim. Frontline made all communications required to adjust this claim in a prompt and appropriate matter. Frontline afforded coverage for the actual cash value of direct physical damages observed, and invited the Insureds to follow the legal and contractual processes for submitting a supplemental claim, a process which the Insureds chose to ignore. As outlined above, the facts of this claim set forth herein evidence expedient and timely administration of this claim and full and strict compliance with the statutory and contractual requirements imposed upon Frontline. Not training, supervising, or managing adjusters properly so that prompt and full payments are made: There is no basis for this allegation, thus it is denied. The Insured submits no facts or circumstances to support this allegation. The handling and administration of this claim occurred with the utmost expediency and timeliness allowed by the statutory and contractual requirements imposed upon Frontline. At no time did Frontline, its agents, or its employees act improperly in the handling, administration, or disposition of this claim. The facts show that Frontline acted promptly with respect to the investigation of the underlying claim. Frontline made all communications required to adjust this claim in a prompt and appropriate matter. As outlined above, the facts of this claim set forth herein evidence expedient and timely administration of this claim and full and strict compliance with the statutory and contractual requirements imposed upon Frontline. Not adjusting claims and evaluating loss properly: There is no basis for this allegation, thus it is denied. The Insured submits no facts or circumstances to support this allegation. The handling and administration of this claim occurred with the utmost expediency and timeliness allowed by the statutory and contractual requirements imposed upon Frontline. At no time did Frontline, its agents, or its employees act improperly in the handling, administration, or disposition of this claim. The facts show that Frontline acted promptly with respect to the investigation of the underlying claim. Frontline made all communications required to adjust this claim in a prompt and appropriate matter. Frontline afforded coverage for the actual cash value of direct physical damages observed, and invited the Insureds to follow the legal and contractual processes for submitting a supplemental claim, a process which the Insureds chose to ignore. As outlined above, the facts of this claim set forth herein evidence expedient and timely administration of this claim and full and strict compliance with the statutory and contractual requirements imposed upon Frontline. Shifting the burden of insuring the loss to the Insured: There is no basis for this allegation, thus it is denied. The Insured submits no facts or circumstances to support this allegation. The handling and administration of this claim occurred with the utmost expediency and timeliness allowed by the statutory and contractual requirements imposed upon Frontline. At no time did Frontline, its agents, or its employees act improperly in the handling, administration, or disposition of this claim. The facts show that Frontline acted promptly with respect to the investigation of the underlying claim. Frontline made all communications required to adjust this claim in a prompt and appropriate matter. Frontline afforded coverage for the actual cash value of direct physical damages observed, and invited the Insureds to follow the legal and contractual processes for submitting a supplemental claim, a process which the Insureds chose to ignore. As outlined above, the facts of this claim set forth herein evidence expedient and timely administration of this claim and full and strict compliance with the statutory and contractual requirements imposed upon Frontline. Intentionally misstating the terms, conditions, and benefits of the insurance policy to the insured: There is no basis for this allegation, thus it is denied. The Insured submits no facts or circumstances to support this allegation. The handling and administration of this claim occurred with the utmost expediency and timeliness allowed by the statutory and contractual requirements imposed upon Frontline. At no time did Frontline, its agents, or its employees act improperly in the handling, administration, or disposition of this claim. The facts show that Frontline acted promptly with respect to the investigation of the underlying claim. Frontline made all communications required to adjust this claim in a prompt and appropriate matter. As outlined above, the facts of this claim set forth herein evidence expedient and timely administration of this claim and full and strict compliance with the statutory and contractual requirements imposed upon Frontline. Failing to implement proper standards for the adjustment and investigation of claims: There is no basis for this allegation, thus it is denied. The Insured submits no facts or circumstances to support this allegation. The handling and administration of this claim occurred with the utmost expediency and timeliness allowed by the statutory and contractual requirements imposed upon Frontline. At no time did Frontline, its agents, or its employees act improperly in the handling, administration, or disposition of this claim. The facts show that Frontline acted promptly with respect to the investigation of the underlying claim. Frontline made all communications required to adjust this claim in a prompt and appropriate matter. As outlined above, the facts of this claim set forth herein evidence expedient and timely administration of this claim and full and strict compliance with the statutory and contractual requirements imposed upon Frontline. ALLEGED STATUTORY VIOLATIONS The Insured alleges four (4) statutory violations in the CRN, however, no specific facts or circumstances are provided to support these allegations. The CRN is simply a recitation of general, stock allegations of bad faith conduct, conclusory statements of facts not reasonably supported by evidence. Frontline denies each and every allegation of statutory violation individually as follows: 624.155(1)(b)(1): Denied. Frontline has not failed to attempt to settle this claim in good faith and has always acted fairly and honestly towards the Insured. As shown in the above factual summary, the conduct of Frontline following its receipt of the first notice of the loss has complied with all aspects of Florida law. Coverage for this loss was properly denied based upon the inspection of an Independent Adjuster and the consideration of the additional documentation submitted by and on behalf of the Insured. 626.9541(1)(i)(3)(a): Denied. This allegation is without basis. The Insured submitted no facts or circumstances supporting this allegation, simply making conclusory allegations as to the Insured’s disagreement with Frontline’s coverage determination. Frontline has adopted and implemented standards for the proper investigation of claims at all times. 627.444(2)(a): Denied. This allegation is without basis. The Insureds submitted no facts or circumstances supporting this allegation, simply making conclusory allegations. Frontline has adopted and implemented standards for the proper investigation of claims at all times. 627.4137(1)(e): Denied. This allegation is without basis. The Insureds submitted no facts or circumstances supporting this allegation, simply making conclusory allegations. Frontline has adopted and implemented standards for the proper investigation of claims at all times. ALLEGED VIOLATIONS OF THE INSURANCE POLICY The Insureds’ CRN does not reference a single Policy provision, simply stating that “[t]he violations alleged are statutorily based and do not rely on any specific Policy language.” Notwithstanding, Frontline denies violating any provision or duties set forth in the Policy or any statutory obligations, and further asserts compliance with the Policy and all of its provisions and endorsements. Frontline handled the Insured’s claim with diligence and at all times acted fairly in administration of this claim and treated its Insured with honesty and with due regard for her interests. All actions by Frontline were done in compliance with the Policy. Furthermore, with respect to the allegations pertaining to the failure to provide a “loss run” statement, the Insured never made any such request which would trigger an obligation to provide same by Frontline. FRONTLINE DENIES ALL ALLEGATIONS IN THE CRN Frontline hereby denies any and all allegations of bad faith by the Complainant, and states that it has, at all times material, handled and adjusted the Complainant’s claim with the utmost good faith. Any and all allegations of bad faith contained within the CRN are expressly rejected by Frontline. As stated above, the CRN is simply a recitation of general allegations of bad faith conduct, along with a list of statutory violations that are not specifically alleged or described. The CRN is therefore non-compliant with Florida Statute Section 624.155(3), which requires that a civil remedy notice of insurer violation “state with specificity”, inter alia, the facts and circumstances giving rise to the violation and the “specific” language of the subject insurance Policy that is relevant to any alleged violation(s). The Complainant failed to provide any specific and/or accurate facts or circumstances giving rise to the alleged violations in the CRN, and instead alleges a litany of incomplete, misleading, and/or boilerplate allegations against Frontline as alleged acts of bad faith. There are not sufficient references in the CRN to any specific Policy language that is relevant to the allegations of bad faith. Failure to provide such specific reference to Policy language is direct and clear noncompliance with the requirements of Fla. Stat. § 624.155, and renders the CRN deficient on its face, as to form and substance. Accordingly, the CRN does not provide the contemplated and mandated notice of alleged bad faith that is required as a condition precedent to any civil claim for bad faith pursuant to Fla. Stat. § 624.155. For these reasons, the CRN is denied and rejected. Frontline further denies any and all other allegations not specifically addressed in this response related to the above-referenced Civil Remedy Notice. There has been no violation of the referenced statutory sections by Frontline. Rather, the facts of this matter make it exceedingly clear that the Insureds retained counsel(s) are actively engaging in bad faith litigation tactics that merit investigation and intervention by the Department of Financial Services. By responding to the Civil Remedy Notice filed by the Complainant, Frontline neither waives nor abandons, but rather, expressly reserves any and all rights, claims and defenses it has or may have under the terms and conditions of the Policy and applicable Florida law. Herein, Frontline has attempted to fully and adequately respond to the allegations alleged in the CRN. Should the Florida Department of Financial Services have any questions or further inquiry with respect to this matter, please contact the undersigned. Thank you for your time and attention to this matter. Very Truly Yours, CHARTWELL LAW, LLP. ______________________________ Michael J. Kranzler, Esq. cc: Florida Department of Financial Services
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