Civil Remedy Notice of Insurer Violations
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Filing Number:     808186
Filing Accepted:  2/24/2025
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Complainant
Last/Business Name *  
RENAISSANCE CONDO ASSN   First Name   AMY
Street Address * 3401 WINKLER AVE
City, State Zip * FORT MYERS, FL 33916
Email Address * BOGGS-PLEADINGS@BOGGSLAWGROUP.COM
Complainant Type: * Insured
Insured
Last/Business Name*   RENAISSANCE CONDO ASSN   First Name   AMY
Policy # * HCP007506 Claim #* H127257
Attorney
Attorney is Applicable
Last Name* BOGGS First Name * AMY Initial
Street Address* 4554 CENTRAL AVE, STE L
City, State Zip* SAINT PETERSBURG , FL 33711
Email Address * BOGGS-PLEADINGS@BOGGSLAWGROUP.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY
NAIC Company Code 14407
 
Name of individual responsible for violation (if any):* DAVE THURMAN
Type of Insurance * Commercial Property & Casualty   
Reason for Notice *
Claim Delay
Unsatisfactory Settlement Offer
Unfair Trade Practice
Other : gross underevaluation of the loss
Other : failing to respond to proof of loss
* Statutory provision(s) which the insurer allegedly violated.
 
624.155(1)(b)(1) Not attempting in good faith to settle claims when, under all the circumstances, it could and should have done so, had it acted fairly and honestly toward its insured and with due regard for her or his interests.
624.155(1)(b)(3) Except as to liability coverages, failing to promptly settle claims, when the obligation to settle a claim has become reasonably clear, under one portion of the insurance policy coverage in order to influence settlements under other portions of the insurance policy coverage.
626.9541(1)(i)(3)(a) Failing to adopt and implement standards for the proper investigation of claims.
626.9541(1)(i)(3)(c) Failing to acknowledge and act promptly upon communications with respect to claims.
626.9541(1)(i)(3)(d) Denying claims without conducting reasonable investigations based upon available information.
626.9541(1)(i)(3)(e) Failing to affirm or deny full or partial coverage of claims, and, as to partial coverage, the dollar amount or extent of coverage, or failing to provide a written statement that the claim is being investigated, upon the written request of the insured within 30 days after proof-of-loss statements have been completed.
626.9541(1)(i)(3)(f) Failing to promptly provide a reasonable explanation in writing to the insured of the basis in the insurance policy, in relation to the facts or applicable law, for denial of a claim or for the offer of a compromise settlement.
626.9541(1)(i)(4) Failing to pay undisputed amounts of partial or full benefits owed under first-party property insurance policies within 60 days after an insurer receives notice of a residential property insurance claim, determines the amounts of partial or full benefits, and agrees to coverage, unless payment of the undisputed benefits is prevented by factors beyond the control of the insurer as defined in s. 627.70131(5).
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

Loss payment provision of the policy which requires payment of covered losses. Loss payment provision which requires coverage for the cost of reasonable repairs to the property in the event of a covered loss.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

The Renaissance (Fort Myers) Condominium is an upscale condominium community located in Fort Myers, Florida (the “Community”). The Community is comprised of seven (7) residential buildings, carports, a pool area and fencing. The Community is governed and maintained by the Renaissance (Fort Myers) Condominium Association, Inc. ( the “Association”). The Community was severely damaged as a result of Hurricane Ian which barreled through Fort Myers on September 28, 2022. The Association was insured for wind damage with Heritage Property & Casualty Insurance Co. (“Heritage”) for the 4/24/22 to 4/24/2023 policy period (the “Policy”). The Policy includes coverage for the peril of windstorm and covers all of the buildings in the Community. The Association submits this Notice of Violation against Heritage because Heritage has failed and refused to pay the full benefits due under the Policy, has grossly undervalued the claim – paying only $29,519.15 for damage estimated to exceed $1.8 million – has misrepresented the coverage available under the Policy, and has failed to timely communicate with the Association. In sum, Heritage undervalued, delayed, and mis-handled this claim from the outset. The Association timely reported the loss to Heritage and Heritage assigned claim number H127257 to the loss. Heritage took nearly a year before it accepted coverage on 8/22/23 and made a small payment of $29,515.15 for damage to the carports. Heritage closed the claim and refused to re-open the claim after the Association retained a public adjuster and submitted additional documentation of damages. Specifically, the Association through its adjuster has submitted a detailed damage analysis and photos establishing damage in the amount of $1,832,803.26 ACV/ $2,062,162.29 RCV and Heritage refused to tender payment beyond the initial payment of $29,515.15. The Association submitted a Sworn Statement in Proof of Loss to Heritage on September 24, 2024. Heritage still refused to tender additional payment. The Association is seeking damages as follows: Aggregate Total Estimated Damage for Buildings 1-7 $1,755,264.72 ACV/ $1,975,976.81 RCV less Aggregate Deductible for Buildings 1-7 of $518,990.60; Plus Estimated Carport damage total $60,528.54 ACV/ $69,175.48 RCV, reduced to Limits ($41,027.00), less prior payment of $29,519.15; Plus Fence Damage Total $17,010.00 ACV/ $17,010.00 RCV, reduced to Limits ($9,411.00) = $1,257,192.87 ACV/ $1,477,905.06 RCV. Heritage has refused On information and belief, Heritage has engaged in the following behaviors with such frequency that the conduct is a pattern and practice of Heritage: delay, improper adjustment of claims, under-valuation of claims, failure to communicate with insureds, failure to respond to the proofs of loss submitted by insureds, failure to tender undisputed amounts due in a timely manner, and failing to render a coverage determination within a reasonable time period following the loss. This Notice is sent to perfect the Association’s rights under Florida Statute section 624155. In order to cure the defects identified in this Civil Remedy Notice of Insurer Violation, Heritage must tender payment for damage to Buildings 1-7, the fences and the carports in an amount consistent with the insured’s scope of damage.
Comments
User Id Date Added Comment
ncarlisle@heritagepci.com 04-21-2025 April 21, 2025 VIA Certified Mail and e-file submission Florida Department of Financial Services Consumer Assistance, c/o: Civil Remedy Section Larson Building 200 East Gaines Street Tallahassee, Florida 32399-0322 VIA Certified Mail E-mail Correspondence: Boggs-Pleadings@boggslawgroup.com Amy Renaissance Condominium Association c/o Amy Boggs 4554 Central Avenue, Suite L Saint Petersburg, FL 33711 Re: RESPONSE TO CIVIL REMEDY NOTICE Claimant: Amy Renaissance Condo. Assn.(identified in the Policy of Insurance as Renaissance (Fort Myers) Condominium Assoc., Inc.) Policy Number: HCP007506 Claim Number: H127257 Date of Loss (as claimed): September 28, 2022 Loss Location: 3401 Winkler Avenue, Fort Myers, FL 33916 DFS Filing Number: 808186 Date of DFS Acceptance: February 24, 2025 Dear Ms. Boggs and Department of Financial Services, This shall serve as Heritage Property & Casualty Insurance Company’s (“Heritage”) response to the Civil Remedy Notice of Insurer Violation (“CRN”), regarding the claim presented by Amy Renaissance Condo. Assn. (identified in the subject policy of Insurance as Renaissance (Fort Myers) Condominium Assoc., Inc.) or (“Complainant” “Insured’s property” or “Renaissance”) for alleged damages sustained to the subject property on or about September 28, 2022. We are in receipt of a Civil Remedy Notice accepted on February 24, 2025, as submitted to the Florida Department of Financial Services. This shall serve as Heritage’s response to the CRN. While Heritage welcomes the opportunity to respond to this Civil Remedy Notice of Insurer Violation and specifically denies each and every allegation contained in the Civil Remedy Notice (“CRN”) filed in relation to this claim, Heritage believes that the Civil Remedy Notice misstates facts and misrepresents facts, as well as provides information which directly contradicts the alleged violations. For this reason, the Civil Remedy Notice must be rejected and/or Heritage be found NOT to be in Violation document of the subject provisions/statutes identified Florida Statute §624.155(3)(b)(2), requires the Complainant to “describe the facts and circumstances giving rise to the insurer’s violation”, to enable the insurer to investigate and resolve the claim. However, the CRN filed by Renaissance fails to identify the named insured properly, and intentionally excludes important facts, details and dates. To be sure, Heritage does not insure any entity identified as “Amy Renaissance Condo Assn”. It would appear that this CRN was of such little importance to the Complainant, that they did take the time to identify the parties properly. In contrast, Heritage takes these matters seriously and will rely upon facts and information to support denial of any alleged violations, and demonstrate that it handled this claim quickly, efficiently and in good faith compliance with any and all statutes addressed in this matter. In this instance, the subject insurance policy involves insurance coverage to Seven (7) Structures at Renaissance, inclusive of two (2) metal carports, in and around 3401 Winkler Avenue, Fort Myers Florida pursuant to the terms, conditions, duties, exclusions and endorsements of the subject insurance policy. Complainant intentionally fails to include any dates as to when they “timely reported” the claim and fails to specify precisely what they reported as the loss initially. Instead, the Complainant states that they “timely reported the loss”. However, the truth is that the Complainant waited 10 months after Hurricane Ian (9-28-22), reporting a claim to Heritage on 7-27-23. Furthermore, the Complainant intentionally fails to acknowledge that the damages reported to Heritage when the claim was reported was limited to the 2 metal carports. Indeed, when Heritage inspected the property on 7-31-23 (4 days after notification of the loss) utilizing a field adjuster at Advantage Adjustment Group (“AAG”), the property manager in attendance, Lisa Marinello, advised AAG as follows: WE SPOKE WITH MS. LISA MARINELLO, AND SHE STATED THAT AFTER THE STORM THEY HAD THE ROOFS INSPECTED. THE ROOFS WERE NEW AND ONLY NEEDED SOME REPAIRS AND TILES REPLACED. SHE CONFIRMED THEY DO NOT WISH TO CLAIM THE ROOFS, ONLY THE CARPORTS. The Complainant, Renaissance, then issued a bid for replacement of the carports which was dated 10-28-22. For reasons that still remain unknown, Renaissance waited almost 9 months after this proposal was provided to them, to notify Heritage of this carport damage loss. In the CRN, the Complainant incorrectly states “Heritage took nearly a year before it accepted coverage.” THIS IS COMPLETELY AND UTTERLY FALSE. Any delay in in this matter was due solely to the Renaissance’s failure to timely report the claim, and failure to provide Heritage with documentation of the damages it was seeking THAT BEING SAID, Heritage TIMELY prepared an estimate and issued payment via correspondence dated 8-8-23 ( shortly after it was reported 7-27-23) identifying a gross loss of the two carports at $43,934.00, which, after application of $2,051.35 deductible, and subtracting recoverable depreciation in the amount of $11,507.85 (and excess of $855.65), resulted in payment in amount of $29,519.15 for claimed damages CONFIRMED BY RENAISSANCE AS LIMITED TO 2 ALUMINUM CARPORTS. Renaissance then ALLOWS NEARLY A FULL YEAR TO PASS, and on 7-15-24 (11 months and 7 days) Heritage receives only a Letter of Representation and Public Adjuster Agreement from Andrew Knox at Altieri Adjusters. NO OTHER DOCUMENTS WERE PROVIDED. NO ESTIMATE, NO PHOTOS, NO INVOICES and NO other information. In response, the same day, Heritage acknowledged the Letter of Representation and advised that the claim is closed and will remain so pending documentation of damaged[s] not addressed by our settlement. Rather than provide documentation of any damages, the Public Adjuster waited until 10-4-24 to provide a letter dated 9-25-24, and an estimate/other documents via email from Andrew Knox at Altieri Adjusters. By this time over two years had passed since Hurricane Ian, and no supplement documents were provided, and no additional formal requests were made to Heritage after over 24 months had passed since the date of loss for alleged damages (9-28-22 to 10-4-24). Additionally, this newfound information came after Renaissance/Complainant had confirmed to Heritage that no roof damage was being claimed (1 year and 3 months prior). Therefore, Renaissance had now allowed over 2 years to pass and suddenly changed its position to suggest that there was damage to the roof from Hurricane (in direct contradiction and to the prejudice of Heritage as the insurer). Behavior in this fashion is clearly an attempt to preclude timely investigation by an Insurance carrier and avoid timely inspection closer to the date of loss. It is an intentional effort by Renaissance to affirmatively make statements that it is not seeking damage in an effort to misguide Heritage and play hiding-the-ball tactics in an effort to prejudice an insurance carrier. SUCH TACTICS CANNOT BE CONDONED. Indeed, waiting over 2 years to go back on your position, and suddenly pursue a claim for damages to the roof(s) at the property, after CONFIRMING THAT ROOF DAMAGES WERE NOT BEING CLAIMED is disingenuous, inexcusable, improper, and beyond limitations identified by Florida Statutes. To be clear, Heritage did not open coverage for any damages beyond the 2 aluminum carports because nothing else was claimed. The Complainants pursuit of damages to the roof of any of the 7 structures was expressly denied by the Complainant as part of the subject claim. Renaissance intentionally withheld its position, and intentions, in violation of the duties of prompt notice under the subject policy. Further, Renaissance’s failure to timely report the claim within a two-year period precludes the claim both statutorily and pursuant to policy provisions including but not limited to prompt notice. As such, Heritage’s position is that it afforded coverage for a claim in this matter made 10 months after the date of loss by the Complainant (even though they were clearly aware of the damage). Further, the subject claim was limited to 2 aluminum carports based upon Renaissance’s own representations/admissions/confirmations and excludes damage to any other portion of the property. Any failure to pay any claimed additional amounts now being claimed is due to misstatements and the inexplicable untimeliness of the Complainant and its representative, BUT NOT the Insurer, Heritage. It is readily apparent that this Civil Remedy Notice is an attempt to use any manner or fashion to obtain monetary damages utilizing ambiguous, inapplicable and incorrect statements in its CRN, while ignoring the facts that preclude the Complainant from seeking damages due to its own misrepresentations. Heritage’s response to Complainant’s CRN demonstrates that Heritage conducted a thorough investigation of Complainant’s claim, including, but not limited to: (1) assigning an Independent Adjuster to inspect the property; (2) reviewing any and all timely provided information in the best possible position to afford as much coverage and benefits in favor of the insured for damages as the policy affords; (3) and clearly relaying the basis for its determination of coverage consistent with the terms, conditions, endorsements and exclusion of the subject policy of insurance The Complainant’s CRN only sets forth inapplicable, false statements regarding the claim while ignoring both facts and the truth. In its CRN, it is the Complainant who has NOT provided adequate and correct facts, nor provided information or documentation to support a suggestion of improper adjustment of the claim, untimeliness and/or undervaluation pursuant to the subject policy. The only information provided by Renaissance was well after the coverage determinations by Heritage, beyond time limitation set forth by law and subject policy, and after express confirmations that minimal damage had occurred to the roof from Hurricane Ian. Under Florida Law, a Civil Remedy Notice requires the Complainant, “pursuant to section 624.155, F.S., to indicate all statutory provisions alleged to have been violated.” The notice filed in this matter alleges Heritage Property & Casualty Insurance Company violated the following statutory provisions: 1. 624.155(1)(b)(1): Not attempting in good faith to settle claims when, under all circumstances, it could and should have done so, had it acted fairly and honestly toward its insured and with due regard for his or her interests. Response: Heritage denies the allegations contained herein. As indicated by the facts stated above, Heritage has at all times acted fairly and honestly toward the Complainant. Heritage promptly investigated and adjusted the Complainant’s Hurricane Ian claim and issued and explained its coverage determination to the Complainant. 2. 624.155(1)(b)(3): Except as to liability coverages, failing to promptly settle claims, when the obligation to settle a claim has become reasonably clear, under one portion of the insurance policy coverage in order to influence settlements under other portions of the insurance policy coverage. Response: Heritage issued payment under the policy of insurance for damages claimed to the Two (2) Aluminum Carports after application of the Hurricane Deductible provided proper payment. The Complainant fails to identify or describe any facts and/or circumstances regarding the failure to settle a claim by Heritage, NOR do they properly identify that the “reported loss” was identified ONLY as damage to the 2 Aluminum Carports. In this instance, Heritage issued payment based upon the subject policy of insurance and its thorough investigation of the claim for damage to 2 aluminum carports. The Complainant made no other timely communications with Heritage. When the Complainant changed position in direct contradiction to previous representations, over 2 years had passed since the alleged date of loss. The CRN fails to identify any portion of the subject insurance policy which affords more coverage than that which was timely claimed. There is no support for this assertion, and Heritage’s response to the CRN, as well as the facts above demonstrate that Renaissance’s unfounded and incorrect allegations are false and without merit. 3. 626.9541(1)(i)(3)(a): Failing to adopt and implement standards for the proper investigation of claims. Response: The Complainant fails to describe any facts and/or circumstances regarding the failure to adopt and implement standards for the proper investigation of claims. There is no support for this assertion, and Heritage’s response to the CRN, as well as the facts above demonstrate that the Complainants’ unfounded and unsubstantiated allegations are false and without merit. Heritage completed thorough investigations of the reported claim for 2 aluminum carports after Express Confirmation by Renaissance that the Roof(s) were minimally damaged and were not being claimed. Heritage timely issued coverage determinations with attached detailed estimates and detailed reports. 4. 626.9541(1)(i)(3)(c): Failing to acknowledge and act promptly upon communication with respect to claims. Response: Heritage issued payment under the policy of insurance for damages claimed to the Two (2) Aluminum Carports after application of the Hurricane Deductible provided proper payment. The Complainant intentionally did not include dates in this CRN because Heritage acted promptly, but the Complainant did not. Here, the Complainant waited 10 months after Hurricane Ian to report a claim for damage from Hurricane Ian on 7-27-23. Heritage inspected the property 4 days later and issued a timely determination of coverage as identified in its response to the CRN above. In this instance, Heritage timely issued payment based upon the subject policy of insurance and its thorough investigation of the claim for damage to 2 aluminum carports. The Complainant made no other timely communications with Heritage. When the Complainant changed position in direct contradiction to previous representations, the Complainant had waited over 2 years since the alleged date of loss. There is no support for this assertion, and Heritage’s response to the CRN, as well as the facts above demonstrate that Renaissance’s unfounded and incorrect allegations are false and without merit 5. 626.9541(1)(i)(3)(d) Denying claims without conducting reasonable investigations based upon available information. Response: This claim is completely unsubstantiated and inapplicable. Heritage did not deny this claim. Heritage denies the allegations contained herein. The Complainant failed to make any other timely claims and expressly confirmed they did not wish to claim any roof damage only the carports at the Subject Property. Heritage expressly relied upon this information for its coverage determinations and communicated/provided this information to Renaissance clearly and concisely. Heritage is not responsible for the Complainants untimely change of position. There is no failure by Heritage. 6. 626.9541(1)(i)(3)(e) Failing to affirm or deny full or partial coverage of claims, and, as to partial coverage, the dollar amount or extent of coverage, or failing to provide a written statement that the claim is being investigated, upon the written request of the insured within 30 days after proof of loss statements have been completed Response: This claim is completely unsubstantiated. Heritage denies the allegations contained herein. Specifically, the Coverage Determination timely provided and dated 8-8-23 provided expressly as follows: This inspection was completed on July 31, 2023. Per your confirmation, no other loss is being claimed outside of the carports. Heritage has been notified that the condo building roofs incurred minor damage and this damage has been spot repaired; this roof damage is not being claimed. There was wind damage found to the carports. From the damages observed and afforded coverage, our adjuster prepared an estimate totaling $43,934.00 which exceeded the coverage limit for the scheduled carports. Under separate cover, we will be issuing a settlement check in the amount of $29,519.15. The financial breakdown is as follows: Location 1 Building 7 - Carports Dwelling / Structure $ 43,934.00 “Other” Structure(s) $ 0.00 Other Damages $ 0.00 Gross Loss $ 43,934.00 Less Recoverable Depreciation $ 11,507.85 Less Deductible $ 2,051.35 Less Excess $ 855.65 Less Previous Payments $ 0.00 NET AMOUNT PAID $ 29,519.15 The Complainant expressly confirmed no other damages but operated in a fashion to preclude full and complete investigation by its misrepresentations. That said, Complainant failed to identify its change of position within a 2-year period by its own behavior and activity. 7. 626.9541(1)(i)(3)(f) Failing to promptly provide a reasonable explanation in writing to the Insured of the basis in the insurance policy in relation to the facts or applicable law for denial of a claim or the offer of a compromise settlement Response: Heritage denies the allegations contained herein. As with the previous assertion of violation, this assertion is absurd and intentionally ignores the facts, and the Complainant expressly confirmed no other damages, but operated in a fashion to preclude full and complete investigation by its misrepresentations. That said, Complainant failed to identify its change of position within a 2-year period by its own behavior and activity. Heritage has, at all times, acted fairly and honestly toward the Complainant and in conformance with the any and all portions of the Insurance policy. By Contrast, the Complainant operated in violation of the policy regarding cooperation and good faith dealing. 8. 626.9541(1)(i)(4) Failing to pay undisputed amounts of atrial or full benefits owed under first-party property insurance policies within 60 days after an insurer receives notice of a residential property insurance claim, determines the amounts of partial or full benefits, and agrees to coverage unless payment of the undisputed benefits is prevent by factors beyond the control of the insurer as defined in s. 627.70131 (5). Response: Heritage denies the assertion of this claim as it is completely unsubstantiated and is a completely false assertion where the facts clearly provide otherwise. Complainant reported a loss from Hurricane Ian on 7-27-23 (10 months after Ian). Heritage issued its Coverage Determination timely on 8-8-23, and expressly provided as follows: This inspection was completed on July 31, 2023. Per your confirmation, no other loss is being claimed outside of the carports. Heritage has been notified that the condo building roofs incurred minor damage and this damage has been spot repaired; this roof damage is not being claimed. There was wind damage found to the carports. From the damages observed and afforded coverage, our adjuster prepared an estimate totaling $43,934.00 which exceeded the coverage limit for the scheduled carports. Under separate cover, we will be issuing a settlement check in the amount of $29,519.15. The financial breakdown is as follows: Location 1 Building 7 - Carports Dwelling / Structure $ 43,934.00 “Other” Structure(s) $ 0.00 Other Damages $ 0.00 Gross Loss $ 43,934.00 Less Recoverable Depreciation $ 11,507.85 Less Deductible $ 2,051.35 Less Excess $ 855.65 Less Previous Payments $ 0.00 NET AMOUNT PAID $ 29,519.15 The Complainant expressly confirmed no other damages but operated in a fashion to preclude full and complete investigation by its misrepresentations. That said, Complainant failed to identify its change of position within a 2-year period by its own behavior and activity. As detailed by the facts stated above and herein, Heritage did not violate any of the aforementioned statute sections. Heritage has properly investigated the subject claim and provided a detailed explanation with regards to coverage for same. The purpose of the Civil Remedy Notice is to provide the insurer notice of the issue its insured has with the claim and what it is seeking to remedy that issue. However, it is important to note that Insurers are not required to pay any amount demanded by their insureds to avoid a bad-faith claim. Rousso v. Liberty Surplus Ins. Corp., 2010 U.S. Dist. LEXIS 82328, at *14-15 (S.D. Fla. Aug. 13, 2010). The Florida Supreme Court has held that an insurer's appropriate response to a Civil Remedy Notice filed pursuant to Fla. Stat. 624.155 is “based upon the insurer's good-faith evaluation of what is owed on the insurance contract.” Vest v. Travelers Ins. Co., 753 So. 2d 1270, 1275 (Fla 2000). The Court further stated, “What is owed on the contract is . . . governed by whether all conditions precedent for payment contained within the policy have been met.” Id. For its part, an insurer “must evaluate a claim based upon proof of loss required by the policy and its expertise in advance of a determination by a court or arbitration.” Id. at 1275-76. Heritage has complied, in good faith, with these obligations. This CRN reflects unfounded, blatantly false and mistake filled, factually deficient effort to attack an Insurance Carrier (Heritage). This approach is contrary to the purpose of the statute. The Notice must reflect a good faith effort to inform Heritage of how it has fallen short of its obligations under the policy and what it can do to fix its shortcomings. This CRN is insufficient factually, and as a matter of law. Under § 624.155, Heritage is entitled not only to a clear proposed solution, but also more and accurate details about how Heritage fell short of its obligations to provide any further coverage pursuant to the terms of the insurance agreement. As such, the Notice is deficient, and the Complainant has failed to comply with several conditions precedent to bringing a claim under § 624.155. Heritage denies all allegations contained in the CRN and submits there are no violations. While this response is meant to be comprehensive, Heritage’s response above is based upon the limited information provided in the CRN and the information we have to date. If the Complainant feels that we are not in possession of all the facts, please inform us immediately. Please note that Heritage’s response is not necessarily exhaustive and does not preclude us from asserting any other valid reason for seeking rejection and return of the CRN. Also, this letter or any act or failure to act on the part of Heritage or any agent or representative of Heritage or at law as all such rights and defenses are hereby specifically reserved. We trust that this response addresses the allegations of insurer violation alleged in the Civil Remedy Notice of Insurer Violation. Should you have any questions regarding this matter or need anything further, please do not hesitate to contact the undersigned. Very truly yours, /s/ Kevin J. McAllister Kevin McAllister, Esq.
aboggs@boggslawgroup.com 02-24-2025 This Notice is withdrawn because it contains a typographical error in the Insured's name. A corrected CRN was filed on 2.24.25 - Filing #808190
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