Civil Remedy Notice of Insurer Violations
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Filing Number:     807307
Filing Accepted:  2/18/2025
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Complainant
Last/Business Name *  
ZHU, PU   First Name   HUA, YING
Street Address * 4431 SW 62ND LOOP
City, State Zip * OCALA, FL 34474
Email Address * CCC239187563@YAHOO.COM
Complainant Type: * Insured
Insured
Last/Business Name*   ZHU, PU   First Name   HUA, YING
Policy # * 5561284949W Claim #* 01000107353
Attorney
Attorney is Applicable
Last Name* SULISUFAY First Name * LAURA Initial T.
Street Address* 3411 W. FLETCHER AVE, STE. B
City, State Zip* TAMPA , FL 33618
Email Address * PRESUIT@SULIMARTINEZLAW.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):* DERRICK COLLINS AND ANY OTHER INDIVIDUAL FROM, OR AGENT OF, FIRST PROTECTIVE INSURANCE COMPANY, WHO WAS INVOLVED IN THE CLAIM.
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Claim Denial
Unsatisfactory Settlement Offer
Unfair Trade Practice
Other : Violation of Code of Ethics
Other : Not treating the Insured with good faith claims conduct
Other : Looking for ways to deny full recovery to the Insured
Other : Failing to properly investigate the Insured’s loss
Other : Failing to provide the Insured with the full benefits awarded under the contract of insurance in a t
Other : Not training, supervising, or managing adjusters properly so that prompt and full payments are made
Other : Not adjusting claims and evaluating loss properly
Other : Shifting the burden of insuring the loss to the Insured
Other : Failing to implement proper standards for the adjustment and investigation of claims
* Statutory provision(s) which the insurer allegedly violated.
 
624.155(1)(b)(1) Not attempting in good faith to settle claims when, under all the circumstances, it could and should have done so, had it acted fairly and honestly toward its insured and with due regard for her or his interests.
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)(d) Denying claims without conducting reasonable investigations based upon available information.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

THE POLICY LANGUAGE RELEVANT TO THE VIOLATIONS INCLUDES ALL APPLICABLE LOSS PAYMENT AND COVERAGE PROVISIONS OF POLICY NUMBER 5561284949W, INCLUDING THE DECLARATIONS PAGE AND ALL ENDORSEMENTS TO THE POLICY, WITH RESPECT TO COVERAGES A, B, C, AND D. ADDITIONALLY, ANY SECTIONS RELIED UPON BY THE INSURER IN ITS FAILURE TO FULLY PAY THE CLAIM, INCLUDING THE DUTIES IN THE EVENT OF LOSS PROVISIONS AND THE POLICY'S EXCLUSION OF COVERAGE PROVISIONS. THE VIOLATIONS ALLEGED ARE ALSO 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 has committed the following in handling the insured’s claim: 1. Failing to act in due diligence and good faith to resolve claims 2. Placing the financial interest of the Carrier before that of 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. Shifting the burden of investigating the loss onto the Insured. 10. Misrepresenting the terms of the insurance policy. Hua Zhu and Ying Pu are homeowners with an all-risks insurance policy issued by First Protective Insurance Company (hereinafter “Carrier”),. On or about April 26, 2023, while the policy was in full force and effect, the Insured’s property located at 4431 SW 62nd Loop Ocala, FL 34474 sustained significant damage as a result of a wind/hail driven storm. The insured promptly reported the claim and fully cooperated with the carrier’s investigation. The Carrier assigned claim number 01000107353 to the loss. After reporting the claim, Carrier retained an unqualified and biased field adjuster to adjust the loss. This adjuster had a financial incentive to adjust the loss in a manner that would minimize Carrier’s losses. Instead of adjusting the claim fairly, honestly, in good faith, and with due regard for the Insured’s interest, the adjuster made a conscious effort to ignore evidence of covered losses to the property. Then in a letter dated February 7, 2024, the carrier notified the Insured that it had completed its investigation into the loss and concluded failure to notify Frontline of the loss as soon as possible may have prejudiced our ability to independently confirm the cause, origin, date of loss and duration of the reported damages. 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 the loss, the Insured through its retained representatives disputed the coverage determination and submitted an estimate prepared by Flood, Wind & Fire Public Adjusting Group for $49,314.96, invoice prepared by J & S Air Quality Experts for $2,050.00 and emergency tarping services invoice prepared by TRKSEI Emergency Response Team Inc for the amounts of $4,510.00, $4,547.55 and $5,692.42 which were fair and reasonable assessments of the loss. Worst still, Carrier failed to retain qualified experts necessary to identify the repairs necessary to restore the property to its pre-loss condition within reasonable time. Under the circumstances surrounding this claim, had Carrier acted fairly and honestly toward the Insured and with due regard for the Insured’s interests, Carrier could and should have attempted in good faith to settle this claim. Carrier did not and, instead, dishonestly and unfairly placed its own interests well ahead of those of the Insured. In doing so, Carrier violated Section 624.155(1)(b)(1), Florida Statutes. Carrier’s use of unqualified and bias adjusters, and failure to retain experts necessary to identify the repairs necessary to restore the property to its pre-loss condition evidences Carrier’s failure to adopt and implement standards for the proper investigation of claims in violation of Section 626.9541(1)(i)(3)(a), Florida Statutes. Carrier’s use of unqualified and bias adjusters, and failure to retain experts necessary to identify the repairs necessary to restore the property to its pre-loss condition, evidences Carrier’s failure to conduct a reasonable investigation based upon available information. When applying the facts present here to Florida law, it is clear that Carrier is acting in bad faith. Florida Statute § 624.02 defines insurance as a contract whereby one undertakes to indemnify another or pay or allow a specified amount or a determinable benefit based on determinable contingencies. Inherent is the fact that payment must be made timely and promptly so that insureds may mitigate their damages and be put back into the position they were in prior to the loss as quickly as possible. Carrier has breached this duty by refusing to properly and timely adjust the loss. Moreover, Section 69B-220.201 of the Florida Administrative Code defines Carrier’s adjusters conduct here as an unfair claims settlement practice. Specifically, Section 69B-220.201(3) provides that “[a]n adjuster shall not approach investigations, adjustments, and settlements in a manner prejudicial to the insured” and that “[a]n adjuster shall make truthful and unbiased reports of the facts after making a complete investigation.” As detailed above, Carrier’s investigation and adjustment of this claim was done in a manner prejudicial to Insured, was incomplete, and lacked truthful and unbiased reports of the facts. 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 representatives failed to conduct a thorough and adequate investigation, or the representatives 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. The conduct outlined above is done within the Insurer’s routine course of the business. 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 denied full coverage for the claim. 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: The Carrier has delayed processing the claim, causing frustration and inconvenience to the Insured. 2. Lack of Good Faith Conduct: The Carrier has not treated the Insured with good faith conduct expected when handling claims. 3. Attempt to Reduce Recovery: The Carrier has actively sought ways to minimize the amount owed to the Insured under the policy. 4. Attempt to Deny Recovery: The Carrier has looked for reasons to deny coverage altogether, rather than fulfill its obligations under the policy. 5. Failure to Property Evaluate Loss: Claims have not been assessed accurately or promptly, resulting in delays and incomplete indemnity for the Insured. 6. Inadequate Training and Supervision of Adjusters: The Carrier has not ensured its adjusters are adequately trained to handle claims promptly and fairly. 7. Placing Company Interests over Insured Interests: The Carrier has prioritized its financial interests over the health and safety of the Insured. 8. Failure to Provide Complaint Estimates: Estimates provided by the Carrier do not comply with Florida Building Codes. 9. Shifting Investigation Burden to Insured: The Carrier has unfairly placed the burden of investigating the claim onto the Insured. 10. Conducting Inadequate Investigations: The Carrier’s Investigation into the claim have been insufficient or cursory. Therefore, to cure the defects outlined in this civil remedy notice, the Insurer must: 1. Admit full coverage for the Insured’s loss and tender all additional amounts owed under the Policy for the covered loss to the insured property Please email any responses to this civil remedy notice to presuit@sulimartinezlaw.com A copy of this form submitted to the FDFS has been sent via email to the following parties, providing them notice of the filing of the civil remedy notice: • First Protective Insurance Company via DFS Filing • Claims Department, First Protective Insurance Company, via email; service@flhi.com • Hua Zhu and Ying Pu via email ccc239187563@yahoo.com
Comments
User Id Date Added Comment
kferry@camboferry.com 04-14-2025 April 14, 2025 Via E-Mail Only Hua Zhu and Ying Pu c/o Laura Topalli Sulisufay, Esq. Suli Law 3411 W. Fletcher Ave Ste B Tampa, FL 33618 PRESUIT@SULILAW.COM Re: Matter: Hua Zhu and Ying Pu Date of Loss: April 26, 2023 Claim Number: 01000107353 Policy Number: 5561284949 DFS Filing Number: 807307 Dear Ms. Sulisufay, My firm represents First Protective Insurance Company d/b/a Frontline (“Frontline”) with respect to the above matter. This letter is in response to the Civil Remedy Notice of Insurer Violation with filing number 807307 (“CRN”) you filed on behalf of “HUA,YING ZHU,PU.” As an initial matter, please note that the CRN lists the named insureds as “HUA, YING ZHU,PU” and the policy number as “5561284949W.” Frontline has no records for such named insureds and policy number. However, Frontline issued a policy of insurance bearing policy number 5561284949 (the “Policy”), to the named Insureds Hua Zhu and Ying Pu (the “Insureds”), for the property located at 4431 SW 62nd Loop, Ocala, Florida 34474 (the “Property”). Because Frontline did not issue the policy that was provided to the individuals listed on the Notice, the Notice is not proper. Notwithstanding, and in an abundance of caution, Frontline will respond to the CRN. The CRN is void because it is legally invalid. Beyond that, the allegations in the Notice have no merit. I. The Civil Remedy Notice is legally invalid. The filing of a valid Civil Remedy Notice is a condition precedent to an action brought pursuant to section 624.155, Florida Statutes. Talat Enter., Inc. v. Aetna Cas. & Sur. Co., 753 So. 2d 1278, 1283 (Fla. 2000). Because the statute is in derogation of the common law, it must be strictly construed. Id. “[A]ny statute in derogation of the common law requires strict compliance with its provisions by one seeking to avail himself of its benefits.” Florida Steel Corp. v. Adaptable Devs., Inc., 503 So. 2d 1232, 1234 (Fla. 1986). Section 624.155, Florida Statutes, requires a Civil Remedy Notice to provide specific information to put the insurer on notice of the alleged violation. Additionally, a Civil Remedy Notice must be “specific enough to provide insurers notice of the wrongdoing so the insurer can cure the same within sixty days.” Valenti v. Unum Life Ins. Co. of Am., 8:04CV1615T-30TGW, 2006 WL 1627276, at *2 (M.D. Fla. 2006). Here, the CRN is invalid because it does not contain all the information required by section 624.155. Demase v. State Farm Fla. Ins. Co., 2022 Fla. App. LEXIS 7760 (Fla. 5th DCA 2022). Also, it is invalid because it lacks sufficient specificity to provide notice to Frontline of the alleged wrongdoing, as discussed below. First, the boilerplate CRN lacks sufficient specificity to provide notice of the alleged bad-faith conduct. The CRN lists four (4) different statutes which Frontline allegedly violated. However, the CRN fails to provide any true and relevant facts supporting the alleged violations or relating these alleged violations to the four (4) cited statutes. Because the CRN fails to relate the cited statutes to the alleged violations or provided any facts to support why the Complainant believes Frontline violated the cited statutes, Frontline is unable to properly respond, and the CRN is invalid and should be rejected and returned. Second, the CRN fails to reference the specific policy language relevant to the alleged violation as required by Fla. Stat. §624.155(3)(b)4. Pursuant to Fla. Stat. §624.155(3)(b)4, the CRN must cite the specific policy language that is relevant to the alleged violations. Here, the CRN cites as follows: THE POLICY LANGUAGE RELEVANT TO THE VIOLATIONS INCLUDES ALL APPLICABLE LOSS PAYMENT AND COVERAGE PROVISIONS OF POLICY NUMBER 5561284949W, INCLUDING THE DECLARATIONS PAGE AND ALL ENDORSEMENTS TO THE POLICY, WITH RESPECT TOCOVERAGES A, B, C, AND D. ADDITIONALLY, ANY SECTIONS RELIED UPON BY THE INSURER IN ITS FAILURE TO FULLY PAY THE CLAIM, INCLUDING THE DUTIES IN THE EVENT OF LOSS PROVISIONS AND THE POLICY'S EXCLUSION OF COVERAGE PROVISIONS. THE VIOLATIONS ALLEGED ARE ALSO STATUTORILY BASED AND DO NOT RELY ON ANY SPECIFIC POLICY LANGUAGE. As previously noted, Frontline has no records of a policy bearing the policy number “5561284949W.” Additionally, as previously noted, the CRN lists four (4) different statutes which Frontline allegedly violated but fails to provide any true and relevant facts specific to this claim in support of the alleged violations. Notwithstanding, the CRN is effectively referencing, in generality, nearly every policy provision found in any homeowner’s insurance policy. Therefore, the CRN does not in any way reference the specific policy language alleged to have been violated and the CRN fails to satisfy the statutory requirement that an insured “state with specificity” the policy language and statutory provisions at issue. See Julien v. United Prop. & Cas. Ins. Co., No. 311 So. 3d 875 (Fla. 4th DCA 2021). In turn, this prevents Frontline from addressing any issues regarding the Policy the Complainant alleges to have been violated, which is the underlying purpose of Fla. Stat. §624.155(3)(b)4. The CRN, therefore, is statutorily deficient because it does not comply with the requirements set forth in Fla. Stat. §624.155(3)(b)4. Demase v. State Farm Fla. Ins. Co., 2022 Fla. App. LEXIS 7760 (Fla. 5th DCA 2022). Third, as detailed in section II. of this response, the CRN does not provide any specific supporting facts and merely makes conclusory and inaccurate statements. No specific facts identifying what, if anything, Frontline did or failed to do with regard to the claim were provided. Instead, the allegations are mere self-serving and conclusory statements without substance or relation to any alleged violation or the subject claim. This undermines the purpose of the CRN requirement preventing Frontline from investigating and resolving any of the alleged violations. The failure to provide any specific supporting facts for the allegations renders the CRN invalid. Fourth, the CRN is invalid because it does not list a specific cure for the alleged violations. In Talat, the Florida Supreme Court said that to “cure” a Civil Remedy Notice, an insurer must pay the amount owed pursuant to the express terms and conditions of the policy.” However, the CRN here states, “Therefore, to cure the defects outlined in this civil remedy notice, the Insurer must: 1. Admit full coverage for the Insured’s loss and tender all additional amounts owed under the Policy for the covered loss to the insured property.” No cure amount of any kind is provided, and Frontline is left to guess what would be required to “cure” the alleged violations. It is improper for a civil remedy notice to not contain a cure; therefore, the CRN is invalid. Talat, 753 So. 2d at 1282–83; see also Francois v. Illinois Nat. Ins. Co., 01-CV-8070, 2002 WL 33760405, at *4 (S.D. Fla. 2002) aff'd, 49 Fed. Appx. 290 (11th Cir. 2002). Additionally, the CRN does not list Frontline’s address. See Julien v. United Prop. & Cas. Ins. Co., No. 311 So. 3d 875 (Fla. 4th DCA 2021); Pin-Pon Corp., 500 F. Supp. 3d 1336 (S.D. Fla. 2020). Because the CRN fails to comply with the information requirements promulgated by the Department of Financial Services, it is legally invalid. See Pin-Pon Corp. v. Landmark Ins. Co., 2020 U.S. Dist. LEXIS 100072, *7 (S.D. Fla., June 5, 2020); Julien v. United Prop. & Cas. Ins. Co., 4D19-2763 (September 23, 2020). Again, in serving this response, Frontline reserves all rights under Florida law to be served with a properly completed Civil Remedy Notice that is statutorily compliant. As the CRN fails to strictly comply with the requirements of section 624.155, Florida Statutes, it is legally insufficient and should be rejected. II. The Civil Remedy Notice Lacks Merit The CRN also lacks merit. The subject claim was reported by the Insureds’ public adjuster on December 21, 2023 for alleged wind and hail damage at the subject property allegedly occurring two hundred and thirty-nine (239) days prior on April 26, 2023. Notably, concurrent with the reporting of the subject claim, the Insureds’ public adjuster reported an HVAC leak claim with a date of loss of April 26, 2023. This is in direct contradiction to the Insureds’ following statement: “The insured promptly reported the claim and fully cooperated with the carrier’s investigation.” On December 21, 2023, the same day the Loss was reported, Frontline issued correspondence to the Insureds acknowledging the claim, providing the Insureds with a copy of the Homeowner Claims Bill of Rights, notifying the Insureds of their rights to mediation through the Department of Financial Services, and advising the Insureds of their post loss obligations under the policy. Specifically, Frontline requested the Insureds, within 60 days of its correspondence, submit a Sworn Statement in Proof of Loss that is compliant with the requirements of the Policy, and included a copy of a Sworn Statement in Proof of Loss Form in compliance with the Policy for the Insureds’ completion. Per documents submitted by the Insureds’ public adjuster, the Insureds signed a Sworn Proof of Loss two days before they reported the claim, however, this document was neither notarized nor did it comply with the policy. On the following day, December 22, 2023, Frontline’s adjuster emailed the Insureds and their public adjuster, advising of what can be expected to occur throughout the processing of the claim and requesting the Insureds to keep any and all failed components or parts for inspection. Attached to this email was a copy of the correspondence issued to the Insureds on December 21, 2023, as well as correspondence advising that Frontline’s investigation would proceed under a reservation of rights due to questions of coverage and concerns that the Insureds had failed to comply with their post-loss obligations under the Policy. This same correspondence requested the Insureds’ cooperation with Frontline’s investigation of the claim, pursuant to the Insureds’ post-loss obligations under the Policy, by, among other things, providing all invoices and receipts for work completed to the property, and allowing Frontline to inspect the damaged property. This is contrary to the CRN’s baseless allegation that Frontline violated Florida Statute 626.9541(1)(i)(3)(a) by failing to adopt and implement standards for the proper investigation of claims. Also, on the same day, Frontline’s adjuster attempted to reach the Insureds via telephone as Frontline had not yet received a letter of representation from the Insureds’ public adjuster and left a voicemail. Additionally, the field adjuster left a voicemail with the Insureds’ public adjuster to schedule an inspection of the subject property. Frontline received three invoices from TRKSEI Emergency Response Team Inc. (“TRKSEI”) to allegedly tarp the Insureds’ roof. However, neither TRESKEI nor the Insureds provided photographs to Frontline showing that a tarp was, in fact, ever placed on the Insureds’ roof. In the following days, an independent field adjuster retained by Frontline made multiple attempts to schedule the initial inspection of the Loss through the Insureds and their public adjuster, which was ultimately scheduled for December 28, 2023. On December 28, 2023, the Insured cancelled the initial inspection set for that day as their public adjuster was purportedly on vacation. On December 28, 2023, Frontline acknowledged the public adjuster’s letter of representation. On January 3, 2024, Frontline was finally able to inspect the loss through an independent field adjuster with the Insureds’ public adjuster in attendance. This is contrary to the CRN’s baseless allegations that Frontline violated Florida Statute 626.9541(1)(i)(3)(a) by failing to adopt and implement standards for the proper investigation of claims and Florida Statute 626.9541(1)(i)(3)(d) by denying claims without conducting reasonable investigations based upon available information. The FA did not note any wind created openings and noted that the interior damage was limited to a kitchen ceiling stain before the microwave vent. The PA stated there was no damage in other rooms and refused to allow the FA to photograph the other rooms. Notably, the Insureds later had a mold assessment prepared where the Insureds indicated there was ceiling damage in multiple rooms. As such, this directly contradicts the Insureds’ statements that they cooperated with Frontline’s investigation of the claim. On January 5, 2024, Frontline received an estimate, a photo report, and a “Sworn Proof of Loss” from the Insureds’ public adjuster. The estimate was dated January 4, 2024, alleging $49,314.96 in replacement cost value for a roof replacement, detach and resetting gutters, and interior repairs to the kitchen ceiling. This is contrary to the CRN’s assertion that the Insureds submitted an estimate prepared by their public adjuster due to their disagreement with Frontline’s coverage decision, as one had not even been reached at this time. On January 9, 2024, Frontline’s adjuster emailed the Insureds and their public adjuster advising that Frontline had assigned an engineer to inspect the Loss and requested the Insureds’ participation in a recorded statement. Attached to this email was correspondence from Frontline requesting the Insureds’ cooperation with Frontline’s investigation of the Loss, pursuant to the Insureds’ post-loss obligations under the Policy, by, among other things, providing documents to assist in its investigation. This is contrary to the CRN’s baseless allegations that Frontline violated Florida Statute 626.9541(1)(i)(3)(a) by failing to adopt and implement standards for the proper investigation of claims and Florida Statute 626.9541(1)(i)(3)(d) by denying claims without conducting reasonable investigations based upon available information. As a reminder, pursuant to Fla. Stat. 624.155(5)(b)1: “The insured, claimant, and representative of the insured or claimant have a duty to act in good faith in furnishing information regarding the claim, in making demands of the insurer, in setting deadlines, and in attempting to settle the claim.” Here, the Insureds completely failed to provide the requested information, including a policy compliant Sworn Proof of Loss. On January 11, 2024, the desk adjuster acknowledged the mold assessment documents and responded to the mold assessor that Frontline’s investigation was ongoing. On January 11, 2024, the desk adjuster acknowledged TRKSEI’s documents and responded to TRKSEI that Frontline’s investigation was ongoing On January 16, 2024, Frontline conducted the recorded statement of the Insured, Ying Pu, who advised that the HVAC technician called a service company that came out and said that she may have roofing issues as they saw a spot in kitchen. Ms. Pu advised that she was unsure of the claimed date of loss. She also confirmed she did not take any pictures or videos of any damage after the storm. Specifically, she stated that she did not notice any damage to the ceiling until mid-December when the service technician for her HVAC claim told her about it. On January 18, 2024, Frontline inspected the Loss through an independent engineering firm, with Hua Zhu and the Insureds’ public adjuster in attendance. This is contrary to the CRN’s baseless allegation that Frontline violated Florida Statute 626.9541(1)(i)(3)(a) by failing to adopt and implement standards for the proper investigation of claims and Florida Statute 626.9541(1)(i)(3)(d) by denying claims without conducting reasonable investigations based upon available information. The engineer concluded the following: 1. The moisture-related damage to the kitchen ceiling was consistent with long-term, intermittent moisture exposure from the stove exhaust vent due to excess condensation during periods of occupant use. No evidence of staining was observed on the roof sheathing around the vent; however, staining was observed on the insulation material beneath the vent pipe in the attic. The damage feasibly occurred over a minimum period of months prior to the reported date of loss. No storm created openings to the roof were observed in the vicinity of the ceiling drywall stains. 2. In general, the shingle roof was in fair condition with respect to weathering. 3. No hail-related damage was observed on the roof. 4. No wind-related damage was observed on the roof. 5. Damage to the decorative vent cover and surrounding paint finish was mechanical in nature. No storm related damage was observed at the vent cover. On February 7, 2024, Frontline’s adjuster spoke with the Insureds’ public adjuster over the phone, advising that coverage would be denied as there was no storm created damage and that the interior damage claimed was long-term in nature. On the same day, Frontline issued its coverage determination letter, which denied coverage for the Loss pursuant to the terms, conditions, limitations, exceptions, and exclusions from coverage under the Policy. The coverage determination letter noted the Insureds’ failure to comply with their post-loss obligations under the Policy, which prejudiced Frontline’s investigation of the Loss. The coverage determination letter further explained that based upon the findings of the independent engineering firm, that there was no storm created opening, and that the damage claimed to the interior was long-term in nature. The coverage determination letter further explained that under the Policy, damage due to repeated leakage of water is expressly excluded from coverage regardless of any other cause or event that contributes concurrently or in any sequence to the loss. The coverage determination letter then went on to cite to the applicable language under the Policy. Frontline’s coverage determination was made less than 60 days after the Insureds reported the claim, in direct contravention to the claim delay alleged in the CRN. In fact, any delays were due to the public adjuster’s delays in scheduling the initial inspection and the Insureds’ failures to comply with post loss obligations by failing to respond to Frontline’s multiple requests for information. This is also contrary to the CRN’s baseless allegations that Frontline violated Florida Statute 626.9541(1)(i)(3)(d) by denying claims without conducting reasonable investigations based upon available information, and Florida Statute 626.9541(1)(i)(3)(b) by misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue. On February 21, 2024, your office submitted a Letter of Representation which was acknowledged that same day. With its acknowledgment, Frontline also provided a copy of its denial letter. On March 6, 2024, Frontline emailed a copy of its denial letter to the mold assessor and TRKSEI. On March 20, 2024, Frontline received a call from your office requesting a copy of the previously sent letter of representation acknowledgment letter and denial letter. On the same day, Frontline re-sent those documents to your office. Without complying with their post-loss obligations and providing documents responsive to Frontline’s requests for information or an otherwise compliant Sworn Proof of Loss, on February 18, 2025, the Insureds submitted a Notice of Intent to Initiate Litigation, a Notice of Intent to Initiate Repairs, and this subject CRN. In addition to the various baseless allegations and inaccurate statements of fact noted above, the CRN alleges, without an specific facts in support thereof, that Frontline violated Florida Statute 624.155(1)(b)(1) by 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. Frontline specifically and categorically denies this allegation, along with all the other baseless allegations within the CRN that are not specifically denied herein. On February 28, 2025, Frontline responded to the Notice of Intent to Initiate Litigation standing on its prior coverage denial. In light of Frontline’s investigation, coverage was properly denied for the subject claim, pursuant to the terms, conditions, exclusions, limits and deductible of the Policy. Accordingly, Frontline denies any and all allegations of bad faith in connection with the claim submitted by Hua Zhu and Ying Pu. If you have any questions, please do not hesitate to contact me. Warmest regards, Cambo Ferry, PLLC /s/ Katelyn Ferry, Esq.
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