Civil Remedy Notice of Insurer Violations
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Filing Number:     808678
Filing Accepted:  2/27/2025
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Complainant
Last/Business Name *  
ZAK   First Name   CARISSA AND PAUL
Street Address * 922 EAGLE ISLE COURT
City, State Zip * OSPREY, FL 34229
Email Address * 2PAULZAK@GMAIL.COM
Complainant Type: * Insured
Insured
Last/Business Name*   ZAK   First Name   CARISSA AND PAUL
Policy # * 6864421150 Claim #* 01000127775
Attorney
Attorney is Applicable
Last Name* WEIDNER First Name * KEITH Initial W.
Street Address* 1700 W. MAIN ST., SUITE 100
City, State Zip* PENSACOLA , FL 32502
Email Address * KWEIDNER@TWWLAWFIRM.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):* CHAD PADGETT; IAN SWANSON; TYLETHA BIVENS
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Claim Delay
Unsatisfactory Settlement Offer
Unfair Trade Practice
* Statutory provision(s) which the insurer allegedly violated.
 
624.155(1)(b)(1) Not attempting in good faith to settle claims when, under all the circumstances, it could and should have done so, had it acted fairly and honestly toward its insured and with due regard for her or his interests.
626.9541(1)(i)(2) A material misrepresentation made to an insured or any other person having an interest in the proceeds payable under such contract or policy, for the purpose and with the intent of effecting settlement of such claims, loss, or damage under such contract or policy on less favorable terms than those provided in, and contemplated by, such contract or policy.
626.9541(1)(i)(3)(a) Failing to adopt and implement standards for the proper investigation of claims.
626.9541(1)(i)(3)(b) Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue.
626.9541(1)(i)(3)(c) Failing to acknowledge and act promptly upon communications with respect to claims.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

SECTION I - PROPERTY COVERAGES A. Coverage A - Dwelling 1. We cover: a. The dwelling on the "residence premises" shown in the Declarations, including structures attached to the dwelling; D. Loss Settlement 2. Buildings covered under Coverage A or B at replacement cost without deduction for depreciation, subject to the following: a. If, at the time of loss, the amount of insurance in this policy on the damaged building is 80% or more of the full replacement cost of the building immediately before the loss, we will pay the cost to repair or replace, without deduction for depreciation, but not more than the least of the following amounts: (1) The limit of liability under this policy that applies to the building; (2) The replacement cost of that part of the building damaged with material of like kind and quality and for like use; or (3) The necessary amount actually spent to repair or replace the damaged building. J. Loss Payment We will adjust all losses with you. We will pay you unless some other person is named in the policy or is legally entitled to receive payment. Loss will be payable 60 days after we receive your proof of loss and; SPECIAL PROVISIONS – FLORIDA a. 20 days after we receive your proof of loss in compliance with SECTION I - CONDITIONS, C. Duties After Loss, paragraph 9, and reach written agreement with you; or b. 60 days after we receive your proof of loss in compliance with SECTION I - CONDITIONS, C. Duties After Loss, paragraph 9; and 1) There is an entry of a final judgment; or 2) There is a filing of an appraisal award or a mediation settlement with us. c. If payment is not denied, within 90 days after we receive notice of an initial, reopened or supplemental claim. This Civil Remedy Notice is also grounded in First Protective Insurance Company d/b/a Frontline Insurance’s statutory duty to act in good faith and deal fairly with its insured when handling claims.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

The policyholders, Carissa and Paul Zak (collectively “Zak”), sustained losses to their property located at 922 Eagle Isle Ct., Osprey, FL 34229 caused by and following Hurricane Milton as referenced in this Civil Remedy Notice. Zak timely notified First Protective Insurance Company d/b/a Frontline Insurance (“Frontline”) of the claim. In addition to the damage sustained to Zak’s lanai screen, landscaping, and other items, Zak’s roof suffered extensive hurricane damage to the concrete tiles on the front and rear slopes, leaving broken and shattered tiles throughout the roof as well as lifted and loose tiles that slid down and damaged the tiles beneath them. The right and left elevations of Zak’s roof also suffered multiple cracked and damaged tiles. Frontline’s initial inspection of the property did not result in an accurate or complete estimate of the covered damage. Specifically, Frontline’s estimate did not identify all damage to Zak’s roof and grossly underestimated the cost to restore the roof to its pre-loss condition which could only be accomplished by a roof replacement. During the initial inspection, Frontline’s field adjuster, Ian Swanson, informed the insureds during his inspection that he found broken tiles below loose tiles that were not immediately visible—a finding that would necessitate a roof replacement. Despite this, Frontline chose to prepare and rely on an estimate of only $9,459.56, replacement cost value on the dwelling, that would only allow for an inadequate repair of Zak’s roof and resulted in a determination of the damage that fell below the deductible. As a result, Frontline refused to issue any payment to Zak on this claim that would allow them to repair the extensive hurricane damage to their roof. Frontline’s attempt to avoid its obligation in this manner was wrongful and in violation of Frontline’s contractual and statutory duties to Zak. Distressed by Frontline’s refusal to issue any payment on this claim, Zak engaged several local roofers to inspect their roof and advise on the measures necessary to restore the concrete tile roof to its pre-loss condition. Each of these roofers independently determined Zak’s roof had suffered extensive tile damage necessitating a roof replacement and that due to the age of Zak’s roof, which was built in 2003, the tiles could not be matched because they had been discontinued many years prior. Several contractors refused to even provide Zak a repair estimate stating a repair cannot be done. The roof must be replaced. Frontline’s refusal of the roof replacement was wrongful, in bad faith, and caused unnecessary delay on this claim as well as other harms and losses over and above the amount owed on the policy of insurance. As a result of Frontline’s failure to accurately and timely adjust and pay this claim, its errors and misinformation with respect to the damage to the roof, and its attempts to bully and intimidate Zak into accepting its coverage decision, Zak was forced to incur costs in hiring a reputable, skilled public adjuster to prepare an estimate of the cost to repair the covered damage. Zak’s public adjuster inspected the property and estimated the cost to repair the covered damage at $107,968.31, the majority of which was attributed to the need for a roof replacement. This estimate represents a far more accurate estimate of the cost to repair the entirety of the damage caused to Zak’s home and other structures by wind during the storm. Had Frontline adjusted the claim initially in good faith and in Zak’s best interest, Frontline’s inspection and estimate would have resulted in a fair amount of compensation that would not have forced Zak to have to hire a public adjuster to protect their interests and right to be paid in full on the claim. Zak provided their public adjuster’s detailed estimate and photo report to Frontline in hopes of finally persuading Frontline to allow for the necessary roof replacement. In the estimate, Zak informed Frontline as follows: There is extensive damage to the tiles on the front and rear slopes. In addition to the obvious broken and shattered tiles there are many loose and lifted tiles that have slid down or have damaged tiles below them. During the field adjuster’s inspection he informed the insureds that he found broken tile below loose tiles that were not immediately visible. These tiles were most likely damaged by "chattering" which occurs when high winds repeatedly lift tiles during a hurricane creating a "chattering" noise with the lift causing cracks, chips, and loose tiles. The right and left elevation have multiple cracked and damages tiles as well. Due to the age of the roof the decking does not meet the current nailing code requirements. Due to the amount of tiles damaged a complete re-nail of the roof decking will be necessary. In addition to the re-nail requirement the tiles on the roof are concrete LIFETILES tiles that are no longer manufactured. Contractors who have inspected the roof since the loss have refused to provide a repair estimate for the roof due to the extent of damage. Due to the above reasons complete roof replacement is required. Despite this clear evidence supporting the need for the roof replacement, Frontline has continued in its refusal of the roof replacement. Comparing Frontline’s initial estimate of $9,459.56 to Zak’s public adjuster’s estimate of $107,968.31, Frontline’s estimate amounts to an unacceptable 9%—less than a tenth—of the actual claim value. An estimate this inexplicably low could only have been prepared in bad faith with the goal of undermining the claim value so Frontline could pay less on this claim. Frontline’s conduct in this regard—showing a lack of concern for its inadequate adjustment of this claim and its failure and/or refusal to pay Zak what it knows is the true amount required to repair the property—has been in bad faith. In hopes of finally persuading Frontline to approach this claim in good faith and reassess its position on the roof, Zak submitted a sworn proof of loss for $107,968.31 per Frontline’s requirements supported by Zak’s public adjuster’s estimate and detailed photos showing the damage. Frontline, however, did not give this evidence any meaningful consideration by evaluating the roof damage in good faith and acknowledging the need for a roof replacement. Rather, Frontline chose to go on the attack and issue a reservation of rights to Zak now claiming the condition of the property suggests the damage may not have been caused by the extreme weather event but, rather, by wear, tear, marring, deterioration, settling, shrinking, bulging, or expansion (all excluded causes of damage) which could result in the cracking of bulkheads, pavements, patios, footings, foundations, walls, floors, roofs, or ceilings. Frontline’s decision at this juncture to weaponize its policy provisions in an effort to bully and intimidate Zak was in bad faith. Despite Frontline’s wrongful conduct, Zak’s public adjuster continued its efforts to reach Frontline to discuss the necessary roof replacement during the month of January, 2025 to no avail. Multiple phone calls and emails went ignored and remain unanswered. At one point, after Zak’s public adjuster identified himself over the phone, Adjuster Padgett promptly hung up on him. This occurred during a time when Zak was stressed, worried, and anxious to get repairs underway so the integrity of their home could be restored. Frontline’s willful or careless failure to respond timely to communications, emails, and inquiries from its insured violated both its duty under the policy to timely adjust this claim and its duty under Fla. Stat. § 626.9541(1)(i)(3)(c) to acknowledge and act promptly upon communications with respect to claims. Finally, in late January, as a result of Zak’s persistent and repeated efforts to get Frontline to reevaluate this claim and reassess its coverage decision, Frontline finally agreed to send a field adjuster to collect one of Zak’s roof tiles to obtain an ITEL report. Onsite, Frontline’s field adjuster confirmed Zak’s roof tiles are no longer available as new and have not been manufactured for many years. Despite this, Frontline continued in its efforts to avoid its obligation to extend coverage for Zak’s necessary roof replacement, Frontline has now advised Zak’s concrete tiles are available at a salvage tile yard—commonly referred to in the industry as a “boneyard” for tile—and that the tiles could be reglazed and the roof simply repaired. Frontline’s attempt to source tiles from an old stockpile rather than purchasing new ones and effect a roof repair, as opposed the necessary replacement, will not fulfill Frontline’s obligation to restore Zak’s property to its pre-loss condition because the decking does not meet the current nailing code and a complete re-nail of the roof decking is necessary due to the number of tiles damaged. In addition, salvaged tiles often do not match and result in a patchwork, aesthetically displeasing result that does not result in a restoration of the property to its pre-loss condition. Used tiles can also be more brittle or damaged, leading to future structural and performance issues. In all, Frontline’s attempt to save money on this claim by sourcing tiles from a boneyard to repair a roof that needs to be replaced violates its contractual and statutory duties to Zak to adjust and resolve this claim in good faith in Zak’s best interest. Frontline’s failure and/or refusal to settle this insurance claim when under all circumstances it could have and should have done so had it acted fairly and honestly towards Zak is wrongful conduct. As a result of Frontline’s wrongful conduct, Zak was and still is forced to expend out of pocket monies to submit their insurance claim, e.g., retaining a public adjuster to prepare an accurate estimate and legal counsel to file this Civil Remedy Notice in hopes of finally forcing Frontline to honor its obligations under the insurance policy to pay the entirety of the insurance proceeds due and owing to Zak. Frontline is obligated to Zak to tender all insurance proceeds owing and due so that the necessary repairs can commence. Frontline’s refusal to tender the appropriate amount due has been in bad faith and is a breach of the insurance agreement which requires Frontline to pay timely and promptly so that Zak can mitigate their damages and be put back into the position they were in prior to the loss as quickly as possible. To date, Frontline has failed to timely pay or deny the claim in full in direct violation of Fla. Stat. § 627.70131. Frontline’s actions, in this regard, have been in bad faith. It is clear from Frontline’s failure to issue the benefits owed and its intentional attempt to avoid its full obligations to Zak, that Frontline has engaged in a pattern of fraudulent and dilatory tactics to the prejudice and harm of Zak. To cure the defects outlined in this Civil Remedy Notice, Frontline must: (1) Immediately tender all undisputed insurance proceeds to Zak with statutory interest owed; (2) Act fairly and honestly towards Zak and with due regard for their interest in attempting to settle this claim; (3) Immediately tender all insurance monies due and owing to Zak with statutory interest; and (4) Pay Zak the fair value of their insurance claim. First Protective Insurance Company d/b/a Frontline Insurance’s address is 500 International Parkway, Lake Mary, FL 32746.
Comments
User Id Date Added Comment
gsabatino@whlmlegal.com 04-24-2025 GINA M. SABATINO, ESQUIRE gsabatino@chartwelllaw.com Reply To: Miami Office 100 SE 2nd Street Suite 2150 Miami, FL 33131-5322 Phone: (305) 372-9044 Facsimile: (305) 372-5044 April 24, 2025 SENT VIA ELECTRONIC FILING THROUGH WWW.FLDFS.COM – CIVIL REMEDY SYSTEM Florida Department of Financial Services Attn.: Division of Consumer Services – Civil Remedy Section 200 East Gaines Street Tallahassee, Florida 32399 And VIA E-MAIL: Keith W. Weidner kweidner@twwlawfirm.com Carissa Zak and Paul Zak c/o Keith W. Weidner 1700 W. Main Street, Suite 100 kweidner@twwlawfirm.com Re: Complainant: Carissa Zak and Paul Zak Insurer: First Protective Insurance Company DFS Filing Number: 808678 Filing Accepted Date: 2/27/2025 Policy Number: 6864421150 Claim Number: 01000127775 Date of Loss: October 9, 2024 To Whom It May Concern, This firm represents First Protective Insurance Company d/b/a Frontline Insurance (hereinafter “Frontline”) in connection with a claim submitted by CARISSA ZAK AND PAUL ZAK (hereinafter the “Complainant/s”), following a reported Hurricane Ian loss occurring on or about October 9, 2024. This correspondence shall serve as a formal response by Frontline to the Civil Remedy Notice of Insurer Violation (hereinafter “CRN”), filing number 808678, recently submitted on behalf of CARISSA ZAK AND PAUL ZAK, and associated with policy number 6864421150, claim number 01000127775, and a date of loss of October 9, 2024. Below, we provide Frontline’s response to the above-referenced CRN. Notwithstanding the foregoing, 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 further states 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. 5d DCA 2003). The Complainant/s’ CRN is deficient as the limited facts and circumstances set forth therein are false, incomplete, and misleading. Additionally, the CRN includes a blanket list of five (5) 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 to the facts at issue in the claim. Further, the CRN does not contain facts addressing and supporting each of the alleged statutory violations against Frontline. Rather, the CRN sets forth only stock, conclusory allegations of purported bad faith. For these reasons alone, the CRN is defective on its face. In light of the incomplete, misleading, and 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 date of loss for this claim was October 9, 2024 and was first reported to Frontline on October 21, 2024, as damage to the roof and interior areas of the insured property. Frontline promptly retained an independent adjuster to inspect the property on October 22, 2024 and an engineer to inspect on or about December 12, 2024. Frontline found minimal wind damage to the roof, lanai, and solar panels on the subject property and opened coverage accordingly. The alleged loss fell below the policy’s applicable deductible. Frontline also received a contractor’s estimate from Builder’s Perspective Public Adjusting for $107,968.31 and supporting documentation during this time. This estimate is over-priced, over-scoped, and includes alleged damages not caused by Hurricane Milton. Frontline then sent its coverage determination letter dated February 11, 2025 to the Insureds. Throughout the entire investigation of the claim, Frontline’s representatives, field adjuster, and engineer have been communicating with the Insureds and Insureds’ representative throughout the entire pendency of the claim. Despite the foregoing, the Complainant filed the subject CRN on 2/27/25. As demonstrated by the detailed factual summary above, Frontline has been engaging in a timely, thorough, and good faith evaluation of this claim. As shown, Frontline has, at all times, fully complied with all obligations imposed by the subject Policy and Florida law. ALLEGED REASON FOR NOTICE: Claim Delay: Frontline denies any improper claim delay in the adjustment of this claim as evident from the facts above. Frontline promptly acknowledged the Complainant/s’ claim and timely initiated its investigation of the loss, including an inspection of the subject property, after which FRONTLINE opened coverage for the covered portion of the Complainant/s’ claim. After coverage was opened, the Complainant/s unilaterally procured a grossly over-scoped estimate seeking to maximize recovery for the Complainant/s with no regard to coverage decisions. At all times material hereto, Frontline acted in accordance with its duties and obligations pursuant to the policy of insurance. Unsatisfactory Settlement Offer: There is no basis for this allegation and Frontline denies any allegation pertaining to any unsatisfactory settlement offer with regard to the subject claim. The Complainant/s submit no facts or circumstances to support this allegation. It is clear from the facts outlined herein and handling and administration of this claim occurred with the utmost expediency and diligence 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. FRONTLINE properly inspected, estimated, and made all communications required to adjust this claim in a fair, satisfactory, and appropriate manner. Unfair Trade Practice: There is no basis for this allegation, thus it is denied. The Complainant/s submit no facts or circumstances to support this allegation. At no time did Frontline, its agents, or its employees employ any unfair business practice during the handling, administration, or disposition of this claim. 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, made all communications required to adjust this claim in a prompt and appropriate matter, and was in full and strict compliance with the statutory and contractual requirements imposed upon Frontline. ALLEGED STATUTORY VIOLATIONS The Complainant alleged multiple statutory violations in the CRN; however, no specific facts or circumstances are provided that support those allegations. Notwithstanding, Frontline denies each and every allegation of statutory violation individually as follows: 624.155(1)(b)(1): Denied. 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. Frontline evaluated the claim as promptly as possible under the circumstances and made a coverage determination pursuant to the policy. The Complainant/s were promptly advised of the claim determination, with an explanation of the full basis for coverage and a list of additional documentation which could be provided for additional consideration. 626.9541(1)(i)(2): Denied. This allegation is without basis. Frontline has always been forthcoming in relation to the subject claim and Policy and has not made any material misrepresentation to the Insureds. The aforementioned facts demonstrate that Frontline employed proper practices in the investigation and adjustment of this claim, and in strict compliance with the statutory requirements imposed upon it. Furthermore, the Complainant/s have submitted absolutely no facts or circumstances supporting this allegation. 626.9541(1)(i)(3)(a): Denied. This allegation is without basis. Frontline has implemented standards for proper investigation of the claims regarding insurance policy provisions during the investigation of the claims. The facts demonstrate Frontline employed proper practices and properly communicated regarding facts and policy terms during the investigation and adjustment of this claim, and in strict compliance with the statutory requirements imposed upon it. Furthermore, the Complainant/s’ have submitted absolutely no facts or circumstances supporting this allegation. 626.9541(1)(i)(3)(b): Denied. This allegation is without basis. Frontline has always been forthcoming in relation to the subject claim and Policy and has not misrepresented any facts to the Insureds. The aforementioned facts demonstrate that Frontline employed proper practices in the investigation and adjustment of this claim, and in strict compliance with the statutory requirements imposed upon it. Furthermore, the Complainant/s have submitted absolutely no facts or circumstances supporting this allegation. 626.9541(1)(i)(3)(c): Denied. There is no showing by the Complainant/s’ to support this alleged violation. As shown in the detailed factual summary above, Frontline was completely forthcoming with the Complainant/s,’ properly advising the Complainant/s’ of the applicable coverages at issue and promptly engaged in communications with the Insureds. Complainant/s did not submit any facts or circumstances in support of this alleged violation. Moreover, Frontline asserts its full and strict compliance with the statutory requirements imposed upon it and all duties and obligations set forth in the subject insurance Policy. Frontline also denies any and all statutory violations as pertained to Florida Statute Section 627.70131. ALLEGED VIOLATIONS OF THE INSURANCE POLICY FRONTLINE asserts that the Complainant CRN completely fails to identify any specific policy language that is purportedly relevant to the alleged violations. The Complainant merely references several broad policy sections, without referencing any specific Policy language, and the failure to provide such specific reference to Policy language is a direct and clear noncompliance with the requirements of Fla. Stat. § 624.155, rendering the CRN deficient on its face as to form and substance. Moreover, the Complainant fails to identify the respective relevance of the referenced broad policy sections to the alleged violations. Accordingly, the Complainant failed to provide FRONTLINE with the contemplated notice of the nature of the policy violations being asserted against it. Notwithstanding the foregoing, Frontline denies violating any provision or duties set forth in the Policy and further asserts compliance with the Policy and all its provisions and endorsements. Frontline handled the Complainant claim with diligence and at all times acted fairly in administration of this claim and treated its insureds with honesty and with due regard for their interests. All actions by Frontline were done in complete and strict compliance with the Policy. 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 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, stock 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 simply allege a litany of non-specific, incomplete, misleading, and boilerplate allegations against Frontline as alleged acts of bad faith. Moreover, the Complainant fails to reference any section of the subject insurance policy. The Complainant CRN does not, in any way, identify any provisions of the subject policy that are relevant to the allegations of bad faith. Failure to provide such specific reference to Policy language is direct and clear non-compliance 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. Additionally, as described in detail above, the facts alleged in the CRN are contrary to the facts underlying the subject claim. Frontline further denies any and all other allegations not specifically addressed in this response related to the above-referenced Civil Remedy Notice. In sum, there has been no violation of the referenced statutory sections by Frontline. By responding to the Civil Remedy Notice filed by Carissa Zak and Paul Zak, 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 attention to this matter. Very truly yours, Gina M. Sabatino, Esq. Gina M. Sabatino, Esq. cc: Florida Department of Financial Service
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