Civil Remedy Filing

Civil Remedy Notice of Insurer Violations

Filing Number: 810245

Filing Accepted: 3/10/2025

Print Filing

Complainant

Last/Business Name *

AMY SCHMIDT AND DAVID SCHMIDT

First Name

Street Address *

7713 STILL LAKES DRIVE

City, State Zip *

ODESSA, FL 33556

Email Address *

DAVIDPSCHMIDT23@GMAIL.COM

Complainant Type: *

Insured

Last/Business Name*		AMY SCHMIDT AND DAVID SCHMIDT		First Name
Policy # *		EDH5477925-01		Claim #*		EDI969474

Attorney

Attorney is Applicable

Last Name*	SARANOVA- PUGH First Name * LOANMY Initial
Street Address*		925 FEDERAL HWY
City, State Zip*		BOCA RATON , FL 33432
Email Address *		LSARANOVA@KPATTORNEY.COM

Violation

Insurer Type *		Authorized Insurer Unauthorized Insurer

Insurer Name
Insurer Name*		EDISON INSURANCE COMPANY
Insurer Name*
Street Address*
City, State Zip*		,
NAIC Company Code 12482

Name of individual responsible for violation (if any):* LAYCEE WILLIAMS
Type of Insurance * Residential Property & Casualty

Reason for Notice *

	Claim Delay
	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.
	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)(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.

* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

Loss settlement provision

* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

The carrier was immediately put on notice of the insureds’ Hurricane Milton claim. Subsequently, the insureds prepared a loss package in the amount of $146,850.00 needed to restore the property back to its pre-loss condition. Whereas, the carrier has failed to prudently inspect the insureds’ property, come to a fair coverage determination and promptly pay the claim. In turn, the insureds have complied with all of the carrier’s requests to date and the carrier has still failed to treat this claim with good faith. This intentional delay with the claim has led to direct prejudice of the insureds. About one hundred and seventy-nine days have passed since the original date of loss. The carrier has still refused to pay the fully covered amount owed under the policy. The carrier is aware of the damage sustained by the insured’s property and has not taken any meaningful ensuing action. It is clear that the carrier is not treating the insureds with good faith claims conduct; failing to pay a claim clearly owed; not adjusting the claim and evaluating the loss properly, promptly and fairly to provide full and prompt indemnity to the insureds; failing to implement proper standards for the adjustment and investigation of claims by its adjusters and placing the company’s interests before the insureds’ interests; refusing to pay the full amount owed to the insureds despite the fact that the carrier has been on notice of the damages and looking for ways to delay full recovery or any recovery to the insureds, when a reasonable carrier in a similar position would have tendered a full payment in accordance with both the policy language and statutory requirements. The carrier’s actions are in violation of Florida Statutes §§ 624.155(1)(b)(1), 624.155(1)(b)(3), 626.9541(1)(i)(3)(a); 626.9541(1)(i)(3)(b), 626.9541(1)(i)(3)(c) and 626.9541(1)(i)(3)(f), as well as Section I- Perils Insured Against, subsection 1, providing coverage for direct loss to property unless the damage was caused solely by an excluded or excepted cause of loss; and the loss payment provision under Section I- Conditions requiring payment of a claim within 90 days. All the aforementioned are part of what appears to be an ongoing pattern and practice of behavior of the carrier that it demonstrates a wanton and reckless disregard for the insureds’ rights and a pattern and practice of bad faith claims practices to its insureds across the state of Florida. Therefore, to cure the defects outlined in this Civil Remedy Notice, the carrier must: 1.) Pay the complete covered loss in the amount of $146,850.00, less any prior payments and less any applicable policy deductible; and 2.) Pay the statutory interest on the amount of unpaid damages from the date of loss to the date payment is finally made. A copy of this letter and filed form submitted to the FDFS has been sent to the carrier. Please do not hesitate to contact the undersigned or Jocelyn Padron at (561)-892-9949 if you have any questions or concerns. Sincerely, Loanmy Saranova- Pugh Attorney at Law

Comments

User Id		Date Added		Comment
april@zinoberdiana.com		05-08-2025		We represent Edison Insurance Company (hereinafter, “Edison”) in the dispute filed by you on behalf of Amy Schmidt and David Schmidt as the Complainants (hereinafter, “Complainants”), against Edison for Claim No. EDI969474. This correspondence constitutes Edison’s Response to the Civil Remedy Notice of Insurer Violation which your office filed on behalf of the Complainants on March 10, 2025, with the Florida Department of Financial Services (“DFS”), DFS filing number 810245 (hereinafter, the “CRN”). While Edison welcomes the opportunity to respond to this CRN, Edison specifically denies each and every allegation contained in the CRN filed in relation to this claim. Further, Edison asserts that the CRN should be rejected and returned by DFS, as the CRN fails to comply with the specific information requirements as set forth within § 624.155, Florida Statutes, and Florida case law, and is therefore facially invalid and deficient. I. The CRN fails to satisfy the requirements of Florida law. Concerning the contents of the CRN, the law requires strict compliance with the specificity requirements in § 624.155, Florida Statutes, which the CRN fails to satisfy. Both § 624.155(3), Florida Statutes, and the Civil Remedy Notice form require the Complainants to specifically state, among other things, the statutory provisions, including the specific language of the statute, which the insurer allegedly violated, the facts and circumstances giving rise to the violation, the name of any individual involved in the violation, and the specific policy language that is relevant to the violation. Additionally, § 624.155(3)(b) mandates that the Civil Remedy Notice must be “on a form provided by the [Department] and shall state with specificity … such other information as the department may require.” (emphasis added). Further, the purpose of the specificity requirement for a civil remedy notice is to put the insurer on notice of an alleged violation, the circumstances surrounding same, and indicate the details of the alleged violation in order to provide an insurer with 60 days to “cure” the alleged claim defects and otherwise avoid litigation. See Talat Enterprises, Inc. v. Aetna Casualty and Surety Co., 753 So. 2d 1278, 1283-4 (Fla. 2000); Rousso v. Liberty Surplus Ins. Corp., 2010 U.S. Dist. LEXIS 82328 (S.D. Fla. Aug. 13, 2010). Uninformative recitations that do not inform the insurer of the facts underlying the alleged violations or match up with the statutes that the complainant identifies as the statutes that were purportedly violated are insufficient to fulfill the requirements of § 624.155. Rousso, 2010 U.S. Dist. LEXIS 82328. The CRN fails to meet the specificity requirements of § 624.155, Florida Statutes, and therefore is invalid and deficient. Notably, in contravention of the statutory and form requirements that a complainant must state the specific statutory provisions allegedly violated and the facts and circumstances giving rise to the violation, the CRN identifies numerous statutory provisions, though they are not wholly relevant or applicable to the alleged facts or claimed violations contained in the CRN or fail to correlate with any specific facts or circumstances giving rise to the alleged violations. Likewise, the CRN identifies certain “reason[s] for notice” without providing sufficient facts to support each. Additionally, contrary to the requirement to “describe the facts and circumstances giving rise to the insurer’s violation as you understand them at this time,” the purpose of which is to “enable the insurer to investigate and resolve [the] claim,” the CRN itself only provides unsupported, incomplete, generic, conclusory, and insufficient allegations with no basis in fact or circumstance, as well as omits specific facts to support its allegations of violations. The CRN includes a lengthy commentary on unsupported, conclusory accusations, unqualified opinion, legal conclusions, conjecture, and inaccurate statements of facts cast in the light most favorable to the Complainants and their representatives. In short, the facts alleged are simply inaccurate, fail to paint a complete picture of the handling of this claim, fail to apprise Edison of how its actions constituted a violation of said statutes, or were identified without any factual support. II. Despite the deficiencies, Edison denies all allegations contained in the CRN. Notwithstanding the deficiencies in the CRN and without waiving the objections above, Edison explicitly denies any violation of the Florida Statutes sections referenced in the CRN. Edison hereby denies each and every allegation contained in the CRN, either explicitly or implicitly, and denies any wrongdoing in the handling of this matter. Rather, Edison handled the claim both diligently and properly under the terms and conditions of the insurance policy, as well as in accord with Florida law. Edison denies each and every allegation contained in the CRN and responds to them individually as follows: The Complainants list the following purported reasons for submitting the CRN which are 1) Claim Delay and 2) Unfair Trade Practice. As indicated in detail below, the CRN fails to establish or set forth any specific facts that would support the allegations asserted in support of the perceived violations and Edison denies each and every allegation. Specifically, Edison responds as follows: Allegation of Claim Delay: This allegation is without basis and therefore denied. Complainant should immediately withdraw this allegation from the CRN as it cannot be established by any credible evidence. At all times material to this claim, Edison acted timely, diligently, and responsibly in its pursuit of coverage. At all times, Edison has continuously acted promptly and timely with regards to all aspects of this claim. Notably, the claim was first reported on January 14, 2025 for an October 9, 2024 date of loss and Edison issued its initial coverage determination on January 24, 2025. Upon receipt of additional information, Edison timely continued in its investigation and adjustment and issued its supplemental coverage determination on February 14, 2025. Moreover, any perceived delays alleged in the CRN are not due to the actions of Edison, nor did Edison have control over any actions causing any perceived delays. Further, claim delay, in and of itself, is not a valid reason for filing a CRN. Allegation of Unfair Trade Practice: This allegation is wholly without basis in law or in fact and is therefore denied. Counsel for Complainants should immediately withdraw this allegation from the CRN as it cannot be established by any credible evidence. Edison handled the claim both diligently and properly under the terms and conditions of the insurance policy as well as in accord with Florida law, a determination of coverage was made based on a good faith investigation and the terms and conditions of the subject policy, a good faith attempt to investigate this claim has and continues to be made, and at all times material to this claim, Edison has and continues to act fairly and honestly towards the Insureds and with due regard for the interests of the Insureds, as it does on every claim. Moreover, the subject CRN cites numerous statutes Edison has allegedly violated. While Edison categorically and unequivocally denies violating any statutes, Edison will briefly address the specific statutes alleged to have been violated, in an abundance of caution. § 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. Edison denies this allegation. The CRN sets forth no actual facts to support this allegation, only opinions as to how the Complainants believe the claim should have been resolved. The CRN also sets forth several inaccuracies and incomplete information regarding the claim based solely on unsupported opinions. Edison retained a qualified independent adjuster and drone company to inspect the insured property in the subject claim. Additionally, Edison made a determination of coverage on this claim based on the totality of its good faith investigation and the terms and conditions of the subject policy and Florida law and issued a detailed explanation to the Insureds regarding its coverage determination in addition to providing the statement of loss and estimate for transparency purposes. While Edison has and continues to make a good faith attempt to investigate this claim and has and continues to act fairly and honestly towards the Insureds and with due regard for the interests of the Insureds, Edison is also not obligated to settle a claim in a matter beyond that which is covered under the terms, conditions and exclusions of the subject policy. The remainder of the CRN simply states disparaging and unsubstantiated opinions regarding Edison and its agents assisting in the investigation of the subject claim. At no time has Edison acted dishonestly or unfairly toward the Insureds and/or their representatives. All actions have been performed in good faith for the purpose of moving the claim towards a just and equitable resolution. Edison acted in accordance with Florida Statute § 624.155(1)(b)(1) and has in no way violated said statutory provisions. § 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. Edison denies this allegation. The CRN sets forth no actual facts to support this allegation, only opinions as to how the Complainants believe the claim should have been resolved. The CRN also sets forth several inaccuracies and incomplete information regarding the claim based solely on unsupported opinions. Edison retained a qualified independent adjuster and drone company to inspect the insured property in the subject claim. Additionally, Edison made a determination of coverage on this claim based on the totality of its good faith investigation and the terms and conditions of the subject policy and Florida law and issued detailed explanations to the Insureds regarding its coverage determinations including the statement of loss and estimate for transparency purposes. While Edison has and continues to make a good faith attempt to investigate this claim and has and continues to act fairly and honestly towards the Insureds and with due regard for the interests of the Insureds, Edison is also not obligated to settle a claim in a matter beyond that which is covered under the terms, conditions and exclusions of the subject policy. The remainder of the CRN simply states disparaging and unsubstantiated opinions regarding Edison and its agents assisting in the investigation of the subject claim. At no time has Edison acted dishonestly or unfairly toward the Insureds and/or their representatives. Moreover, it is unclear what other portions of the policy coverage Complainants claim Edison was trying to influence the settlements of. All actions have been performed in good faith for the purpose of moving the claim towards a just and equitable resolution. Edison acted in accordance with Florida Statute § 624.155(1)(b)(3) and has in no way violated said statutory provisions. § 626.9541(1)(i)(3)(a) Failing to adopt and implement standards for proper investigation of claims. Edison denies this allegation. The CRN sets forth no actual facts to support this allegation, only opinions as to how the Complainants believe the claim should have been resolved. The CRN also sets forth several inaccuracies and incomplete information regarding the claim based solely on unsupported opinions. Edison retained a qualified independent adjuster and drone company to inspect the insured property in the subject claim. Additionally, Edison made a determination of coverage on this claim based on the totality of its good faith investigation and the terms and conditions of the subject policy and Florida law and issued detailed explanations to the Insureds regarding its coverage determinations in addition to providing the statement of loss and estimate for transparency purposes. While Edison has and continues to make a good faith attempt to investigate this claim and has and continues to act fairly and honestly towards the Insureds and with due regard for the interests of the Insureds, Edison is also not obligated to settle a claim in a matter beyond that which is covered under the terms, conditions and exclusions of the subject policy. The remainder of the CRN simply states disparaging and unsubstantiated opinions regarding Edison and its agents assisting in the investigation of the subject claim. Edison has always implemented standards for investigating and adjusting claims commensurate with the requirements of Florida Statutes, and it will continue to do so. All actions have been performed in good faith and for the purpose of moving the claim towards a just and equitable resolution. Edison acted in accordance with Florida Statute § 626.9541(1)(i)(3)(a) and has in no way violated said statutory provisions. § 626.9541(1)(i)(3)(b) Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue. Edison denies this allegation. The CRN sets forth no actual facts to support this allegation. The CRN also sets forth several inaccuracies and incomplete information regarding the claim based solely on unsupported opinions. Edison retained a qualified independent adjuster and drone company to inspect the insured property in the subject claim. Additionally, Edison made a determination of coverage on this claim based on the totality of its good faith investigation and the terms and conditions of the subject policy and Florida law and issued an honest and detailed explanation to the Insureds regarding its coverage determination in addition to providing the statement of loss and estimate for transparency purposes. While Edison has and continues to make a good faith attempt to investigate this claim and has and continues to act fairly and honestly towards the Insureds and with due regard for the interests of the Insureds, Edison is also not obligated to settle a claim in a matter beyond that which is covered under the terms, conditions and exclusions of the subject policy. The remainder of the CRN simply states disparaging and unsubstantiated opinions regarding Edison and its agents assisting in the investigation of the subject claim. Moreover, the CRN fails to identify and explain what in particular Edison allegedly misrepresented and how any statements made by Edison constituted misrepresentations. On the contrary, at no time has Edison acted dishonestly or unfairly toward the Insureds and/or their representatives. Edison has not made misrepresentations to the Insureds and/or their representatives. All actions have been performed in good faith and for the purpose of moving the claim towards a just and equitable resolution. Edison acted in accordance with Florida Statute § 626.9541(1)(i)(3)(b) and has in no way violated said statutory provisions. § 626.9541(1)(i)(3)(c) Failing to acknowledge and act promptly upon communications with respect to claims Edison denies this allegation. The CRN sets forth no actual accurate facts to support this allegation. The CRN also sets forth several inaccuracies and incomplete information regarding the claim based solely on unsupported opinions. After the claim was reported, Edison immediately began its thorough investigation and issued its coverage determination letter promptly and timely. Additionally, Edison promptly acted and responded to all received documents and information provided with regards to the claim. While Edison has and continues to make a good faith attempt to investigate this claim and has and continues to act fairly and honestly towards the Insureds and with due regard for the interests of the Insureds, Edison is also not obligated to settle a claim in a matter beyond that which is covered under the terms, conditions and exclusions of the subject policy. The remainder of the CRN simply states disparaging and unsubstantiated opinions regarding Edison and its agents assisting in the investigation of the subject claim. Notably, the CRN wholly fails to identify any specific communications which Edison did not promptly responds to or acknowledge. On the contrary, Edison has, in fact, communicated promptly with the Insureds and their representatives. All actions have been performed in good faith and for the purpose of moving the claim towards a just and equitable resolution. Edison acted in accordance with Florida Statute § 626.9541(1)(i)(3)(c) and has in no way violated said statutory provisions. § 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. Edison denies this allegation. The CRN sets forth no actual facts to support this allegation, only opinions as to how the Complainants believe the claim should have been resolved. The CRN also sets forth several inaccuracies and incomplete information regarding the claim based solely on unsupported opinions. Edison retained a qualified independent adjuster and drone company to inspect the insured property in the subject claim. Additionally, Edison made a determination of coverage on this claim based on the totality of its good faith investigation and the terms and conditions of the subject policy and Florida law and issued detailed explanations to the Insureds regarding its coverage determinations in addition to providing the statement of loss and estimates for transparency purposes. While Edison has and continues to make a good faith attempt to investigate this claim and has and continues to act fairly and honestly towards the Insureds and with due regard for the interests of the Insureds, Edison is also not obligated to settle a claim in a matter beyond that which is covered under the terms, conditions and exclusions of the subject policy. The remainder of the CRN simply states disparaging and unsubstantiated opinions regarding Edison and its agents assisting in the investigation of the subject claim. Notably, Edison provided the Insureds with its detailed coverage determination, providing the basis for its decision, and the applicable policy language and estimate. On the other hand, the Complainants fail to specify how or why the communications from Edison were not sufficient other than essentially disagreeing with the decision. All actions have been performed in good faith and for the purpose of moving the claim towards a just and equitable resolution. Edison acted in accordance with Florida Statute § 626.9541(1)(i)(3)(f) and has in no way violated said statutory provisions. Alleged Violations of Policy of Insurance The CRN requires the Complainants to include the specific policy language that is relevant to the violation. Rather than complying with this requirement, the CRN only generally and vaguely refers to “Loss settlement provision.” This is clearly improper, nonspecific, over generalized, and noncompliant with the CRN requirements. The failure to comply with this requirement or to provide factual support as to what and how Edison purportedly violated the policy prevents Edison from engaging in any meaningful review of the policy terms and conditions or actions that the Complainants take issue with and addressing any issues regarding the policy. Edison cannot hit a moving target by attempting to determine what provisions of the policy are actually at issue. As for public policy, this appears to be the exact purpose for the statutory requirements referenced above, which you have violated by failing to accurately provide the policy provisions at issue. Moreover, to the extent the Complainants subsequently intend to rely on specific additional policy provisions, they are precluded from doing so as they failed to properly include those provisions in the CRN. Notwithstanding, Edison denies violating any provision or duty set forth in the policy. Alleged Factual and Circumstantial Support for the CRN A review of the facts and circumstances surrounding the investigation and claim decisions on the subject claim reveals Edison acted in good faith and diligently investigated, handled, and adjusted the claim at issue in this dispute. Edison acted fairly, honestly, and in good faith, acknowledged and acted promptly upon receipt of the claim, attempted in good faith to adjust the claim pursuant to the terms of the policy, took reasonable steps to investigate the claim, communicated reasonably and honestly with the Insureds and the Insureds’ representatives about the claim, and provided the Insureds reasonable explanations for its actions. The subject claim involves alleged windstorm (Hurricane Milton) damage with a reported date of loss of October 9, 2024 to the property located at 7713 Still Lakes Dr., Odessa, FL 33556 (the “Property”) first reported to Edison on January 14, 2025. Edison promptly responded with acknowledgement of the claim and the Homeowner Claims Bill of Rights and initiated its investigation of the claim, which included an inspection of the Property by a qualified independent adjuster and a drone company to properly and safely inspect the tile roof. Edison made a determination of coverage on this claim based on the totality of its diligent, reasonable, and good faith investigation and the terms and conditions of the subject policy and Florida law. Based on the investigation, Edison issued its initial coverage determination letter on January 24, 2025 providing a detailed explanation advising as to the extent of the covered damage pursuant to the Policy and advising that the repairs for the covered damage did not exceed the deductible, providing the statement of loss, and the estimate for the covered damages. Moreover, after additional documentation was received, Edison continued in its good faith investigation of the claim and, as a result, issued its supplemental claim determination on February 14, 2025 explaining why it was Edison was standing by its initial coverage determination. As made clear, Edison has continued to promptly and fairly adjust the claim as information is made available to it. Edison promptly and honestly made all coverage determinations based on its reasonable investigation of the claim. Moreover, contrary to the Complainants’ claims, Edison has and continues to promptly respond to all communications, communicate honestly with the Insureds and their representatives, and conduct a fair and good faith ongoing investigation of the claim. There is no indication in the CRN nor anywhere within the record evidence to suggest that Edison handled the subject claim in bad faith or incongruent with the applicable Florida Statutes. Rather, the record evidence establishes the opposite, and shows that Edison properly handled and adjusted the subject claim and has continued to do so from the time it was first received through the present. Furthermore, under the circumstances, and upon information and belief, the filing of the CRN appears to be an effort to strong-arm Edison into payment for repairs and excessive benefits for which the Complainants are not entitled under the policy. The disagreement with the claim decision does not in any way constitute bad faith on the part of Edison. Under the circumstances presented, Edison cannot in good faith issue a payment for damages that are claimed and demanded by the Complainants as doing so would, in essence, breach Edison’s duty of good faith and fair dealing owed toward each and every one of its other policyholders. Accordingly, there is no evidence that Edison has acted in any way, whatsoever, contrary to the terms of the policy or in violation of the statutes listed in the CRN. III. Demands to Cure Defects. Moreover, the CRN does not specify a cure for the alleged violations that comports with the provisions of the subject Policy. Further, the CRN requests “cures” that are improper according to Florida law and Fla. Stat. §624.155. See Talat Enterprises, Inc. v. Aetna Casualty and Surety Co., 753 So. 2d 1278, 1281 (Fla. 2000). The Talat decision provides that a “cure” must be limited to contract damages. Additionally, Section 624.155, Florida Statutes, does not impose on an insurer the obligation to pay whatever its insured demands. Talat, 753 So. 2d at 1282. On the contrary, the Florida Supreme Court holds that the scope of what can be “cured” in responding to a Civil Remedy Notice, is limited to contractual amounts due to the insured. See Talat, 753 So. 2d at 1281. The subject Notice is deficient as it does not provide an opportunity to “cure” the alleged violations without imposing obligations on Edison not owed or contemplated by the Policy. To the extent the CRN requests anything other than contract proceeds, the CRN is defective and should be rejected. The offer to cure in the CRN, rather, is illusory and even a reading of the CRN in a light most favorable to the Complainants requires that it be invalidated and rejected. Notably, the CRN requests that in order to cure the alleged violations, Edison must: 1) pay $146,850.00 minus the deductible and 2) pay statutory interest. Based on its thorough investigation, the information received at this time, and the terms and conditions of the Policy, Edison properly determined the covered damages pursuant to the Policy and determined that after taking into account the deductible, there are no amounts are due and owing at this time. IV. Conclusion. In closing, Edison first believes that the CRN does not comply with section 624.155, Florida Statutes, and should therefore be rejected and returned by DFS due to its failure to comply with § 624.155, Florida Statutes, and Florida case law. Regardless of the rejection and lack of compliance, Edison denies all allegations contained in the CRN and submits there are no violations. While this Response is meant to be comprehensive, Edison’s Response above is based upon the limited information provided in the CRN and the information we have to date. If the Complainants feel that we are not in possession of all the facts, please inform us immediately. Please note that Edison’s Response is not necessarily exhaustive and does not preclude us from asserting any other valid reason for the lack of compliance with Florida Statute § 624.155. Also, this letter or any act or failure to act on the part of Edison or any agent or representative of Edison should not be construed as a waiver of any rights or defenses available to it by contract or at law as all such rights and defenses are hereby specifically reserved. We trust that this Response addresses the allegations of insurer violation alleged in the CRN filed on March 10, 2025. Should you have any questions regarding this matter or need anything further, please do not hesitate to contact the undersigned. Respectfully submitted, ZINOBER DIANA & MONTEVERDE, P.A. April L. Zinober cc: Edison Insurance Company

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. Before submitting a Notice using this system, please verify that all text has been entered correctly and completely. Once the Notice has been submitted, the text cannot be changed or deleted.

DFS-10-363
Rev. 10/14/2008