Civil Remedy Notice of Insurer Violations
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Filing Number:     808825
Filing Accepted:  2/27/2025
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Complainant
Last/Business Name *  
BEACON WOODS EAST MASTER ASSOCIATION, INC.   First Name  
Street Address * 8700 PAVILION DRIVE
City, State Zip * HUDSON, FL 34667
Email Address * TIM.MILLWOODVILLAGE@GMAIL.COM
Complainant Type: * Insured
Insured
Last/Business Name*   BEACON WOODS EAST MASTER ASSOCIATION, INC.   First Name  
Policy # * 5107586239 Claim #* 05000002536
Attorney
Attorney is Applicable
Last Name* JAMESON First Name * ROBERT Initial E
Street Address* 203 FORT WADE ROAD, SUITE 260
City, State Zip* PONTE VEDRA , FLORIDA 32081
Email Address * ROBERT@WOOLSEYMORCOM.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   FRONTLINE INSURANCE UNLIMITED COMPANY
NAIC Company Code 10074
 
Name of individual responsible for violation (if any):* UNKNOWN – FRONTLINE INSURANCE UNLIMITED HAS NOT ISSUED A COVERAGE DETERMINATION WITHIN 90 DAYS OF THE INSURED REPORTING THE LOSS.
Type of Insurance * Commercial Property & Casualty   
Reason for Notice *
Claim Delay
Other : Unfair trade practice
Unfair Trade Practice
Other : Failure to act on claim
Other : Failure to maintain proper complaint handling procedures
Other : Misrepresenting the insurance policy provisions to the insured
Other : Misrepresenting Florida statutory provisions to the insured
Other : Failure to acknowledge and act promptly upon communications with respect to claims
Other : Denying claims without conducting reasonable investigations based upon available information
Other : Failing to affirm or deny full or partial coverage of claims, and, as to partial coverage, the dolla
Other : Failing to promptly provide a reasonable explanation in writing to the insured of the basis in the i
Other : Failing to promptly notify the insured of any additional information necessary for the processing of
Other : Failing to clearly explain the nature of the requested information and the reasons why such informat
Other : Failing to pay undisputed amounts of partial or full benefits owed under first-party property insura
* Statutory provision(s) which the insurer allegedly violated.
 
624.155(1)(b)(1) Not attempting in good faith to settle claims when, under all the circumstances, it could and should have done so, had it acted fairly and honestly toward its insured and with due regard for her or his interests.
624.155(1)(b)(3) Except as to liability coverages, failing to promptly settle claims, when the obligation to settle a claim has become reasonably clear, under one portion of the insurance policy coverage in order to influence settlements under other portions of the insurance policy coverage.
626.9541(1)(i)(2) A material misrepresentation made to an insured or any other person having an interest in the proceeds payable under such contract or policy, for the purpose and with the intent of effecting settlement of such claims, loss, or damage under such contract or policy on less favorable terms than those provided in, and contemplated by, such contract or policy.
626.9541(1)(i)(3)(a) Failing to adopt and implement standards for the proper investigation of claims.
626.9541(1)(i)(3)(b) Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue.
626.9541(1)(i)(3)(c) Failing to acknowledge and act promptly upon communications with respect to claims.
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)(3)(g) Failing to promptly notify the insured of any additional information necessary for the processing of a claim.
626.9541(1)(i)(3)(h) Failing to clearly explain the nature of the requested information and the reasons why such information is necessary.
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.

A. Coverage - We will pay for direct physical loss of or damage to Covered Property at the premises described in the Declarations caused by or resulting from any Covered Cause of Loss. **** 4. Additional Coverages a. Debris Removal – [W]e will pay your expense to remove debris of Covered Property and other debris that is on the described premises, when such debris is caused by or results from a Covered Cause of Loss that occurs during the policy period. **** Also refer to: Coverage A provision, coverage B provision, coverage C provision, coverage D provision, all additional coverages provisions, all coverages provided by endorsement or rider, the declarations page, loss payment or settlement provision, duties in event of loss policy provision, all terms and conditions of section I of the insurance policy, the insurance policy definitions section, the insurance policy‘s exclusion of coverage provisions, all insurance policy provisions that provide coverage to the insured property, and all policy provisions.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

624.155(1)(a)(1) – violating 626.9541(1)(i) 626.9541(1)(a)(1) -- misrepresenting the terms of an insurance policy. 626.9541(1)(i) -- unfair claim settlement practices. Facts of the case: Frontline Insurance Unlimited (“FRONTLINE”) has committed the following in handling the insured’s claim: 1) failure to pay benefits owed; 2) failure to act in due diligence and good faith to resolve claims; 3) placing the financial interest of the insurer before that of the policy holder and claimant; 4) failure to properly train, evaluate, and manage adjusters retained to represent the policies and procedures of FRONTLINE; 5) looking for ways to delay benefit payments and otherwise “low ball” or “stone wall” claims; 6) looking for ways to deny the insured’s claim; 7) looking for ways to reduce recovery to the insured; 8) failure to perform a reasonable investigation; 9) misrepresenting Florida statutory provisions to its insured; 10) misrepresenting insurance policy provisions to the insured; 11) FRONTLINE has failed and refused to acknowledge coverage and promptly pay the benefits due and owed to the insured; 12) the reasons for this may be attributed to improper training, supervision, and/or motivation of outside adjusters and claims supervisors to promptly and fairly adjust and pay full benefits available to the insured. The insurer may have failed to adopt proper standards of investigation and adjustment of losses or is otherwise not implementing those standards because a proper investigation and full and prompt payment for the loss is not occurring. In Florida, the work of adjusting insurance claims engages the public trust. FRONTLINE has breached this duty by its adjustment of the insured’s claim of loss. FRONTLINE has failed to create and implement adequate guidelines for proper investigation to evaluate claims handling and for training and supervision of employees resulting in violations as set forth above. FRONTLINE has failed and/or refused to thoroughly, accurately, and completely investigate and evaluate the insured’s insurance claim for damages. Despite the insured’s timely notification to FRONTLINE of their insurance claim, FRONTLINE has failed and refused to acknowledge the covered loss and pay all amounts due and owing to the insured under the policy of insurance. Despite the insured’s pleas otherwise, FRONTLINE has failed and refused to acknowledge its obligation to tender all insurance proceed monies due and owing the insured or assist the insured in mitigation of the damages. In exchange for a premium paid by the insured, FRONTLINE issued the subject insurance policy which provided coverage for the insured property for “sudden and accidental physical loss to covered property described in Coverages A and B.” As such, the subject Policy contains coverage for all direct physical losses to the insured property unless the loss is specifically and unambiguously excluded from coverage by the Policy. On or about October 10, 2024, the insured property suffered a windstorm loss (Hurricane Milton) and the insured immediately submitted a claim to FRONTLINE for extensive windstorm damage i.e., storm, wind, rain, and water intrusion damages throughout the insured property. Hence, the insured suffered a substantial loss regarding the real property and continue to suffer such loss. Having suffered such substantial damage, the insured promptly notified FRONTLINE of the loss in an effort to mitigate the current damage and prevent the exacerbation of any additional losses. The desired result did not follow. Since being presented the Insured’s claim, FRONTLINE, has failed to issue a coverage determination within 90 days of the Insured reporting the loss to FRONTLINE. Additionally, FRONTLINE did not promptly inspect the property, waiting at least 60 days to perform an inspection. Ultimately, FRONTLINE has failed and refused to properly investigate and settle the insured’s claim in good faith. The insured has requested that FRONTLINE conduct an investigation, admit coverage, and pay damages; FRONTLINE has failed and refused to do so. In short, FRONTLINE has failed to handle its insured’s claim in good faith in violation of Fla. Stat. 624.155(1)(b)(1), 624.155(1)(b)(3), and 626.9541(1)(i).Therefore, FRONTLINE breached the Policy. Given the extensive nature of the physical damage, the insured retained a loss consultant, AVIVA Insurance Adjusters (“AVIVA”), to perform an investigation and damage evaluation in accordance with industry standards and Florida law. Based on its investigation, AVIVA determined that a windstorm on or about October 10, 2024 (Hurricane Milton) including storm, rain, and wind caused damage to the exterior of the insured property (particularly the roof warranting replacement), creating openings which allowed water to intrude into the interior causing further damage. Moreover, AVIVA determined, taking into account the estimate below, that at least $823,596.42 worth of mitigation, remediation, and repairs would be required to return the property to its pre-loss condition as a result of the loss. Additionally, the insured has incurred costs of $281,529.56 for mitigation and remediation, including tarping of the structure and water and mold remediation. Moreover, the insured has incurred costs of $1,595.00 for repairing the fence. The Insured sent correspondence to FRONTLINE enclosing supporting documentation. To date, FRONTLINE failed and refused to promptly investigate the claim, delaying its investigation by at least 60 days. Additionally, FRONTLINE has failed to issue a coverage determination within 90 days. Therefore, FRONTLINE breached the Policy. In summary, FRONTLINE chose to delay coverage for the insured’s loss. To date, FRONTLINE continues to deny the insured and its insured’s full indemnity for the claim. While FRONTLINE refuses to honor, or even acknowledge, this claim, a jury in Pasco County will likely find FRONTLINE failed to promptly investigate the claim and timely issue a coverage determination in violation of the policy and Florida law. As of today, FRONTLINE has failed and refused to inform the insured of their rights under the policy of insurance and Florida statutes, has improperly delayed the insured’s claim. Indeed, from the time of receiving the claim, FRONTLINE has purposely and maliciously delayed in adjusting the subject claim in an effort to either avoid paying the claim altogether. To date, the insured has made a good faith effort to comply with all of the requirements under the subject policy of insurance, and it is only fair that FRONTLINE do the same. Yet, that is not the case. The insured feels that the insured property is a valuable asset, and, by continuously delaying the proper handling of this claim, FRONTLINE is putting the insured property at risk. As responsible property owners, the insured purchased insurance to protect the property, paid all of the premiums, and have kept up to date with the responsibilities under the policy. Yet, when the insured needed to rely on the insurance because of this unforeseen loss, FRONTLINE turned its back and delayed coverage that the insured is rightfully owed. 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 upon determinable contingencies. Inherent is the fact that payment must be made timely and promptly so that the insured may mitigate their damages to put them back into the position they were prior to loss as quickly as possible. FRONTLINE breached this duty. The actions taken by FRONTLINE in the handling / adjustment of the insured’s claim were willful, wanton, and with complete disregard for the rights of its insured and occur with such a frequency as to indicate a general business practice and are in violation of Fla. Stat. 624.155 and 626.9541. FRONTLINE’S actions amount to but are not limited to the following: 1. Claim delay 2. Unfair trade practice 3. Unfair claim settlement practices 4. Failure to act on claim 5. Failure to maintain proper complaint handling procedures 6. Misrepresenting the insurance policy provisions to the insured 7. Misrepresenting Florida statutory provisions to the insured 8. Failure to acknowledge and act promptly upon communications with respect to claims 9. Denying claims without conducting reasonable investigations based upon available information 10. 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. 11. 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. 12. Failing to promptly notify the insured of any additional information necessary for the processing of a claim. 13. Failing to clearly explain the nature of the requested information and the reasons why such information is necessary. 14. Failing to pay undisputed amounts of partial or full benefits owed under first-party property insurance policies within 90 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 an act of God, prevented by the impossibility of performance, or due to actions by the insured or claimant that constitute fraud, lack of cooperation, or intentional misrepresentation regarding the claim for which benefits are owed. Therefore, to cure the defects outlined in this civil remedy notice, FRONTLINE must: (1): Admit full coverage for the insured’s loss; (2): Tender all insurance monies due and owing to the insured for the loss under the subject Policy; A copy of this form submitted to the FDFS has been emailed and/or uploaded and also printed out and mailed to the following parties providing them notice of the filing of this civil remedy notice: Frontline Insurance Unlimited
Comments
User Id Date Added Comment
steebagy@thetmlaw.com 04-28-2025 April 28, 2025 Electronic Filing Florida Department of Financial Services Consumer Assistance/Civil Remedy Section Larson Building 200 E. Gaines Street Tallahassee, FL 32399-0322 Complainant: Beacon Woods East Master Association, Inc. Policy No.: 5107586239 Claim No.: 05000002536 Date of Loss: Reported as 10/9/24 CRN Filing No.: 808825 Dear Sir or Madam: Please be advised that this law firm represents Frontline Insurance Unlimited Company (“Frontline”) with respect to the above-referenced matter. This is Frontline’s response to the Civil Remedy Notice of Insurer Violations (hereinafter “CRN”) filed by Robert E. Jameson, Esquire in relation to Claim Number 05000002536 (hereinafter “Claim”) under the Commercial Property policy of insurance issued by Frontline to its insured, Beacon Woods East Master Association, Inc. (hereinafter “Insured”) bearing Policy Number 5107886239 (hereinafter “Policy”). The CRN is overbroad, objectionable, legally insufficient, fails to comply with Florida law and otherwise satisfy Florida law and further deprives Frontline of true notice with adequate opportunity to cure. Frontline denies the CRN allegations as set forth herein. The CRN alleges the following unsupported statutory violations: • 624.155(1)(a)(1); • 624.155(1)(b)(1); • 624.155(1)(b)(3); • 626.9541(1)(a)(1); • 626.9541(1)(i); • 626.9541(1)(i)(2); • 626.9541(1)(i)(3)(a); • 626.9541(1)(i)(3)(b); • 626.9541(1)(i)(3)(c); • 626.9541(1)(i)(3)(d); • 626.9541(1)(i)(3)(e); • 626.9541(1)(i)(3)(f); • 626.9541(1)(i)(3)(g); • 626.9541(1)(i)(3)(h); and • 626.9541(1)(i)(4). Frontline denies all allegations contained within the CRN, including but not limited to the above alleged violations of Sections 624.155 and 626.9541, Florida Statutes. In its CRN, the Insured fails to provide specific and sufficient information to support such allegations. Rather, the Insured only provided inaccurate allegations and omissions with no basis in fact or circumstance. The CRN recites the aforesaid 15 statutory provisions allegedly violated without any specificity whatsoever. While there are no specific facts or bases to support any of the alleged violations, it is also noteworthy that Section 626.9541(1)(i)(4), Florida Statutes is wholly inapplicable to the Claim and Policy, further infirming the CRN. The CRN also impermissibly makes legal argument rather than setting forth specific facts as it relates to the unsupported allegations contained therein. Frontline has handled this Claim pursuant to appropriate standards governing the investigation of claims, has acted in good faith, fairly and honestly towards its Insured and with due regard for its interests as well as complied with all other requirements pursuant to Florida law. Further, the CRN is vague and of limited assistance as it asserts conclusory, boilerplate allegations without specific facts. To that end, alleged policy language recited in the body of the CRN is not contained within the Policy issued to the Insured and, rather, appears to be further evidence of boilerplate copy and pasting methodology employed. Thus, it appears that this is a boilerplate CRN meant to harass and obtain some sort of litigation advantage as opposed to be a true embodiment of any real violation. The abusive use of the Civil Remedy process defeats the spirit as well as the intent of the law and should be strongly discouraged. Additionally, the CRN fails to recite particular individuals and all Policy language allegedly relevant to any claimed violation. A Civil Remedy Notice must contain, among other things, the specific policy language that is relevant to the alleged violations, persons most responsible and the facts and circumstances giving rise to the alleged violation. See § 624.155 (3)(b), Fla. Stat. (providing CRN to the Department of Insurance and an authorized insurer must state with specificity the following information: . . . (2) the facts and circumstances giving rise to the violation . . . (4) reference to specific policy language that is relevant to the violation, if any . . . .); Heritage Corp. of South Florida v. Nat ’l Union Fire Ins. Co. of Pittsburgh, 580 F.Supp. 2d 1294, 1299-1300 (U.S. S.D. Fla. 2008). The subject CRN is therefore insufficient as it fails to include names of individuals involved in the alleged the violation or “specific policy language that is relevant to the violation”, in contravention of the governing statute. Id. Additionally, if Frontline allegedly violated specific terms of the insurance Policy as alleged, as noted herein, the subject CRN must include the “terms of the insurance coverage” it has allegedly violated. The CRN fails to include this with respect to all Policy terms allegedly at issue. Furthermore, simply listing what amounts to a Table of Contents of the Policy is insufficient to comply with either the spirit or the letter of the governing law. See Julien v. United Prop. & Cas. Ins. Co., 311 So. 3d 875 (Fla. 4th DCA 2020) (holding insured failed to satisfy the specific requirements that a Civil Remedy Notice identify the specific statute and specific policy provision relevant to the carrier’s alleged violations). Thus, the CRN fails to meet the requirements of the applicable Florida law. See § 624.155 (3)(b), Fla. Stat. Likewise, the allegations in the CRN are inaccurate and are not supported by the subject Policy. Frontline first received notice of the Claim on or about October 12, 2024, and it began its investigation under reservation of rights as set forth by way of correspondence dated October 26, 2024. As part of Frontline’s investigation, on October 12, 2024, Frontline requested the Insured’s execution of a signed, sworn proof of loss (“SPOL”) pursuant to the Policy. Frontline reminded the Insured that the SPOL had been requested, including by way of correspondence dated October 26, 2024, December 9, 2024, and March 26, 2025. The Policy required return of the SPOL within 60-days, that being, on or before December 11, 2024. However, the CRN omits that it was not until April 7, 2025, that you returned the SPOL; this is untimely under the Policy. Additionally, the late SPOL identifies and is addressed to Universal Property & Casualty Insurance Company, not Frontline. The Insured’s delay in providing the SPOL was beyond Frontline’s control. Also, as part of its investigation, contrary to the CRN allegations, Frontline conducted its initial field inspection on or about October 23, 2024. Said inspection revealed that carpeting had been removed from various areas, including the common area and meeting room, without it being retained for Frontline’s inspection. The CRN omits that the Insured substantially changed property conditions before Frontline was afforded an opportunity to inspect. The roof had tarping at the time of Frontline’s initial inspection by the vendor hired by the Insured, Storm Masters Emergency Response (“Storm Masters”); therefore, Frontline was unable to view the tarped portion of the roof at that time. Photographs of the roof prior to tarping were requested, including by way of correspondence dated October 26, 2024. The CRN omits that, to date, the Insured has failed to provide Frontline with photographs evidencing these conditions prior to tarp installation. To further aid Frontline with its investigation, Frontline retained a Building Consultant with Keystone Experts + Engineers (“Keystone”) to estimate any covered damage and, and Root Cause Consulting to determine the cause, origin and duration of the reported damage. The consultants’ inspections took place on December 1, 2024, and January 24, 2025, respectively. Extensive demolition had occurred at the property prior to completion of inspections. This fact is also omitted by the CRN. Root Cause Consulting concluded that exterior damage from elevated winds associated with either Hurricane Helene or Hurricane Milton consisted of a broken exterior window pane on the south side of the first story, the door at the rear of the building in the northeast corner of the great room, and 25 square feet of shingles on the two-story roof along with 10 square feet of shingles on the gym roof both of which were less than 1% of the overall roof sections and, therefore, repairable. No damage was found to the tower roof or porte cochroof. Other than the broken glass pane in the south window, none of the remaining windows exhibited displaced, deflected, or dented framing. No damage was noted to the dormer window. Although the carpet was removed from the room that the above noted door provided access to and no photographic evidence prior to removal was provided, Frontline’s investigation determined it was reasonable to conclude the carpet was damaged when the door came open during the storm. Frontline’s investigation also determined that it was reasonable to conclude that the three leaning street lighting poles around the tennis court were damaged by elevated winds during the storm. As such, Frontline determined the Policy afforded coverage for these damages for which the Insured has been indemnified for. The CRN is further misleading and omits that the Insured’s public adjuster’s estimate prepared by Aviva Insurance Adjusters Corporation, referenced within the CRN, was not provided to Frontline at the time the CRN was filed or any time prior thereto. Rather, Frontline received that estimate for the first time on or about March 17, 2025; it included a claim for full roof replacement. Another estimate prepared by LSC Construction Consultants was provided by the public adjuster for the first time on or about April 1, 2025, also alleging roof replacement. In light of the damages being claimed, Frontline retained AKG Roofing & Specialty Services, Inc. (“AKG”) who re-inspected the insured building on or about April 21, 2025. AKG determined that roof conditions related to reported cause of loss or that could not ruled out as related to the storm were repairable. Frontline’s investigation ultimately determined that damages covered by the Policy totaled $43,111.75 resulting in collective total net payments of $8,885.06 to the Insured pursuant to the Policy after application of depreciation and the applicable deductibles, that being the $30,604.23 Hurricane Deductible and $420.00 Hurricane Special Class Deductible for Light Pole Coverage. Frontline directs the Insured to its prior communications sent to it regarding Frontline’s coverage position and corresponding estimates prepared by Keystone and AKG, including correspondence dated March 26, 2025, and April 25, 2025, along with any enclosures, all of which speak for themselves and are incorporated by reference. AKG’s inspection revealed additional unrelated damage to the insured building’s shingle roof caused by Storm Masters faulty, inadequate or defective workmanship, repair or construction associated with the tarp installation that was underway prior to Frontline’s inspection and reflected in the vendor’s photographs dated on or about October 25, 2024. Storm Masters nailed tarps into the roof shingles and through the wood decking. This workmanship, repair or construction methodology employed by the vendor was faulty, inadequate or defective, as determined by AKG and contrary to proper tarp installation that is customary and within industry standards. It was also determined that the extensive tarping was unnecessary. This additional damage caused by or resulting from said tarp installation did not occur on the reported date of loss nor was it caused by Hurricane Milton. Rather, it was subsequently caused by the vendor. Additionally, there is no coverage under the Policy for loss or damage caused by or resulting from acts or decisions of any person, group, or organization, and/or faulty, inadequate or defective workmanship, repairs, construction, materials or maintenance. Furthermore, cosmetic damage (as defined by the Policy) to roof surfacing is also specifically excluded by the Policy. Additionally, Root Cause Consulting and AKG’s inspections did not reveal direct physical loss to the roofing system caused by Hurricane Milton that allowed rain to enter as set forth in the aforesaid incorporated communications sent to the Insured dated March 26, 2025, and April 25, 2025. The CRN omits this fact and further fails to acknowledge that the governing Policy does not provide coverage for loss or damage to the interior of any building caused by or resulting from rain, whether driven by wind or not, unless the building first sustains damage by a Covered Cause of Loss to its roof or walls through which the rain entered. Thus, since the wind driven rain did not enter through areas of the roof or walls specifically damaged by a Covered Cause of Loss as defined by the Policy, that being, risk of direct physical loss not otherwise excluded, there is no coverage for these damages caused by or resulting from rain whether driven by wind or not as previously communicated to the Insured. Damage caused by other excluded conditions were identified by Root Cause Consulting including rust stains to the elevator door caused by long-term exposure to moisture affecting the area at least six months before the reported date of loss, staining on the building tower’s wall sheathing indicating that moisture had been penetrating the walls of the tower for at least a year before the reported date of loss, and staining to the roof sheathing in the attic indicating long-term leaks occurring years before the reported date of loss. Some of the stains were interrupted by mismatched roof sheathing, indicating that the stains existed before the roof sheathing was repaired in 2015 per permit history and, as such, would have been at least 10 years old before the reported date of loss also with historical repairs to the ceilings on the second story in this area demonstrating that the roof leaks occurred before Hurricane Milton. The CRN omits these facts. There is no coverage under the Policy for loss or damage caused by or resulting from wear and tear, rust, continuous or repeated seepage or leakage of water or moisture that occurs over a period of 14 days or more, faulty, inadequate or defective workmanship, repairs, or maintenance and/or prior loss or damage. Additionally, the Policy does not cover loss or damage outside the Policy period. Frontline again directs the Insured to its prior communications discussed herein. Frontline’s inspections mentioned above revealed changes in conditions to the damaged building materials being claimed, including removal of materials and demolition that occurred prior to inspections being completed, such as, carpet and baseboard removal along with substantial demolition. The CRN omits these facts. Prior to Root Cause Consulting’s inspection, removal of the wall coverings, ceiling, and flooring in the gym, great room, and west central room on the second story were undertaken. Frontline has requested photographs of the property conditions before changes were made including via correspondence dated October 26, 2024, March 26, 2025, and April 25, 2025. Frontline received photographs from the Insured’s public adjuster on March 13, 2025. They do not depict all conditions being claimed damaged prior to being changed, including before carpet removal. Frontline reiterated its prior requests for photographs depicting the property damage being claimed in the above communications, including before conditions were altered as requested in the incorporated above-noted correspondence. Frontline was not afforded the opportunity to inspect the damages according to Policy conditions and its investigation was hindered including the ability to determination causation and the extent of damages being claimed to certain areas, resulting in prejudice to Frontline. Like many other pertinent facts, the CRN omits this information. Regarding the estimates mentioned in the CRN from Storm Masters, Frontline is in receipt of estimates dated October 18, 2024, for services totaling $88,516.17, and $82,501.45, and October 25, 2024 estimate for tarping and what appears to be additional water dry-out services totaling $34,220.69. These services appear to be attributed to excluded conditions as identified above and/or exceed what was reasonable, necessary and/or related to covered damage under the Policy coupled with the above-noted faulty, inadequate, or defective tarp installation undertaken by the vendor. As such, there is no coverage for these estimates under the Policy outside what Frontline’s investigation to date has determined reasonable, necessary and covered by the Policy. Frontline has also continued to request from the Insured mold testing and any protocol obtained as discussed with the Insured’s public adjuster during inspection on or about December 1, 2024, and followed up on by Frontline, including in its March 26, 2025, and April 25, 2025 communications. The CRN is further misleading in its omission that the Insured has not complied with Policy conditions, causing any alleged delay that is outside the control of Frontline. As noted above, Frontline remains pending the Insured’s compliance with Policy conditions. The Insured has failed to provide requested records and documents examination in violation of the Policy and outside the control of Frontline. All documents requested by Frontline are to assist with its Claim investigation, understanding and evaluating the damages being alleged, and to assess any Policy provisions which may be applicable. The Insured’s failure to timely provide an SPOL was also outside the control of Frontline. Frontline has yet to receive any SPOL that correctly identifies it as the insurer. As previously conveyed to the Insured by way of correspondence dated April 14, 2024, Frontline is not in agreement with the SPOL submitted. Damages covered by the Policy as revealed by Frontline’s investigation to date are set forth herein and in the above-noted communications and estimates which have been previously provided and speak for themselves. The CRN omits the fact that qualified engineer and roofer opinion supported Frontline’s coverage determination under the Policy’s terms, conditions, exclusions and limitations with the Insured being fully indemnified for all damage covered by the Policy. To date, the Insured has not complied with Policy conditions and has not provided any additional information or documentation for Frontline’s consideration which could alter or change its assessment. Instead, it has made inaccurate, misleading, and conclusory allegations. Additionally, the CRN fails to state a cure demand amount with specificity. To the extent it seeks payment for the amount owed under the Policy, cure has already occurred since nothing further is owed based upon Frontline’s investigation to date. Thus, as set forth herein, the CRN fails to comply with Florida law, including the pleading requirements of Section 624.155, Florida Statutes. The CRN is also overbroad, objectionable, improper, and insufficient as noted herein. The alleged violations and allegations of bad faith in the CRN are unfounded, misleading, insufficient and denied by Frontline. Frontline has handled the Claim in compliance with the Policy and Florida law. Frontline also asserts that this response is not necessarily exhaustive and does not preclude it from asserting any other valid facts or defenses to the CRN. We trust that this correspondence addresses any concerns or questions which you may have regarding the CRN file. Please feel free to contact us if you have any remaining questions, comments or require any additional information. Very truly yours, The Teebagy & Medeiros Law Group, PLLC Crystalin C. Medeiros For the Firm CC: Robert E. Jameson, Esquire (Via email: Robert@woolseymorcom.com)
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