Civil Remedy Filing

Civil Remedy Notice of Insurer Violations

Filing Number: 811313

Filing Accepted: 3/14/2025

Print Filing

Complainant

Last/Business Name *

CRENSHAW

First Name

JORDAN

Street Address *

1211 E. 26TH ST.

City, State Zip *

LYNN HAVEN, FL 32444

Email Address *

SERVICE@LARLEGALGROUP.COM

Complainant Type: *

Insured

Last/Business Name*		CRENSHAW		First Name		JORDAN
Policy # *		2489226531		Claim #*		01000115794

Attorney

Attorney is Applicable

Last Name*	ROBINSON First Name * LUCIE Initial A.
Street Address*		111 NORTH ORANGE AVE., SUITE 800
City, State Zip*		ORLANDO , FLORIDA 32801
Email Address *		SERVICE@LARLEGALGROUP.COM

Violation

Insurer Type *		Authorized Insurer Unauthorized Insurer

Insurer Name
Insurer Name*		FRONTLINE INSURANCE UNLIMITED COMPANY
Insurer Name*
Street Address*
City, State Zip*		,
NAIC Company Code 10074

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

Reason for Notice *

	Unsatisfactory Settlement Offer
	Claim Delay
	Claim Denial
	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)(d)		Denying claims without conducting reasonable investigations based upon available information.

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

A copy of the policy has been requested.

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

March 14, 2025 Via E-mail and Certified Mail: dcollins@flhi.com Frontline Insurance Attn: Derrick Collins- Claims Adjuster P.O. Box 958405 Lake Mary, FL 32795 RE: Client: Jordan Mark Crenshaw Claim No.: 01000115794 Policy No.: 2489226531 DOL: January 9, 2024 Insured(s): Jordan Mark Crenshaw Insured Property: 1211 E. 26th St., Lynn Haven, FL 32444 To Whom It May Concern: Frontline Insurance (the “Carrier”) has committed the following in handling the Insureds’ claim: 1) failure to act in due diligence and good faith to resolve claims; 2) placing the financial interest of Carrier before that of the policy holders and Insureds; 3) looking for ways to deny benefit payments and otherwise “low ball” or “stone wall” claims; 4) not adjusting the claims promptly and fairly; 5) not attempting in good faith to settle claims; 6) looking for ways to delay benefit payments; 7) shifting the burden of investigating the loss onto the Insureds; 8) making material misrepresentations of the coverages afforded under the insurance policy; and 9) conducting inadequate investigations. The carrier has not attempted in good faith to settle the Insured’s claim when, under all circumstances, it could and should have done so, had it acted fairly and honestly toward its Insured and with due regard for its interests. The carrier has done everything possible to delay the claim and refuses to provide any sort of status of the claim, or to provide payment in full. Furthermore, the carrier is required to properly investigate and adjust claims and cannot place that burden upon the insured. This was made clear by the appellate court and the Florida Supreme Court in Allstate Indemnity Co. v. Ruiz, 899 So. 2d 1121 (Fla. 2005) (“The Legislature has clearly chosen to impose on the insurance companies a duty to use good faith and fair dealing in processing and litigating the claims of their insureds...”). The carrier was immediately put on notice of the Insured’s claim. Subsequently, the Insured submitted a loss package in the amount of $31,049.42 needed to restore the property back to its pre-loss condition to the carrier. The carrier failed to provide full and complete payment although the Carrier determined that there is coverage for the loss. Thereafter, the carrier has failed to provide adequate payment to restore the property to the pre-loss condition. The carrier alleged they provided a partial payment and coverage determination, but they failed to deliver the same to Claimant. Further, Carrier failed to call or email Claimant to confirm his address when mail was allegedly undeliverable. Such tactics were used to further delay processing of the claim. The Insured has complied with all the carrier’s requests to date and the carrier has still failed to treat this claim with good faith. More than a year has 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 full loss package and has not taken any meaningful ensuing action. It is clear that the carrier is not treating the Insured 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 Insured; failing to implement proper standards for the adjustment and investigation of claims and placing the company’s interests before the Insured’s interests; not training, supervising or managing adjusters properly so that prompt and full payments are made; refusing to pay the full amount owed to the insureds despite the fact that the damages are covered under the policy; looking for ways to delay full recovery or any recovery to the insureds; and refusing to provide coverage for the Insured’s loss in a timely manner. 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)(d), and Fla. Stat. §627.7152(9)(b) making a carrier’s response to a 10-day letter with a pre-suit settlement offer, request for mediation, or demand for appraisal mandatory. In short, Carrier is not acting with due regard for the Insured’s interests. In Florida, the work of adjusting insurance claims engages the public trust. The Carrier has breached this duty. The Carrier takes advantage of the knowledge imbalance and presents estimates which it knows are inadequate so that it may keep money that otherwise should go to the homeowner. The Carrier has intentionally undervalued the Insured’s loss so that it may render less than the full benefits due under the contract of insurance. The Carrier’s actions amount to but are not limited to the following: 1. Claim delay; 2. Not treating the policyholders with good faith claims conduct; 3. Looking for ways to reduce recovery to the Insureds; 4. Looking for ways to deny recovery to the Insureds; 5. Not adjusting claims and evaluating loss properly, promptly and fairly to provide full and prompt indemnity to the Insureds; 6. Not training, supervising or managing adjusters properly so that prompt and full payments are made, but rather placing the company’s interests before the policyholders’ interests; 7. Placing the financial interest of the Carrier over that of the Insureds; 8. Failing to pay interest on claim payments that are older than 90 days; 9. Shifting the burden of investigating the loss onto the Insureds; 10. Treating represented and unrepresented parties differently; 11. Requesting a re-inspection only after the Insureds retained a public adjuster; 12. Making material misrepresentations of the coverages afforded under the insurance policy; 13. Conducting inadequate investigations; 14. Failing to provide an estimate that complies with the Florida law. Therefore, to cure the defects outlined in this Civil Remedy Notice, the carrier must: 1) Pay the complete covered loss in the amount of $31,049.42 less any applicable deductible and prior payment(s); 2) Pay the Insured’s attorneys’ fees and costs as they have been forced to retain counsel; and 3) 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 printed out and mailed. Please do not hesitate to contact the undersigned at (407) 554-5836 if you have any questions or concerns. Very truly yours, LUCIE A. ROBINSON, PLLC /s/Lucie A. Robinson Lucie A. Robinson, Esq. For the Firm

Comments

User Id		Date Added		Comment
amaddox@penningtonlaw.com		05-09-2025		May 9, 2025 VIA ELECTRONIC FILING THROUGH WWW.FLDFS.COM – CIVIL REMEDY SYSTEM Lucie A. Robinson 111 North Orange Ave. Suite 800 Orlando, Florida 32801 service@larlegalgroup.com Civil Remedy Notice Response DFS Filing No.: 811313 Insured: Jordan Crenshaw Complainant: Jordan Crenshaw Policy Number: 2489226531 Claim Number: 01000115794 Date CRN Filed: March 14, 2025 Dear Counsel: Undersigned counsel and the law firm of Pennington, P.A. represent FIRST PROTECTIVE INSURANCE COMPANY (“FRONTLINE”) with regard to the above-referenced claim. This shall serve as FRONTLINE’s response to the Civil Remedy Notice of Insurer Violations (“CRN”), filed by or on behalf of Complainant JORDAN CRENSHAW (hereinafter “Complainant”), with the Florida Department of Financial Services (“DFS”) on March 14, 2025 (DFS Filing No. 811313). COMPLAINANT HAS FILED THIS CRN AGAINST THE INCORRECT PARTY The purpose of the Civil Remedy Notice requirement is to provide an insurer with notice of alleged bad faith and allow it the opportunity to investigate the claims against it prior to an insured initiating a bad faith lawsuit. Here, Complainant has filed a CRN against Frontline Insurance Unlimited Company, which is not the correct company. The correct insurance company, First Protective Insurance Company, has not received proper notice. As such, the CRN is invalid and CRN cannot satisfy the prerequisite for a bad faith lawsuit. COMPLAINANT IS NOT IN FULL COMPLIANCE WITH HIS DUTIES AFTER LOSS Complainant’s CRN is improper as he has failed to fully comply with his duties after loss prior to initiating this action against FRONTLINE, which has caused prejudice to FRONTLINE’s investigation of the claim. Complainant did not report the loss to FRONTLINE until 216 days after the alleged date of loss. The subject policy requires an insured “[g]ive prompt notice” to FRONTLINE of a loss. Complainant admitted during his recorded statement that he was aware his fence was damaged for some period time; yet he still failed to report the claim to FRONTLINE until he was prompted to do so by a general contractor. Additionally, Complainant failed to provide an executed Sworn Proof of Loss to FRONTLINE within sixty (60) days of FRONTLINE’s request, as required by the policy. The subject claim was reported to FRONTLINE on August 12, 2024, and a blank Sworn Proof of Loss form was subsequently provided to Complainant. FRONTLINE sent a follow-up request to Complainant on September 13, 2024. Despite these requests, Complainant has failed to provide an executed SPOL to FRONTLINE. As Complainant has not fully complied with his duties after loss, he cannot pursue an action against FRONTLINE. This includes the filing of a civil remedy notice. Nowhere within the CRN does Complainant specifically address why they failed to comply with their post-loss contractual obligations. Section 624.155, Florida Statutes cannot be reasonably interpreted in such a way that an insured could avoid complying with their duties after loss, thereby depriving an insurer of information necessary for its continued evaluation of a claim, while also imposing potential sanctions on the insurer. THE CRN FAILS TO COMPLY WITH THE SPECIFICITY REQUIREMENTS OF § 624.155, FLORIDA STATUTES Complainant fails to cite any specific policy language relevant to the violation. Complainant only states “[a] copy of the policy has been requested,” without any further specificity. A copy of the subject policy is available to Complainant through FRONTLINE’s online portal and a certified copy of the policy was sent to Complainant’s counsel on or about February 6, 2025. Despite having easy access to his policy, he has still neglected to include any policy language. This is a clear indication that the CRN consists of boilerplate language that is not specific to this claim; thus, the CRN cannot satisfy the prerequisite for a bad faith lawsuit. Complainant makes numerous allegations that rely directly on the policy. For example, he alleges FRONTLINE misrepresented insurance policy provisions relating to the coverages at issue and failed to promptly settle clams when it has become clear coverage is owed under certain portions of the policy. Yet Complainant does not identify what provisions of the policy were supposedly misrepresented, what coverages are at issue, or the provisions of the policy under which he asserts coverage is due. The policy language is clearly necessary in order to allow FRONTLINE the opportunity to further investigate the allegations of misconduct and make an informed decision as to how to proceed. Complainant’s failure to cite to specific policy language relevant to the violation is contrary to the specificity requirements of § 624.155, Fla. Stat. See also Julien v. United Property & Casualty Insurance Company, 311 So. 3d 875 (Fla. 4th DCA 2021) (broad references to policy language do not satisfy the specificity requirements of the civil remedy notice statute; such requirements are not mere technicalities). For this reason alone, the CRN is impermissibly vague and cannot serve as a prerequisite for pursuing a bad faith claim. The CRN is also impermissibly vague when describing the facts and circumstances that purportedly give rise to the claimed violations. The facts listed in the CRN appear to be boilerplate, copy-and-pasted allegations that could be asserted in any other CRN filed by Complainant’s counsel. The majority of the facts and circumstances section is comprised of lists of general allegations with no supporting facts. For example, the CRN states, “[t]he carrier has not attempted in good faith to settle the Insured’s claim,” and “[t]he carrier has done everything possible to deny the claim and refuses to provide any sort of status of the claim;” yet Complainant never describes evidentiary facts that support these baseless allegations or supposedly amount to bad faith. It is obvious Complainant’s CRN is nothing more than an effort to “check the box” of filing a CRN before pursuing a bad faith lawsuit. Complainant makes no genuine effort to put FRONTLINE on notice of the alleged violations, describe the facts and law supporting those allegations, or allow FRONTLINE to further investigate the allegations of misconduct and make an informed decision as to how to proceed. This is further evidenced by Complainant’s failure to comply with his duties after loss, as discussed above. The CRN does not meet the requirements of § 624.155, Fla. Stat. and cannot satisfy the conditions precedent for pursuing a bad faith claim. The defects cited above are not mere technicalities. Section 624.155(3)(b), Florida Statutes requires that CRNs be specific: (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: 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, she 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. (emphasis added). As Florida’s civil remedy notice procedure is in derogation of common law, § 624.155 “must be strictly construed.” Talat Enters., Inc. v. Aetna Cas. & Sur. Co., 753 So. 2d 1278, 1283 (Fla. 2000) see also Bay v. United Services Automobile Association, 305 So. 3d 294 (Fla. 4th DCA 2020). The CRN at issue simply does not meet these specificity requirements and is invalid. COMPLAINANT HAS MISREPRESENTED PERTINENT FACTS Complainant has made blatant misrepresentations as to certain information in a clear attempt to bolster his claim. These representations fail to rise to the good faith required of an insured and are further grounds for a finding that the CRN is invalid. First, Complainant claims FRONTLINE was immediately put on notice of the claim. Complainant neglects to mention that the claim was reported 216 days after the claimed date of loss. The falsity of this allegation is particularly egregious as Complainant acknowledged to FRONTLINE that he knew of the damage reported a significant amount of time prior to reporting the loss. This representation of fact constitutes a lack of good faith on the part of Complainant and should render the CRN invalid. Most egregiously, Complainant claims FRONTLINE failed to deliver payment to Complainant and further failed to contact him to confirm his address when mail was “allegedly undeliverable.” FRONTLINE made every attempt to ensure Complainant received payment but received no cooperation from Complainant or his counsel. Payment was issued to Complainant for $3,858.99 on or about October 30, 2024. On December 2, 2024, FRONTLINE received the claim determination package, including the check for policy benefits, stamped with “Return to Sender No Mail Receptacle, Unable to Forward.” A FRONTLINE desk adjuster emailed Complainant on December 5, 2024, requesting he confirm his address was correct. The adjuster also called Complainant to request the same but was unable to reach him and left a voicemail. No response was received from Complainant, so the check was mailed again on December 20, 2024, to the same address, as this was the only address in FRONTLINE’s file. On February 13, 2025, FRONTLINE, again, received the claim determination package and payment check stamped with “Return to Sender, Unclaimed, Unable to Forward.” FRONTLINE’s desk adjuster emailed Complainant’s counsel that same day to inform them of the delivery issues and requested instruction on how to proceed with getting the payment to their client. Complainant’s counsel informed that the check should be mailed to their office. FRONTLINE mailed the check in accordance with counsel’s request on February 14, 2025. The check was sent via USPS Priority Mail (Tracking No. 9405536208235282690177). Per the USPS tracking system, it was delivered to Complainant’s counsel on February 18, 2025. COMPLAINANT’S REASONS FOR NOTICE ARE UNSUPPORTED BY FACTS The CRN also fails to provide specific facts to support each of the alleged statutory violations. FRONTLINE specifically addresses the statutory violations in Complainant’s CRN as follows: 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. FRONTLINE fully complied with Florida law and regulations in the adjusting of this claim. As previously discussed at length, the CRN contains nothing more than a list of boilerplate allegations with no legitimate factual support. Additionally, FRONTLINE opened coverage and issued payment on the covered damage as soon as FRONTINE received and reviewed the reports from the HVAC expert and professional engineer it retained to inspect the property on its behalf. Based on these inspections, it was determined the claimed damage to the HVAC was covered under the policy. The HVAC expert determined that the replacement cost value of the HVAC was $4,858.99. After subtracting Complainant’s $1,000.00 deductible, FRONTLINE issued payment to Complainant for $3,858.99 based on this estimate. FRONTLINE sent the payment, a seven (7) page partial payment letter explaining the factual and contractual basis for FRONTLINE’s coverage determination, the HVAC expert report, and a breakdown of how the payment amount was calculated to Complainant on October 30, 2024. The letter explained the reasons for the coverage determination, including the engineer’s findings and supporting policy language. The coverage decision was also explained to Complainant over the phone by FRONTLINE’s desk adjuster on October 29, 2024. Complainant did not express any disagreement with the coverage determination. Over three (3) months later, FRONTLINE received a letter of representation from Complainant’s counsel on February 4, 2025. This was the first and only indication that there was any dispute as to the coverage determination, although FRONTLINE was never told what was specifically being disputed. FRONTLINE promptly acknowledged the LOR and sent Complainant’s counsel requested documents. FRONTLINE also informed Complainant’s counsel that the payment check had been returned to the desk adjuster on multiple occasions and requested instructions on how to ensure Complainant received it. Complainant’s counsel instructed the desk adjuster to mail it to their office on February 13, 2025, and FRONTLINE complied with that request on February 14, 2025. USPS confirmed delivery on February 18, 2025. This CRN was filed less than one (1) month later without any further communication from Complainant or his counsel. 626.9541(1)(i)(3)(a) – Failing to adopt and implement standards for the proper investigation of claims. 626.9541(1)(i)(3)(d) – Denying claims without conducting reasonable investigations based upon available information. Complainant cites no legitimate facts supporting these allegations nor does he identify any supposed failure in FRONTLINE’s standards or investigation process. The “facts and circumstances” section of the CRN contains only broad and baseless allegations, including that FRONTLINE “fail[ed] to implement proper standards for the adjustment and investigation of claims,” improperly trained, supervised, or managed adjusters, and refused to provide coverage for the Insured’s loss in a timely manner. Complainant provides no factual support for any of these allegations; in fact, Complainant provides no facts whatsoever regarding the investigation of the claim. He neglects to mention the FRONTLINE retained both an HVAC specialist and a professional engineer to inspect the claimed damage and provide opinions as to the cause of loss. In doing so, FRONTLINE went above and beyond what is required for adjusting claims. Complainant not only neglects to mention these inspections, but he has also neglected to furnish any factual support that contradicts the opinions of the engineer or supports issuance of payments for portions of the claim that were previously denied. 626.9541(1)(i)(3)(b) – Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue. Complainant’s boilerplate CRN does not identify any misrepresentations made by FRONTLINE. The contention that FRONTLINE misrepresented pertinent facts is completely unfounded. None of the facts he has included in the CRN, which are quite sparce, address this allegation, let alone support it. Ironically, Complainant is the one who has made misrepresentations of fact, as discussed in greater detail above. The assertion FRONTLINE misrepresented policy provisions is equally absurd and lacks any support. As discussed in great length above, Complainant has refused to identify any policy provisions or coverages at issue in this CRN. Suffice it to say he also fails to include any policy provisions that FRONTLINE allegedly misrepresented. COMPLAINANT’S CRN VIOLATES HIS DUTY TO ACT IN GOOD FAITH Pursuant to Section 624.155(5)(b)1., Fla. Stat., “[t]he insured, claimant, and representative of the insured or claimant have a duty to act in good faith in furnishing information regarding the claim, in making demands of the insurer, in setting deadlines, and in attempting to settle the claim.” Complainant and his representatives have failed to comply with this duty of good faith to furnish information regarding the claim by filing a CRN with insufficient facts, blatant misrepresentations, and misleading allegations. Complainant asserts he never received payment from FRONTLINE for this loss; yet, he never informed FRONTLINE of this issue. FRONTLINE contacted Complainant the first time it received returned mail, both via email and phone, with no response from Complainant. The second time FRONTLINE received return mail, it immediately informed Complainant’s counsel of the delivery issue and promptly mailed the payment as Complainant’s counsel instructed. USPS confirmed delivery on February 18, 2025. If the payment was not delivered to Complainant’s counsel, which seems highly unlikely in light of the tracking confirmation, FRONTLINE was not informed. Instead, Complaint’s counsel filed a CRN on his behalf just one (1) month after the check was reissued. Complainant has not made a good faith effort to resolve this claim or otherwise comply with his co-equal duty to act in good faith, as he provides no information that contradicts the facts and opinions regarding the loss stated in FRONTLINE’s claim determination letter. This letter was mailed, emailed, and verbally explained to Complainant in October of 2024. Had Complainant genuinely desired to resolve this claim, he would have provided information necessary to rebut the facts and opinions he claims are incorrect, rather than using the CRN process as a cudgel to try to extract a settlement. As a result, any future bad faith lawsuit must be dismissed. THE CURE DEMAND IS IMPROPER Complainant demands FRONTLINE pay the “complete covered loss” of his insurance claim in the amount of $31,049.42 but does not identify what he contends constitutes the “covered loss.” This is problematic for multiple reasons. First, FRONTLINE has already issued payment for the full replacement cost value (less Complainant’s deductible) of the portion of the loss it determined was covered. Further, FRONTLINE disputes that the amount of Complainant’s estimate is an accurate reflection of the damages for the reasons stated above and because Complainant never provided any information to FRONTLINE to contradict its engineer’s opinions or FRONTLINE’s coverage determination. Complainant’s estimate also contains a line item for his HVAC unit, which FRONTLINE has already issued payment for. Complainant also demands that FRONTLINE pay for expenses incurred in hiring his attorney. This demand is legally unsupported, as Florida no longer permits recovery of one-way attorneys’ fees. § 627.428, Fla. Stat., was repealed when Senate Bill 2A was signed into law in December 2022. Therefore, attorneys’ fees and costs are not due or owed at this time. Complainant is improperly demanding payment of an extracontractual benefit—i.e., attorneys’ fees and costs—that is not owed prior to the maturity of his bad faith claim. See Talat, 753 So. 2d at 1282 (“There is no reason why insureds would not demand also the advance payment of punitive damages and attorney’s fees. Section 624.155(2)(d) would have no effect or purpose under such an expansive and illogical reading of Fla. Stat. Ann. § 624.155(2)(d).”). Even if attorneys’ fees could be demanded, no amount of attorneys’ fees or costs is specified in the CRN. This is yet another vague element of the cure demand that renders the civil remedy notice defective. Complainant also improperly demands that FRONTLINE pay additional extracontractual damages that are not owed, i.e.: “[p]ay the statutory interest on the amount of unpaid damages from the date of loss to the date payment is finally made.” Section 627.70131(7)(a), Florida Statutes, only mandates payment of interest “from the date the insurer receives notice of the claim,” not the date of loss. Complainant reported this claim to FRONTLINE 216 days after the claimed date of loss. As such, Complainant is demanding FRONTLINE pay an additional 216 days of interest that is not warranted nor supported by the policy or Florida law. Thus, in order to meet his cure demand, FRONTLINE would have to afford extracontractual benefits, which additionally renders the civil remedy notice defective. CONCLUSION AND RESERVATION OF RIGHTS FRONTLINE respectfully and categorically denies without limitation all of Complainant’s allegations within the CRN, including but not limited to the alleged violations of the cited provisions of Florida law, regardless of whether or not the specific allegation was cited above. Frontline further denies any and all stated, implied, and/or unspecified allegations, including but not limited to denying any and all allegations of alleged improper claim handling, inadequate investigation, improper delay or denial, failing to adequately and promptly communicate, failing to provide reasonable explanations, failing to affirm or deny coverage, making misrepresentations, general business practices, unfair or deceptive trade practices, and/or unsatisfactory settlement offers or practices, and the like, whether or not specifically alleged by Complainant’s CRN. Frontline has not violated any applicable provision of Florida law in the handling of this claim. Accordingly, FRONTLINE objects to and denies the allegations of the CRN. The objections and denials herein are not necessarily exhaustive, and this response shall not prevent Frontline from asserting any other appropriate objections, denials, and/or defenses related to this claim and/or CRN. Moreover, due to the objections and defects discussed herein, the Department should strike and/or reject the CRN as invalid. As a final matter, it should be emphasized that any policy issued by FRONTLINE is governed by the policy’s terms, conditions, and exclusions together with any endorsements. This CRN response does not waive any such provisions of the policy. Furthermore, any action taken by or on behalf of FRONTLINE, any related insurance company, or its authorized representative(s), whether in the past or future, to investigate the alleged loss, to adjust any claim or request for payment, or in any way related to or arising out of the subject claim or loss, shall not waive any of the terms, conditions, or any other provisions of the policy. Sincerely, /s/ Annabelle L. Maddox Brian E. Chojnowski Annabelle L. Maddox PENNINGTON, P.A. Copy furnished to: Florida Department of Financial Services FIRST PROTECTIVE INSURANCE COMPANY d/b/a FRONTLINE INSURANCE

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