Civil Remedy Notice of Insurer Violations
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Filing Number:     811219
Filing Accepted:  3/14/2025
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Complainant
Last/Business Name *  
FREUND   First Name   HANH; DORIT
Street Address * 1521 SW 13TH PL,
City, State Zip * BOCA RATON, FL 33486-53
Email Address * DORITFREUND@MSN.COM
Complainant Type: * Insured
Insured
Last/Business Name*   FREUND   First Name   HANH; DORIT
Policy # * SJ31151329 Claim #* SL23204528
Attorney
Attorney is Applicable
Last Name* BRAZ First Name * TAMARA Initial
Street Address* 8865 COMMODITY CIR. STE. 12
City, State Zip* ORLANDO , FLORIDA 32819
Email Address * TBRAZ@THELAWGICALFIRM.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   SLIDE INSURANCE COMPANY
NAIC Company Code 17227
 
Name of individual responsible for violation (if any):* ? VERNITA WASHINGTON, SR. DESK ADJUSTER FL ON BEHALF OF SLIDE INSURANCE COMPANY; ? YAMIL G. KURI, PROFESSIONAL ENGINEER, ON BEHALF OF ROOT CAUSE CONSULTING; ? MICHAEL BLOCH, FIELD ADJUSTER ADJUSTER ON BEHALF OF COMPASS ADJUSTING SERVICES INC
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Claim Denial
Claim Delay
Unfair Trade Practice
Other : Improper Investigation
Other : Material 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.
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)(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)(f) Failing to promptly provide a reasonable explanation in writing to the insured of the basis in the insurance policy, in relation to the facts or applicable law, for denial of a claim or for the offer of a compromise settlement.
626.9541(1)(i)(4) Failing to pay undisputed amounts of partial or full benefits owed under first-party property insurance policies within 60 days after an insurer receives notice of a residential property insurance claim, determines the amounts of partial or full benefits, and agrees to coverage, unless payment of the undisputed benefits is prevented by factors beyond the control of the insurer as defined in s. 627.70131(5).
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

HO 00 03 10 00 *** SECTION 1 - PROPERTY COVERAGES A. Coverage A - Dwelling 1. We cover: a. The dwelling on the "residence premises" shown in the Declarations, including struc- tures attached to the dwelling; [;] *** HO 100 02 22 *** SECTION I – PERILS INSURED AGAINST A. Coverage A – Dwelling And Coverage B – Other Structures 1. We insure against risk of direct physical loss to property described in Coverages A and B. ***
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

On or about August 3, 2023, Hanh Freund and Dorit Freund (Complainant(s)) suffered a loss to their Property, located at the address listed above due to water damage. After discovering the damage, Complainant(s) promptly reported the loss to Slide Insurance Company (“Insurer”) on or about August 11, 2023. Throughout Insurer’s investigation, Complainant has fully cooperated with Insurer and fully performed all duties and obligations under the policy by providing all information within Complainant’s custody, possession and control. Insurer, however, has failed to fulfill its duties under the Policy and Florida law. Upon discovering the damages, Complainant retained American Leak Detection Of The Palm Beaches, Inc. to investigate the source and origin of water damages found in the area surrounding the kitchen. On or about August 10, 2023, Complainant entered into a contract with Policyholder Advocates Inc (hereinafter “Public Adjuster”). Subsequently, the same day, the Public Adjuster conducted an inspection of the property and took photographs. On or about August 11, 2023, Insurer sent Complainants a written correspondence acknowledging the claim and stated a determination would be made upon investigation. This however was a misrepresentation. Despite all investigation and supplemental information in its possession, Insurer still did not timely provide a coverage determination. On or about August 14, 2023, the Public Adjuster produced an estimate totaling $44,757.11 in actual cash value (“ACV”) for the damages. On or about August 15, 2023, Insurer hired an Independent Adjuster (hereinafter “Independent Adjuster”) on behalf of Compass Adjusting Services Inc. An inspection of the property was conducted on or about August 15, 2023. However, upon completion of such inspections and being in receipt of supplemental evidence, Insurer still failed to provide any form of status update or coverage determination. On or about August 21, 2023, Complainants and their agents sent Insurer an executed Sworn Proof of Loss Statement. Under Fla. Stat. 627.4137, Insurer had 30 days from the SPOL to provide some form of coverage decision. Here, Insurer failed to acknowledge the SPOL in whole, and thus violated the statutory requirement. By October 10, 2023, Insurer had violated Fla. Stat. 626.70131(7)(a), by failing to determine coverage within the 60-day period required by Florida Law. Instead, Insurer chose to retain an Engineer on or about October 18, 2023, 8 days past the violation, to conduct further inspections. Upon information and belief, Insurer sought to retain an engineer to cause unduly delay in the claims resolution process. On or about October 18, 2023, Insurer retained an engineer, Root Cause Consulting to inspect the subject property. Upon completing such inspection, Insurer failed to update or produce any coverage determination. It wasn’t until November 9, 2023, 22 days later, that Insurer sought to provide some form of claim update. Here, Insurer provided no substantive information regarding the resolution of the claim, other than the fact that investigation is still pending as it is waiting on the engineer’s report. Thus, no determination could be made. Insurer’s letter was vague, overly broad, and entirely devoid of any meaningful reasoning for the delay. On or about November 10, 2023, an engineer report was produced. On or about November 15, 2023, Insurer sent a coverage determination letter resulting in a denial of the claim. In this letter, Insurer recognizes the damages made to the subject property, as confirmed by the public adjuster, however, states the damages were a result of “wear, tear and deterioration”. Despite claiming that damages were not covered, Insurer’s correspondence failed to specify how they were calculated. Instead, Insurer merely attached a denial letter without an estimate and without context, relying on the assumption that an unqualified recipient would be unable to decipher the values or identify the omissions This conduct is a clear misrepresentation of material information, designed to minimize the payout to Complainant. By failing to provide transparency regarding the scope and location of the damages Insurer allegedly evaluated, Insurer misled Complainant regarding the extent of the covered loss. This deliberate misrepresentation constitutes a violation of Fla. Stat. 626.9541(1)(i)(2), which prohibits insurers from knowingly misrepresenting pertinent facts or policy provisions to reduce or deny valid claims. Pursuant to Fla. Stat. 626.9541(1)(i)(3)(f), Insurers are required to provide a reasonable explanation for the denial of a claim. In this case, Insurer's denial was wholly inadequate and failed to meet this standard. Upon information and belief, Insurer regularly uses this tactic to egregiously underpay rightful remedies owed to their insureds. The claim file was open for about 96 days, during which Insurer inspected the property, without acknowledging the Public Adjuster’s estimate and without addressing the contents or undertaking any additional efforts to investigate. Insurer did not retain an Engineer until they exceeded the 60-day deadline as explained in Fla. Stat. 626.9541(1)(i)(4). On or about December 11, 2023, Complainant retained Brownfish Inspections (hereinafter “Certified Microbial Investigator”), to investigate the source and origin of water damages. The Certified Microbial Investigator conducted an inspection of the property and took photographs with an invoice estimating $375 for the costs on or about December 15, 2023. On or about January 5, 2024, Complainant retained Mike The Plumber Services (hereinafter “Plumber”), to repair the broken drain line. The Plumber repaired the broken drain line and investigated other plumbing to repair if necessary with an invoice estimating $571.65 for the costs on or about January 5, 2024. All supplemental information was promptly sent to Insurer upon possession. Insurer, however, failed to recognize any such supplemental information being in clear violation of Fla. Stat. 626.9541(1)(i)(3)(c). By failing to consider the new evidence presented or even slightly investigate the claim, the Insurer is in clear violation of Fla. Stat. 626.9541 (1)(1)(3)(d), which prohibits insurers from denying claims without properly evaluating new information. On or about January 19, 2024, Complainant and their agents once again, retained Mike The Plumber Services (hereinafter “Plumber”) to mitigate the damages. Insurer, yet again, refused to review, acknowledge or respond to this supplemental information. Here, Complainants and their agents acted within their contractual duty to mitigate damages and preserve the subject property. Insurer, however, has failed to reinspect, provide coverage, or fulfill their contractual obligations by acknowledging the mitigation and repair work being done to the subject property. Till date, Insurer has refused to acknowledge the supplemental information and provide the rightful remedies owed to Complainant. Upon information and belief, Insurer has implemented an unreasonable company-wide policy to rely solely and heavily upon homeowners, most of whom have no background or knowledge in any of the trades involved in diagnosing a loss, to report losses with almost expert accuracy. This policy is not in line with Insurer’s duty of a “fair and honest treatment of the claimant” as it seeks only to protect Insurer’s interests. Based on the events described above, it is clear that Insurer conducted an improper and haste investigation to intentionally minimize its liability, contrary to the policy and Florida law’s requirements. Moreover, Insurer has misrepresented pertinent facts and/or insurance policy provisions relating to coverages at issue, and delayed the resolution of the claim by engaging in conduct to deny or reduce recovery to the Insureds. These tactics are believed to be the general business practices of this Insurer. Insurer can cure its bad faith conduct by: 1) accepting the Insureds’ damage claim as compensable, and agreeing to pay the claim in accordance with the policy in the amount of $66,679.00, plus interest, prior to the expiration of the cure period, 2) reviewing and responding to all communications from the Insureds and their agents, including the request for a complete copy of the Policy. PLEASE GOVERN YOURSELF ACCORDINGLY.
Comments
User Id Date Added Comment
jdonner@slideinsurance.com 04-01-2025 Please allow this correspondence to serve as Slide Insurance Company’s (“Slide”)’s response to the Civil Remedy Notice (“CRN”) that was filed on behalf of Hanh Freund and Dorit Freund (“Insureds”). Herein, we include a brief factual history of the underlying claim and actions by Slide which reveals it has acted properly in responding to the underlying claim and in compliance with its contractual and legal obligations. Slide denies each and every allegation brought forth in the CRN and denies any wrongdoing in the handling of the underlying claim. Additionally, Slide denies violating any Florida Statute or Administrative Code as set forth more specifically herein. Moreover, Slide denies violating any provisions or duties set forth in the applicable policy of insurance. Slide further states that the facts and circumstances that are set forth in the CRN, while incomplete and misleading, do not give rise to any violation of any statute or policy provision referenced in the Notice. Furthermore, Slide challenges the validity of the CRN for lacking specificity. See, e.g., Julien v. United Prop. & Cas. Ins. Co., 311 So.3d 875, 879 (Fla. 4th DCA 2021) (affirming dismissal for civil remedy notice’s failure to either strictly, or substantially, comply with statutory specificity requirement); Demase v. State Farm Florida Insurance Company, 351 So.3d 136, 138-39 (Fla. 5th 2022) (holding that the trial court properly determined that a civil remedy notice that failed to state with specificity the relevant policy language was legally insufficient). Finally, the CRN is improper as the Insureds failed to establish that Slide breached the policy of insurance, as required by Fla. Stat. § 624.1551. CLAIM FACTS The Insured filed a claim on August 11, 2023, for damage to their property from a kitchen sink leak. The date of loss was reported as August 3, 2023. Slide acknowledged receipt of the claim and assigned a licensed field adjuster to inspect the property. The inspection on August 15, 2023, revealed water damage to the kitchen sink base cabinet. On August 30, 2023, Slide received an executed Sworn Proof of Loss totaling $42,257.11 based on an estimate for the same value from Policyholder Advocates, Inc. On October 18, 2023, Yamil Kuri with Root Cause inspected the property on Slide’s behalf. On November 15, 2023, Slide issued a letter to the Insureds detailing its decision to deny coverage for the claim pursuant to the policy’s terms, limitations, exclusions, conditions, and endorsements. On January 19, 2024, Slide received a Notice of Intent to Initiate Litigation from Insureds to which Slide responded by maintaining its decision to deny coverage for the claim but also offering money to try to settle the claim. On March 7, 2024, Slide was served a Complaint for breach of contract regarding the subject claim (Case No.: 2024-CC-002220). On July 28, 2024, Slide received a Notice of Voluntary Dismissal without Prejudice for Case No.: 2024-CC-002220. No other information or documentation was provided to Slide prior to receipt of subject civil remedy notice. Slide maintains that it has acted in accordance with the terms of the subject insurance policy and the law in its adjustment of the claim. The facts and circumstances set forth in the CRN are misleading, incomplete, and do not support the allegations of claim denial. The facts show Slide promptly investigated the loss, made communications as necessary to adjust the claim, and notified the Insured and/or their representatives of the coverage decision and relevant policy provisions. To date, neither the Insured nor their representatives have presented any information that would alter Slide’s understanding of the loss and coverage. REASON FOR THE NOTICE The CRN alleges five (5) reasons for the filing of the Notice. However, no specific facts or circumstances are provided to support these allegations. Slide promptly acknowledged the claim and timely initiated its investigation of the loss including inspection of the subject property. Slide acted in accordance with its duties and obligations pursuant to the policy of insurance. Thus, Slide asserts that these allegations are without basis and therefore denied. ALLEGED STATUTORY VIOLATIONS The CRN alleges multiple statutory violations. However, no specific facts or circumstances are provided to support these allegations. Notwithstanding, Slide denies each and every allegation of statutory violation individually as follows: 1. 624.155(1)(b)(1): Denied. The underlying claim was investigated and adjusted in as thorough and expedient a manner as possible. Following the investigation and evaluation of the underlying claim the Insured was notified of the coverage decision and assessment of damages pursuant to the policy ’s terms, conditions, endorsements, limitations, and exclusions. The Insured has submitted absolutely no facts or circumstances supporting this allegation. 2. 626.9541(1)(i)(2): Denied. This allegation is without basis. Slide has adopted and implemented standards for the proper investigation of claims at all times during the investigation of the subject matter. The aforementioned facts demonstrate that Slide employed proper and customary claims practices in the investigation and adjustment of this claim including, but not limited to, prompt inspection of the Insureds’ property and timely communications with the Insureds and/or their representatives. Accordingly, Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Finally, the Insureds have submitted absolutely no facts or circumstances supporting this allegation. 3. 626.9541(1)(i)(3)(a): Denied. This allegation is without basis. Slide has adopted and implemented standards for the proper investigation of claims at all times during the investigation of the subject matter. The aforementioned facts demonstrate that Slide employed proper and customary claims practices in the investigation and adjustment of this claim including, but not limited to, prompt inspection of the Insureds’ property and timely communications with the Insureds and/or their representatives. Accordingly, Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Finally, the Insureds have submitted absolutely no facts or circumstances supporting this allegation. 4. 626.9541(1)(i)(3)(c): Denied. This allegation is without basis. Slide has consistently acted promptly upon all communications with respect to this claim as previously outlined. Slide has adjusted the underlying loss in as thorough and expedient a manner as possible. Moreover, Slide routinely communicated with the Insureds and/or their representatives regarding the underlying claim. Thus, Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Any assertions to the contrary are unsupported by the facts. 5. 626.9541(1)(i)(3)(d): Denied. This allegation is without basis. Slide has consistently acted promptly upon all communications with respect to this claim as previously outlined. Slide has adjusted the underlying loss in as thorough and expedient a manner as possible. Moreover, Slide routinely communicated with the Insureds and/or their representatives regarding the underlying claim. Thus, Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Any assertions to the contrary are unsupported by the facts. 6. 626.9541(1)(i)(3)(f): Denied. This allegation is without basis. Slide has consistently acted promptly upon all communications with respect to this claim as previously outlined. Slide has adjusted the underlying loss in as thorough and expedient a manner as possible. Moreover, Slide routinely communicated with the Insureds and/or their representatives regarding the underlying claim. Thus, Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Any assertions to the contrary are unsupported by the facts. 7. 626.9541(1)(i)(4): Denied. This allegation is without basis. Slide has consistently acted promptly upon all communications with respect to this claim as previously outlined. Slide has adjusted the underlying loss in as thorough and expedient a manner as possible. Moreover, Slide routinely communicated with the Insureds and/or their representatives regarding the underlying claim. Thus, Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Any assertions to the contrary are unsupported by the facts. ALLEGED VIOLATIONS OF THE INSURANCE POLICY The CRN fails to allege specific violations of the insurance policy and provides no specific facts or circumstances of wrongdoing. The boilerplate CRN merely sets forth blanket allegations of wrongdoing, without further information. As such, the CRN is defective, as it failed to specifically identify the policy language that is the subject of the alleged violation and further failed to include sufficient facts to put Slide on notice of the alleged violations. Notwithstanding, Slide denies any and all allegations of policy violations. All actions by Slide were done in compliance with the applicable Policy. As indicated above, Slide thoroughly investigated the reported loss including inspection of the Insured’s property. Thus, it is clear that Slide has acted in compliance with the Policy. Slide asserts that it has at all times complied with the terms of the Policy and has complied with all applicable provisions of the Policy and Florida Statutes in the handling of this matter. STATEMENTS AS TO CURING THE DEFECTS OUTLINED IN THE NOTICE The CRN asserts that Slide must tender all insurance benefits due and owing. Nevertheless, the method for curing violations alleged in a Civil Remedy Notice is not determined by the Insureds. Talat Enterprises, Inc. v. Aetna Casualty Surety Co., 753 So. 2d So. 2d 1278 (Fla. 2000). Accordingly, Florida Statutes Section 624.155 does not impose on an insurer the obligation to pay whatever the Insureds demands. Section 624.155(2)(d) would have no effect or purpose under such an interpretation. Thus, Slide reasserts that it has acted in good faith towards its Insureds at all times. Slide references to all the facts herein, which unequivocally demonstrate Slide’s expedient and timely administration of the Insureds’ claim. Slide further asserts its full and strict compliance with the Policy and reiterates that it has acted properly in responding to the underlying claim in compliance with its contractual and legal obligations. Slide denies any wrongdoing in the handling of the underlying claim. Additionally, Slide denies violating any Florida Statute, Administrative Code, or code of ethics. CONCLUSION In conclusion, the documented facts of this claim establish that Slide acted diligently in its claims response and adequately performed its obligations under the policy of insurance and Florida law. Thus, the facts contradict all allegations that Slide has in any manner acted improperly or contrary to its contractual obligations to the Insureds in this claim. Herein, Slide has attempted to fully and adequately respond to the allegations the Insureds allege in the Civil Remedy Notice of Insurer Violation filed with the Department. Should there be any questions or further inquiry with respect to this matter, please contact the undersigned at (813) 761-1866 or at jdonner@slideinsurance.com. Sincerely, /s/ Jessica Donner Jessica Donner, Esq. Staff Counsel
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