Civil Remedy Notice of Insurer Violations
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Filing Number:     808868
Filing Accepted:  2/28/2025
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Complainant
Last/Business Name *  
AND ROOF TARP NOW, INC.   First Name   ECOBUILD GROUP, INC.
Street Address * INSUREDS' PROPERTY: 5037 TOPROYAL LANE
City, State Zip * JACKSONVILLE, FL 32277
Email Address * INTAKE2@THEKRFIRM.COM
Complainant Type: * Third Party
Insured
Last/Business Name*   VELICHKO   First Name   GEORGE AND LUBA
Policy # * BFL6508093-00 Claim #* CFL22579257
Attorney
Attorney is Applicable
Last Name* KADIR First Name * ALI Initial A.
Street Address* 986 DOUGLAS AVE, STE. 102
City, State Zip* ALTAMONTE SPRINGS , FL 32714
Email Address * INTAKE2@THEKRFIRM.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   PEOPLE'S TRUST INSURANCE COMPANY
NAIC Company Code 13125
 
Name of individual responsible for violation (if any):* AARON C. EDWORTHY (FORMERLY POWELL), ANDREW PARSONS, RAPID RESPONSE TEAM LLC, AND ALL PEOPLE’S TRUST CLAIMS ADJUSTERS, EMPLOYEES, REPRESENTATIVES, AGENTS, VENDORS, AND/OR ENGINEERS WHO HANDLED THE CLAIM.
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Claim Denial
Claim Delay
Unsatisfactory Settlement Offer
Unfair Trade Practice
Other : Misrepresentation
* 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)(2) Making claims payments to insureds or beneficiaries not accompanied by a statement setting forth the coverage under which payments are being made.
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)(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.

“We insure for direct physical loss to the property covered caused by a peril listed below unless the loss is excluded in the Exclusions. . . . . 2. Windstorm Or Hail.”
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

The Complainants, Ecobuild Group, Inc. and Roof Tarp Now, Inc. (“the Complainants”), are mitigation companies and assignees of the homeowners/insureds who provided tarp and emergency mitigation services to the Insureds’ property/home after a wind and rainstorm. However, the Complainants were wrongfully underpaid by the insureds’ insurance company for said services. To be specific, the assignors, George and Luba Velichko (“the Insureds”), are homeowner insureds with an insurance policy issued by People’s Trust Insurance Company (“People’s Trust”) that insured property located at 5037 Toproyal Lane, Jacksonville, Florida 32277. In December of 2020, the Insureds’ property sustained extensive damage caused by a wind and rainstorm for which People’s Trust admitted coverage under the subject insurance policy. The Complainants subsequently provided tarp and emergency mitigation services to the Insureds’ property. To date, all work has been completed. The Complainants submitted reasonably priced invoices totaling $11,839.96 with supporting documentation and photographs to People’s Trust for said services. After reporting the claim, People’s Trust retained an unqualified and biased field adjuster who has a financial relationship with People’s Trust. This field adjuster inspected the Insureds’ home in an apparent effort to minimize People’s Trust’s losses instead of adjusting the claim in good faith. However, despite admitting coverage for the insurance claim, People’s Trust significantly undervalued the coverage afforded by paying only $2,300.00 which is unreasonably low for the services provided. Based on these facts, it is clear People’s Trust unreasonably denied full coverage and full payment for the Complainants’ services in bad faith through its extremely low and unreasonable undervaluation. Had People’s Trust conducted a reasonable investigation based upon the available information, it would have been evident that affording greater coverage and issuing a substantially higher payment is warranted. Instead, it failed to adopt and implement standards for proper claim investigation as well as misrepresented pertinent policy provisions/facts rather than act fairly and/or honestly with the Complainants in due regard for their interests. This has become a common business practice of People’s Trust. Florida Statute § 624.02 defines insurance as a contract whereby one undertakes to indemnify another or pay or allow a specified amount or a determinable benefit based on determinable contingencies. Inherent is the fact that payment must be made timely and promptly so that insureds and/or assignees of the insured(s) may mitigate damages and put the insured(s) back into the position they were in prior to the loss as quickly as possible. People’s Trust has breached this duty by refusing to properly and timely adjust the loss. As a result, the Complainants had no choice but to retain the undersigned counsel to file a lawsuit against People’s Trust. People’s Trust has more than enough information and is still refusing to pay the Complainants the outstanding amount due regarding its invoice. This continued and repeated reckless claim delay and denial of payment will result in a significant punitive damage award if a bad faith lawsuit is filed. People’s Trust can cure the violations contained herein by paying the Complainants the outstanding amount of $9,539.96 for their invoices.
Comments
User Id Date Added Comment
jessi.lippman@csklegal.com 04-01-2025 April 1, 2025 VIA DFS WEBSITE Florida Department of Financial Services Bureau of Consumer Assistance, Civil Remedy Section 200 East Gaines Street Tallahassee, Florida 32399-0322 Re: Complainant: ECOBUILD GROUP, INC. AND ROOF TARP NOW, INC. Filing No.: 808868 Claim No.: CFL22579257 Policy No.: BFL658093-00 Date of Loss: December 24, 2020 Dear Sir/Madam: This correspondence is in response to the Civil Remedy Notice of Insurer Violations (hereinafter referred to as the “Notice”) filed by Ali A. Kadar, Esq., on behalf of Complainant, ECOBUILD GROUP, INC. AND ROOF TARP NOW, INC. (hereinafter “Claimant”), under the Policy of Insurance for Insureds George and Luba Velichko. The Department of Financial Services assigned an accepted date of February 28, 2025, for the Notice. The law firm of Cole, Scott & Kissane, P.A. has been retained to represent People’s Trust Insurance Company (hereinafter “People’s Trust” or “Insurer”) in this matter. People’s Trust welcomes this opportunity to respond to the Notice and denies each and every allegation contained therein. People’s Trust does not consider there to have been any manner of violation and questions the validity of the Notice as it fails to meet the requirements set forth in section 624.155, Florida Statutes and Florida law and thus fails to perfect the Claimant’s right to pursue civil remedies under Florida Statutes. Furthermore, the Notice does not accurately reflect the development of the claim as presented. The potential statutory violations and facts provided are nothing more than unsupported, baseless allegations. There are no facts or circumstances to support any kind of mishandling of this matter by People’s Trust. As indicated below, the subject property was dutifully inspected and proper coverage for the claim was afforded based on the clear meaning of the subject policy. I. Specificity Requirement The Claimant’s Civil Remedy Notice violates multiple requirements set forth in the Florida courts’ jurisprudence for civil remedy notices. In addition, it fails to meet even the most basic requirements of the Statute. Accordingly, People’s Trust respectfully requests the Department return the Civil Remedy Notice and insist the Claimant provide the specific facts required for civil remedy notices. See Section 624.155(3)(c), Florida Statutes. These requirements arise from the following provisions of Section 624.155: (3)(a) As a condition precedent to bringing an action under this section, the department and the authorized insurer must have been given 60 days' written notice of the violation. If the department returns a notice for lack of specificity, the 60-day time period shall not begin until a proper notice is filed. (b) The notice shall be on a form provided by the department and shall state with specificity the following information, and such other information as the department may require (emphasis added): 1. The statutory provision, including the specific language of the statute, which the authorized insurer allegedly violated. 2. The facts and circumstances giving rise to the violation. 3. The name of any individual involved in the violation. 4. Reference to specific policy language that is relevant to the violation, if any. If the person bringing the civil action is a third party claimant, he or he shall not be required to reference the specific policy language if the authorized insurer has not provided a copy of the policy to the third party claimant pursuant to written request. 5. A statement that the notice is given in order to perfect the right to pursue the civil remedy authorized by this section. In interpreting this statute, courts have emphasized the importance of filing specific civil remedy notices. The civil remedy notice is “crucial to the procedural integrity of an action” under the Statute. Allstate Ins. Co. v. Clohessy, 32 F. Supp. 2d 1328, 1333 (M.D. Fla. 1998). “It is, without a doubt, a condition that must be satisfied in order for one to perfect the right to sue under the statute.” Id. “In creating this statutory remedy for bad-faith actions, the Legislature provided this sixty-day window as a last opportunity for insurers to comply with their claim-handling obligations when a good-faith decision by the insurer would indicate that contractual benefits are owed.” Talat Enterprises, Inc. v. Aetna Cas. & Sur. Co., 753 So. 2d 1284 (Fla. 2000). Thus, the CRN cannot be “vague and ‘shotgun’ in nature,” rather than “the type of specific notice required by the statute that would allow [the insurer] an opportunity to cure.” Heritage Corp. of South Florida v. National Union Fire Ins. Co. of Pittsburgh, PA, 580 F. Supp. 2d 1294, 1299 (S.D. Fla. 2008). Because it is in derogation of the common law, Section 624.155(1)(b), Florida Statutes must be strictly construed. Talat, 753 So. 2d at 1283 (citing Baxter v. Royal Indem. Co., 285 So. 2d 652 (Fla. 1st DCA 1973)). To perfect the right to sue under the statute, the insured must specifically notify the insured of any and all alleged violations claimed. Talat Enterprises, Inc. v. Aetna Casualty & Surety Co., 952 F.Supp. 773, 776 (M.D. Fla. 1996) (“Talat I”). In Valenti, the District Court for the Middle District of Florida considered the practical consequences of an insured’s non-specific civil remedy notice. Valenti v. Unum Life Ins. Co. of America, 2006 WL 1627276 (M.D. Fla. 2006). The plaintiff’s civil remedy notice included allegations that the defendant conducted an inadequate investigation. The plaintiff, however, failed to identify with the requisite specificity the defendant’s actions that were inadequate. The Middle District held that the plaintiff’s civil remedy notice was insufficient, and stated the following: [T]he civil remedy notice must be specific enough to provide insurers notice of the wrongdoing so the insurer can cure the same within sixty days. … Plaintiffs’ counsel, during the hearing in this matter, argued a civil remedy notice that states “you denied my claim” should be sufficient to place the insurer on notice of what was needed to be cured. Plaintiffs’ counsel further argued that it was up to the insurer, as the insurance expert, to decipher what actions needed to be cured. This argument, in this Court's estimation, is illogical and is counter to the purpose of the civil remedy notice. If a simple “you denied my claim” was sufficient to put insurers on notice, the sixty-day cure period would be little more than a guessing game with the insurer attempting to correctly guess what errors the insured claimed it made in the claims handling process, or risk defending a bad faith action. This surely is not what the legislature had in mind when it created the civil remedy notice. Accordingly, this Court finds that Plaintiffs allegation that Defendant failed to conduct an adequate investigation is insufficient to provide Defendant an opportunity to cure. Id. at *2. The guidance for an insured could not be clearer. “The purpose of the civil remedy notice is to give the insurer one last chance to settle a claim with its insured and avoid unnecessary bad faith litigation.” Lane v. Westfield Insurance Co., 862 So. 2d 774, 779 (Fla. 5th DCA 2004). Its purpose is not “to give the insured a right of action to proceed against the insurer even after the insured’s claim has been paid or resolved.” Id. Ultimately, conclusory allegations without facts fail to perfect a statutory bad faith claim. Merely alleging the bare minimum allegations is insufficient pursuant to Florida courts’ interpretations of Section 624.155, Florida Statutes. Additionally, Claimants cite statutory violations under 626.9541(1)(i)(3). These statutory sections have a statutory preamble as follows: “3. Committing or performing with such frequency as to indicate a general business practice any of the following:” Violations of these statutory provision require a showing that the violations are occurring with a frequency beyond just that of the Claimant’s own claim. Here, Claimants have not provided any evidence of these violations and lack the specificity to be considered sufficient notice. II. The Elements of a Valid Civil Remedy Notice There are at least eight requirements for a valid civil remedy notice. Pursuant to Section 624.155(3)(c)’s requirement that a civil remedy notice must set forth the “facts and circumstances giving rise to the violation,” a valid civil remedy notice must contain the following: 1. “explain how the [insurer] violated [the statutes],” Heritage Corp., 580 F.Supp. 2d at 1299; 2. “explain the amounts of damage at issue caused by the [insurer’s] alleged statutory violations,” rather than caused by the loss itself, Id.; 3. Provide the facts showing “knowledge and/or delay on the insurance company’s part,” 316, Inc. v. Maryland Cas. Co., 625 F. Supp. 2d 1187, 1192 (N.D. Fla. 2008). 4. provide the facts supporting the specific contractual damages allegedly owed rather than merely the policy limits, Id. at 1193; 5. if an inadequate investigation is alleged, the civil remedy notice must be specific enough to allow the insurer to conduct an additional investigation, Nowak v. Lexington Ins. Co., 464 F.Supp.2d 1248, 1252 (S.D. Fla. 2006). Additionally, subsections (3)(a)1., 3. and 4. require: 6. “the statutory provision, including the specific language of the statute, which the authorized insurer allegedly violated;” 7. “the name of any individual involved in the violation;” and 8. “Reference to specific policy language that is relevant to the violation.” As noted, the first five requirements mandate the insured to provide specific facts and circumstances of the alleged violations. This would necessarily include specific facts regarding the method of the investigation; the reasons the investigation was improper or otherwise inadequate; the reasons why this alleged inadequacy is due to the failure to adopt and implement standards for the proper investigation of claims, and the facts supporting these conclusions. To allege an inadequate investigation, the Notice must include specific facts regarding the method, rather than merely the results. Valenti, 2006 WL 1627276, at *1. Florida law does not allow an insured, without providing any facts, to allege that the insurer’s only option to avoid bad faith is paying whatever the insured demands. 316, Inc., 625 F.Supp.2d at 1194. Requirements two and four regarding the alleged damages must also be specifically provided in the civil remedy notices. Importantly, the Talat court held that payment of undisputed damages within the cure period is sufficient to preclude a statutory bad faith action. In that circumstance, the insurer has “timely paid ‘the damages’ and has corrected ‘the circumstances giving rise to the violation’ within the meaning of [Section 624.155(2)(d), Florida Statutes].” Id. at 1281. The insurer is not required to pay any compensatory damages that flow from any alleged delay in settling the claim. Importantly, only the contractual benefits are owed during the 60-day cure period. To provide an insurer with the notice of the contractual and extra-contractual damages, Florida law clearly requires facts supporting the amount. Merely requesting payment within policy limits without any basis renders the civil remedy notice invalid. If the civil remedy notice does not satisfy each of the eight elements, it cannot be considered valid pursuant to the Florida case authority cited above. A further requirement of section 624.155, Florida Statutes, is that the complainant shall state with specificity the name of any individual involved in the violation. § 624.155(3)(b)3, Fla. Stat. The Claimants do not name a single individual; therefore, this Notice does not meet the requirements of the statute. III. Facts Insureds reported a loss to the Insurer on January 21, 2022, alleging that the property was damaged as a result of wind on or about December 24, 2020. The Insurer assigned Claim Number CFL22579257 to the loss. On January 25, 2022, People’s Trust’s Field Adjuster inspected the property, and documented the damages. On or about January 25, 2022, People’s Trust received an AOB contract/Direction to Pay from EcoBuild dated January 22, 2022, along with an invoice in the amount of $3,832.50, for installation of a tarp. On January 27, 2022, People’s Trust informed the Insureds of its coverage decision, advising that the claim was under deductible, and invoked the option to repair any covered damage which may exceed the deductible. Additionally, on the same day, People’s Trust provided correspondence to EcoBuild regarding their contract with the Insureds for potential restorative repairs and that they may be tortiously interfering with the policy’s Preferred Contractor Endorsement. People’s Trust further advise EcoBuild of the limitations under the Policy, advising that “if a covered loss requires emergency services to protect property from further damage, we must receive advance notice of such a need and an opportunity to have RRT perform those services; otherwise, the policy provides that PTI will not pay the provider of those emergency services more than it would have paid RRT to perform that work. People’s Trust issued a $2,000 payment to EcoBuild for tarping services, pursuant to the limits of the policy. Additionally, on March 17, 2022, People’s Trust received a Direction to Pay contract and Certificate of Completion and Satisfaction signed and dated March 16, 2022, along with an invoice for Temporary Repairs for $300. People’s Trust also received a Tarp and Repair invoice for $1,550. On April 11, 2022, People’s Trust issued $300 to EcoBuild for the Temporary Repair. EcoBuild continued to follow up and People’s Trust advised that No additional payments would be made. On or about September 22, 2022, People’s Trust received an AOB Contract and Direction to Pay from Roof Tarp Now, Inc., along with an invoice for tarping in the amount of $3,750 signed and dated September 21, 2022. On or about September 23, 2022, People’s Trust received an additional tarp invoice from Roof Tarp Now in the amount of $4,594.96, along with a Customer Satisfaction Letter signed and dated September 21, 2022. On September 26, People’s Trust advised Roof Tarp Now that the tarping limit for the subject claim has been exhausted and no payment will be issued. IV. Inaccuracy of Statutory Allegations in Civil Remedy Notice With the above referenced facts established, it is clear the alleged statutory violations are also unsupported. Without any supporting facts other than conclusory statements provided by the Claimants, People’s Trust cannot adequately address the same. In our factual analysis provided in this Response, we provided facts that implicitly address many of the allegations in the Notice. From those facts, it becomes clear that People’s Trust is dealing with the claim pursuant to the professional standards of care. Your Notice alleges the following statutory violations by People’s Trust and, because of the bare nature of the allegations and facts provided, we address each as follows: • 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. - Claimant’s allegation is insufficient on its face. People’s Trust timely inspected and investigated the damages, afforded coverage for the claim, and issued payment for the services provided, pursuant to the limits under the policy. As such, this allegation is baseless. • Making claims payments to insureds or beneficiaries not accompanied by a statement setting forth the coverage under which payments are being made.- Claimant’s allegation is insufficient on its face. People’s Trust provided multiple correspondences supporting its payments and setting forth the limitations on the policy. As such, this allegation is baseless. • 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. - Claimant’s allegation is insufficient on its face. There is no evidence to support that this claim involved more than one coverage, therefore, this allegation is baseless. • Failing to adopt and implement standards for the proper investigation of claims. You have not provided any facts to sustain such an allegation. People’s Trust timely inspected and investigated the damages, afforded coverage for the claim, and issued the undisputed payment for mitigation services, pursuant to the policy limits. As such, this allegation is baseless. • Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue. -You have not provided any facts to sustain such an allegation. People’s Trust timely inspected and investigated the damages, afforded coverage for the claim, and issued the undisputed payment for mitigation services, pursuant to the policy limits. As such, this allegation is baseless. • Failing to acknowledge and act promptly upon communications with respect to claims. – You have not provided any facts to sustain such an allegation. People’s Trust timely inspected and investigated the damages, afforded coverage for the claim, and issued the undisputed payment for mitigation services, pursuant to the policy limits. As such, this allegation is baseless. • Denying claims without conducting reasonable investigations based upon available information. - Claimant’s allegation is insufficient on its face. The claim was not denied. Coverage was afforded for the underlying claim. Claimant, EcoBuild was issued payment pursuant to the policy limit. Roof Tarp Now was advised that benefits were exhausted. Therefore, this allegation is baseless. • Failing to affirm or deny full or partial coverage of claims, and, as to 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. - You have not provided any facts to sustain such an allegation. People’s Trust timely inspected and investigated the damages, afforded coverage for the claim, and issued the undisputed payment for mitigation services, pursuant to the policy limits. As such, this allegation is baseless. • 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. - You have not provided any facts to sustain such an allegation. People’s Trust timely inspected and investigated the damages, afforded coverage for the claim, and issued the undisputed payment for mitigation services, pursuant to the policy limits. As such, this allegation is baseless. • Failing to promptly notify the insured of any additional information necessary for the processing of a claim.- You have not provided any facts to sustain such an allegation. People’s Trust did not require additional information as the mitigation services were paid pursuant to the policy limits. As such, this allegation is baseless. • Failing to clearly explain the nature of the requested information and the reasons why such information is necessary. – claimant has failed to allege any factual basis or specificity as to how claimant was damaged based on this allegation. • 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) – Claimant’s allegation is insufficient on its face. People’s Trust timely inspected and investigated the damages, afforded coverage for the claim, and issued the undisputed payment for mitigation services, pursuant to the policy limits. All undisputed payments were timely made. As such, this allegation is baseless. V. Conclusion People’s Trust specifically denies any and all allegations contained within the Civil Remedy Notice of Insurer Violation including, but not limited to, those allegations contained within “Reason for Notice” including any claim for bad faith. People’s Trust afforded proper coverage on the subject claim after prompt and thorough investigation of the loss, and provided payment pursuant to the policy limits for the requested services. There are no additional benefits due or owing at this time and, as such, no attorneys’ fees are due or owing. Pursuant to the applicable insurance policy, for any alleged covered loss, Claimants must notify People’s Trust before authorizing or commencing repairs or services so that Defendant may, at its option, select Rapid Response Team, LLC to make covered repairs or perform services. Defendant and Rapid Response Team, LLC entered into a “Service Agreement” which provides that Rapid Response Team, LLC will perform tarping services for maximum amount of Two-Thousand Dollars ($2,000.00) per claim. People’s Trust maintains that the Claimants and the insureds have failed to comply with the above-referenced policy provision by way of the purported assignment of benefits in violation of the specific terms of the subject insurance policy. People’s Trust paid the policy limit of $2,000. Moreover, it is Claimant’s actions that have brought the parties to the current state of affairs. The facts referenced in the Civil Remedy Notice are inaccurate, incomplete and premature. People’s Trust has not acted in bad faith. Claimant has not produced any evidence to substantiate the aforementioned allegations. Furthermore, the bare nature of the Civil Remedy Notice does not allow for a more specific response to the alleged violations. People’s Trust will provide a further response and consider the same if and when any additional information is provided relative to any alleged violation. People’s Trust continues to reserve all of its rights. We trust this fully and adequately responds to any inquiry regarding the instant claim. If you have any questions or require further clarification with regard to the above, please do not hesitate to contact us. Sincerely, /s/ Jessi M. Lippman Daniel J. Maher Jessi M. Lippman
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