Civil Remedy Notice of Insurer Violations
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Filing Number:     811308
Filing Accepted:  3/14/2025
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Complainant
Last/Business Name *  
CUNNINGHAM   First Name   VERNON
Street Address * 7798 BURNT OAK TRAIL
City, State Zip * JACKSONVILLE, FL 32256
Email Address * MCKENZIE@GREENLAWGRP.COM
Complainant Type: * Insured
Insured
Last/Business Name*   CUNNINGHAM   First Name   VERNON
Policy # * EDH5370626-02 Claim #* EDI965141
Attorney
Attorney is Applicable
Last Name* GREEN First Name * PAUL Initial
Street Address* 8833 PERIMETER PARK BLVD SUITE 104
City, State Zip* JACKSONVILLE , FL 32216
Email Address * PAUL@GREENLAWGRP.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   EDISON INSURANCE COMPANY
NAIC Company Code 12482
 
Name of individual responsible for violation (if any):* MARY BOLAND AND ALL OTHER SUPERVISORS
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Unsatisfactory Settlement Offer
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)(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.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

See below
 
* 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 June 28th, 2024, Vernon Cunningham (hereinafter “INSURED”), suffered property damage at their property located at 7798 Burnt Oak Trail Jacksonville, FL 32256. The property suffered extensive damage to the roof. Edison Insurance Company. (hereinafter “EDISON”) issued an insurance policy for the Insured’s property, Policy Number EDH5370626-02, which was in full force and effect on the date of the loss. The loss was the result of a significant windstorm. Shortly following the loss, the Insured retained the Green Law Group (hereinafter “FIRM”) to help expedite the claim in order to restore the property to its pre-loss condition. FIRM timely notified EDISON of the damages sustained to the property and contemporaneously provided an estimate of the damages in the amount of $68,250.39. Despite demand of payment, EDISON has failed or refused to pay full value to protect and return property to pre-loss EDISON ’s refusal to adequately and otherwise make INSURED whole, constitutes a breach of contract. As a result of EDISON ‘’forementioned breach of contract, it has become necessary for INSURED to retain the services of FIRM. EDISON has engaged in a customary business practice and a deliberate course of conduct to hinder resolution of its claims until they enter litigation EDISON regularly and consistently “shuffles” desk adjusters when the undersigned attorney calls to discuss claims. One adjuster will imply he can help on the claim but after several minutes states that he does not have the authority to settle the claim and another desk adjuster is needed for that claim. This practice is used solely to insulate EDISON in litigation by saying that their adjusters are available to adjust and settle claims and are not avoiding settling. However, all is doing is “passing off” a claim from one adjuster to another in an effort to delay and frustrate the process. EDISON regularly and consistently denies justified claims outright, omits or denies specific line items required to properly repair/replace a homeowner’s roof, and uses deceptive tactics, some, aforementioned, to prolong the process in a hope that the homeowner will cancel his retainer with the FIRM. It has become a pattern of practice for EDISON to not settle claims when it has the ability to do so and these dilatory tactics serve no purpose other than to increase profits. EDISON has violated the following statutory provisions: §642.155(1)(b)(1) - Not attempting in good faith to settle claims when, under all circumstances, it could and should have done so, had it acted fairly and honestly towards its insured and with due regards 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 reasonable clear, under one portion of the insurance policy coverage in order to influence settlement under other provisions 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) – Committing or performing with such frequency as to indicate a general business practice any of the following: (a) Failing to adopt and implement standards for the proper investigation of claims; (b) Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue; (c) Failing to acknowledge and act promptly upon communications with respect to claims; (d) Denying claims without conducting reasonable investigations based upon available information; (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 with 30 days after proof-of-loss statements have been completed; (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; (g) Failing to promptly notify the insured of any additional information necessary for the processing of a claim; (h) Failing to clearly explain the nature of the requested information and the reasons why such information is necessary. To remedy this Civil Remedy Notice and to cure the conduct giving rise to the violations described herein, EDISON must immediately: (i) tender the full remaining payment to FIRM, on behalf of INSURED; (ii) make payment of any pre-judgment interest owed under Florida law, including §627.70131(5)(a), which is accruing daily; (iii) make payment for the additional expense incurred by the insured in hiring an attorney; and (iv) implement appropriate standards and procedures for claims investigations and resolution in regard to the outstanding amount of this Claim. The aforementioned payments should be tendered to the insured’s attorneys at Green Law Group 8833 Perimeter Park Blvd., Suite 104, Jacksonville, Florida 32216.
Comments
User Id Date Added Comment
jbosch@qpwblaw.com 05-08-2025 VIA DFS WEBSITE Florida Department of Insurance Civil Remedy Section 200 East Gaines Street Tallahassee, Florida 32399 Complainant: Vernon Cunningham Claim No: EDI965141 (“subject claim”) Policy No: EDH5370626-02 (“policy”) Loss Location: 7798 Burnt Oak Trail, Jacksonville, FL 32256 (“property”) CRN Filing No: 811308 CRN Acceptance Date: 3/14/2025 RE: CIVIL REMEDY NOTICE - DFS FILING NUMBER 811308 Dear Sir or Madam: The undersigned counsel represents Edison Insurance Company (“Edison”) in regard to the alleged dispute as to the subject claim number listed above involving an alleged windstorm with a date of loss of on or June 28, 2024, made under the Policy of insurance Edison issued to the Insureds, Vernon Cunningham and Christine Cunningham. This correspondence constitutes Edison Insurance Company’s response to the Civil Remedy Notice of Insurer Violations (“Notice” or “CRN”) filed on behalf of Vernon Cunningham (referenced herein as “Insureds” or “Complainant”) regarding the claim listed above. Based on the below response, the Civil Remedy Notice should be rejected and returned by the Department of Financial Services as it is substantively defective and objectionable for the reasons stated herein, and, without waiving objections, as it completely misstates the facts surrounding this claim. Please note that the CRN was filed on behalf of only one Insured/Complainant and left out the second Insured under the Policy, Ms. Christine Cunningham ALLEGED STATUTORY VIOLATIONS 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 specifically denies the allegation that it has violated the above referenced statute. Edison did not violate these provisions. The CRN does not include any facts to support this allegation. Edison conducted thorough investigations in good faith and issued its coverage determination based on the Policy’s provisions, conditions, exclusions and endorsements. 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 specifically denies the allegation that it has violated the above referenced statute. Edison did not violate these provisions. The CRN does not include any facts to support this allegation. Edison conducted thorough investigations in good faith and issued payments accordingly. 626.954(1)(i)(2): A material misrepresentation made to an Insureds 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. Edison specifically denies the allegation that it has violated the above referenced statute. Edison did not violate these provisions. The CRN does not include any facts to support this allegation. Edison conducted a thorough investigation in good faith. Simply because the outcome of Edison’s investigation revealed covered damages less than Complainant’s unjust demand for compensation, does not mean that Edison has violated the above statute. 626.9541(1)(i)(3)(a): Failing to adopt and implement standards for the proper investigation of claims. Edison specifically denies the Complainant’s allegation that it has violated the above referenced statute. The CRN does not include any facts to support this allegation. Edison did not fail to adopt and implement standards for the proper investigation of the claim. 626.9541(1)(i)(3)(b): Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue. Edison specifically denies the Complainant’s allegation that it has violated the above referenced statute. The CRN does not include any facts to support this allegation. This CRN does not indicate which facts or provisions have been misrepresented. Edison did not make any misrepresentations regarding this claim or the policy. This allegation is without merit and patently false. 626.9541(1)(i)(3)(c): Failing to acknowledge and act promptly upon communications for the proper investigation of claims. Edison specifically denies the Complainant’s allegation that it has violated the above referenced statute. The CRN does not include any facts to support this allegation. Edison conducted a thorough investigation in good faith and promptly and continually communicated with the insureds and their representatives regarding the Claim. This allegation is without merit. 626.9541(1)(i)(3)(d): Denying claims without conducting reasonable investigations based upon available information. Edison specifically denies the Complainant’s allegation that it has violated the above referenced statute. The CRN does not include any facts to support this allegation. Edison conducted a thorough investigation in good faith and issued payments accordingly. 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. Edison specifically denies the Complainant’s allegation that it has violated the above referenced statute. The CRN does not include any facts to support this allegation. Edison conducted a thorough investigation in good faith and issued its coverage determination based on the Policy’s provisions, conditions, exclusions and endorsements. This allegation is without merit. 626.9541(1)(i)(3)(f): Failing to promptly provide a reasonable explanation in writing to the insured of the basis of 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 specifically denies the Complainant’s allegation that it has violated the above referenced statute. The CRN does not include any facts to support this allegation. Edison conducted thorough investigations in good faith and issued its coverage determination based on the Policy’s provisions, conditions, exclusions and endorsements. This Coverage Determination correspondence specifically referenced all claimed damages and conclusions regarding each, and enclosed additional information relating to the claim, as well as information relating to the Department of Financial Services mediation services. This allegation is without merit. 626.9541(1)(i)(3)(g): Failing to promptly notify the insured of any additional information necessary for the processing of a claim. Edison specifically denies the allegation that it has violated the above referenced statute. Edison did not violate these provisions. The CRN does not include any facts to support this allegation. Edison conducted a thorough investigation in good faith and promptly and continually communicated with the insureds and their representatives regarding the Claim. This allegation is without merit. 626.9541(1)(i)(3)(h): Failing to clearly explain the nature of the requested information and the reasons why such information is necessary. Edison specifically denies the allegation that it has violated the above-mentioned statute. Edison did not violate these provisions. The CRN does not include any facts to support this allegation. Edison conducted a thorough investigation in good faith and promptly and continually communicated with the insureds and their representatives regarding the Claim. This allegation is without merit. In addition to the allegations specifically denied above, Edison generally denies all allegations presented in this CRN, as Edison has not violated any statute, Code or Rule. SPECIFICITY REQUIREMENTS Florida Statute requires that a CRN state the facts and circumstances giving rise to the alleged violations with specificity sufficient to allow an insurer to “cure” the alleged violations within the sixty-day statutory period. See Fla. Stat. § 624. 155(3)(b)(2). See also Lane v. Westfield Ins. Co., 862 So. 2d 774, 777 (Fla. 5th DCA 2003), Talat Enterprises, Inc. v. Aetna Cas. & Sur. Co., 753 So. 2d 1278, 1283 (Fla. 2000). However, here, the CRN is deficient and defective in that it fails to state with sufficient specificity the necessary facts in support of the Insured’s contentions, including but not limited to, those that would be necessary for Edison to “cure” the alleged violations. Further, the subject CRN provides what appears to be several boilerplate and conclusory statements, which fail to describe any accurate facts constituting violations of the statutes cited therein. Thus, because the allegations in the CRN are incomplete and incorrect, they fail to provide actual notice of the specific allegations and the actions that Edison could undertake to cure any alleged violations. 316, Inc. v. Maryland Cas. Co., 625 F. Supp. 2d 1187, 1193 (N. D. Fla. 2008). Blanket references to policy provisions and statutes without specification deems the Civil Remedy Notice deficient. Julien v. United Property and Casualty Insurance Co., 311 So. 3d 875 (Fla. 4th DCA 2021). For the reasons set forth herein, Edison hereby objects to the subject CRN and states it does not intend to waive, ratify or otherwise accept the deficiencies in the CRN, and reserves the right to contest the legal adequacy of the CRN hereinafter as appropriate. As to the content of the CRN here, it is important to note that said CRN is a nullity and should be rejected because the CRN fails to comply with the specific requirements mandated by Florida Statutes §624.155. Specifically, Fla. Stat. § 624.155(3)(b)(2) requires the Complainant to set forth with specificity, sufficient factual allegations to state a prima facie case of an insurer violation, so as to put the insurer on notice and be afforded the opportunity to cure the deficiency. However, the Insured failed to do so in the subject CRN and instead only included conclusory statements, which lack even minimal specificity and/or lack the underlying factual basis to support them. The Insured’s failure to describe any actual facts or circumstances to support the alleged statutory violations in the CRN precludes Edison from evaluating what error, if any, allegedly occurred during the claim process. Furthermore, 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 and incorrect allegations with no basis in fact or circumstances. Consequently, the CRN lacks the requisite minimal specificity and Edison is unable to determine what specifically the Complainant is claiming was done by or on behalf of Edison that constitutes the bad faith alleged. Due to the absence of specific and accurate information regarding the alleged acts or omissions by Edison which allegedly give rise to any violation of the Civil Remedy Statute, Edison is limited in its ability to set forth specific facts to address and/or refute these unsubstantiated assertions. Notwithstanding, Edison explicitly denies violations of any applicable Florida Statute in the adjustment of the subject claim and realleges and re-asserts its specific denials to the alleged violations in the subject CRN as set forth above. Edison maintains that it has acted and continues at all times to act in good faith during the investigation and adjustment of the Insured’s claim. Further, Edison wishes to dispel even the inference of any statutory violation and reiterates below the various reasons which clearly show the proper handling of the subject claim by Edison. Additionally, the CRN fails to state with specificity the facts relevant to any alleged policy violation. Julien v. United Property and Casualty Insurance Co., 311 So.3d 875 (Fla. 4th DCA 2021). The CRN merely refers to general language without any details as to how any provisions were actually violated. Thus, the CRN does not satisfy the requirements. BACKGROUND FACTS Aside from the fact that the allegations contained in the subject CRN lack specific facts, the tenor and inferences of statutory violations are wholly without merit, and Edison denies each and every one. Moreover, the Complainant/Insured reported this Claim more than two months late, which is not only a breach of the policy, but it also prejudiced the investigation of the Claim. Below are some of the relevant facts regarding the subject claim that the Insureds failed to include in the CRN. On September 3, 2024, attorney Brianne Paulston with Green Law Group contacted Edison to report a claim for windstorm damage sustained as a result of hail. It was reported that the damage was to the roof with creased and blown-back shingles along with damage to the gutters. No further information regarding the alleged damage was provided at the time of the initial reporting of the claim. Immediately, the next day, Edison sent correspondence to the Insureds acknowledging receipt of the claim. On September 4, 2024, Edison received correspondence from Insureds’ attorney representative at Green Law Group along with a letter of representation. On September 5, 2024, Edison issued its reservation of rights letter to the Insureds, and their attorney representative, informing them of their responsibilities under the policy. In its letter, Edison states: There is also the question of whether coverage under your policy applies to this loss. Under the policy conditions we need to further investigate this matter to provide a timely response. The nature of the coverage question that exists is whether you have complied with your duties after a loss as noted in “Section I – Conditions” of your policy. Edison also included with its letter, the Policy excerpt of “Your Duties After Loss.” Upon receiving notice of Insureds’ claim, Edison retained an independent field adjuster to inspect and evaluate the Insureds’ property and reported damages, which was conducted on September 16, 2024. On September 27, 2024, Edison issued correspondence to the Insureds, and their attorney representative, requesting documentation to proceed with the claim. In its letter, Edison requested the following: Home Inspection Report/4 point Report; Wind Mitigation Report; All Remedy Requests from House closing; Prior Roof Repair Documentation from when you bought the home until now; Who provided the date of loss of 6/28/2024?; and When was the damage noticed and who noticed the damage? On October 16, 2024, Edison issued correspondence to the Insureds, and their attorney representative, informing them that no documents have been received. Edison reiterated what documentation is needed and to forward it for evaluation of coverage for the subject loss. On December 11, 2024, Edison received the last of the documentation to review for evaluation. On January 30, 2025, Edison issued its Coverage Determination letter informing the Insureds, and their attorney representative, that coverage was afforded under the claim. Accordingly, Edison issued a net payment in the amount of $307.80 under Coverage A – Dwelling. Furthermore, Edison stated that the policy deductible of $1,000 was applied to the loss settlement. Edison also included with its letter, a Statement of Loss, Estimate, and applicable Policy language. On March 14, 2025, Edison received this Civil Remedy Notice. As you can see, Edison conducted a good faith comprehensive and prompt investigation of this claim. Edison consistently and promptly communicated with the Insureds and their representatives and conducted an inspection of the property. Edison afforded coverage based on an inspection and thorough investigation of the claim. Edison respectfully denies any wrongdoing in the adjustment and handling of the Subject Claim, and further denies any and all allegations that it violated any statutes. Instead, Edison acted quickly and responsibly and in accordance with the terms and provisions of the applicable Policy of insurance as well as with F.S. §624.155 and §626.9541 and its sub-parts. INACCURACY OF ALLEGATIONS IN THE SUBJECT CRN The case specific facts related to Edison’s handling of the subject claim provided above implicitly address many of the vague allegations contained within the Insured’s CRN and further establish that Edison undertook a thorough investigation in accordance with applicable statutory requirements and professional standards of care. It is important to note that the Insured has not provided any factual support for any of the above allegations. Instead, the facts support that Edison promptly contacted the Insured, inspected the claim shortly after it was reported, and issued a coverage determination based on a thorough investigation. When additional information was provided, Edison conducted additional investigations. The circumstances support that Edison conducted a good faith, thorough, prompt investigation with the information provided. The Insured is alleging bad faith in a scenario where Edison conducted a comprehensive, prompt investigation in good faith. Furthermore, 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 Civil Remedy Notice itself only provides completely false allegations with no basis in fact or circumstances. As clearly set forth above and contrary to the allegations set forth in the Notice, Edison’s investigations and adjusting of its Insured’s claim were prompt, thorough, and complete. Furthermore, the Insured has included absolutely no facts or evidence to support any claims in the Notice. All of these baseless claims support Edison’s position that the claim was properly adjusted, and the Insureds do not actually have any concrete facts to support a bad faith allegation. As mentioned, mere disagreement as to the coverage determination or the amount of coverage does not equate to bad faith. The Civil Remedy Notice does not show how Edison has failed to comply with the statutory provisions alleged to have been violated. Evidently, this Civil Remedy Notice was filed in bad faith, as it is being used as an improper mechanism designed solely for the purpose of intimidating Edison into potentially overpaying the Insured. For the aforementioned reasons, Edison categorically denies that it has acted with bad faith in connection with this claim. CONCLUSION The purpose of a CRN is to provide the insurer an opportunity to “cure” the alleged wrongdoing. Talat Enterprises, Inc. v. Aetna Casualty and Surety Co. , 753 So. 2d 1278 (Fla. 2000). However, the CRN here does not serve this purpose because it does not provide any means as to how Edison can “cure” the alleged defects. This failure to provide a proper opportunity to cure renders the CRN improper. Longpoint Condominium Associations v. Allstate Insurance Co. , 2005 WL 131580 (N. D. Fla. June 2, 2005). Moreover, the method for curing the violations alleged in a civil remedy notice are not determined by the insured. In Talat Enterprises, Inc. v. Aetna Casualty and Surety Co. , 753 So. 2d 1278 (Fla. 2000), the Florida Supreme Court accepted and quoted the reasoning of the court below in its opinion which stated in relevant part, as follows: Section 624. 155 does not impose on an insurer the obligation to pay whatever the insured demands. . . . Section 624. 155(2)(d) would have no effect or purpose under such an interpretation. The law does not support such an expansive and illogical reading of Fla. Stat. Ann. §624. 155(2)(d). . . . To cure an alleged violation and to avoid a civil action, an insurer must pay the claim . . . before the sixty days expire. Talat, 753 So2d at 1282 citing Talat Enterprises Inc. v. Aetna Cas. & Sur. Co., 952 F. Supp. 773, 777-778 (M. D. Fla. 1996). Here, Edison properly afforded coverage for the subject claim and investigated the loss within the statutory time frame. Edison denies all of the allegations contained in the subject CRN, which is defective and improper, as Edison has not violated any of the subject statutes. Edison further states that the accusations made against it in the subject CRN are patently false. In closing, Edison first believes that the Civil Remedy Notice should be rejected and returned by the Department of Financial Services due to its failure to comply with Florida Statute §624.155 and Florida Case law. Due to the lack of any factual and circumstantial basis to support the allegations therein, Edison respectfully requests, through this response, that the DFS return and reject the CRN for lack of specificity pursuant to Florida Statutes. Regardless of the rejection, Edison denies all allegations contained in the Civil Remedy Notice and submits there are no violations. While Edison’s response herein is meant to address the allegations in the Insured’s Notice, it is based upon the limited information provided in the Civil Remedy Notice and the information presented to date. If the Insured feels that Edison is not in possession of all the facts, please inform the undersigned immediately. Please note that Edison’s response is not necessarily exhaustive and does not preclude Edison or anyone on Edison’s behalf from asserting any other valid reason for seeking rejection and return of the Civil Remedy Notice. 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. On behalf of Edison, we trust that this response addresses the allegations in the Civil Remedy Notice of Insurer Violation. Should you have any questions regarding this matter or need anything further, please do not hesitate to contact the undersigned. Very Truly Yours, QUINTAIROS, PRIETO, WOOD & BOYER, P.A.
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