Civil Remedy Filing

Civil Remedy Notice of Insurer Violations

Filing Number: 811334

Filing Accepted: 3/14/2025

Print Filing

Complainant

Last/Business Name *

PARKER

First Name

BRADLEY

Street Address *

17266 GULF PINE CIRCLE

City, State Zip *

WELLINGTON, FL 33414

Email Address *

PARKER.BRADLEY2@GMAIL.COM

Complainant Type: *

Insured

Last/Business Name*		PARKER		First Name		BRADLEY
Policy # *		EDH5391649-02		Claim #*		EDI966088

Attorney

Attorney is Applicable

Last Name*	DEPALO First Name * JAMES "JIMMY" Initial
Street Address*		4887 BELFORT ROAD, SUITE 200
City, State Zip*		JACKSONVILLE , FL 32256
Email Address *		JDEPALO@MERLINLAWGROUP.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):* MICHAEL DANA BEARD, INDEPENDENT ADJUSTER DISPATCHED BY EDISON TO INSPECT THE PROPERTY. STEPHEN DUFF, ESTIMATOR LISTED ON THE INITIAL DAMAGE ESTIMATE, DESPITE NO MENTION OF MR. BEARD’S INSPECTION. TYRA HEWITT, ADJUSTER WHO STATED THAT THE INITIAL ESTI
Type of Insurance * Residential Property & Casualty

Reason for Notice *

	Claim Denial
	Claim Delay
	Unsatisfactory Settlement Offer
	Unfair Trade Practice
	Other : Violations of various statutes and Fla. Admin. code
	Other : Misconduct toward Insured
	Other : Unreasonable Investigation
	Other : Intentionally bullying Insured

* 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)(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.

Based on Bradley Parker’s best belief, the following portions of the policy are relevant: Homeowners HO3 Policy Declarations Coverages Limit of Liability Section 1 A. Dwelling $1,172,900 B. Other Structures $23,458 C. Personal Property $586,450 D. Loss of Use/ALE $117,290 Forms, Notices and Endorsements: EDI NTC 01 01 24 OIR-B1-1670 01 06 EDI HO3 OC 11 23 EDI PRI 06 14 EDI HOJ 01 23 EDI HO 03 04 23 OIR-B1-1655 02 10 EDI HO CDE 05 21 EDI HO ELE 06 21 EDI HO 04 41 06 14 EDI 19 06 14 EDI 24 01 24 EDI 04 16 06 14 EDI HO LO 06 14 EDI GC 01 06 14 EDI HO 04 96 06 14 EDI HO 04 01 09 16 EDI HO ML 06 23 EDI HO RCL 01 24 EDI HO 04 90 06 14 EDI HO 04 77 06 14 EDI SE 01 06 14 EDI HO 04 95 08 15 Endorsement Premium Details: Limit of Liability Ordinance or Law Coverage 25% of Coverage A Debris Removal $500 per occurrence 2% ($23,458) Hurricane Deductible OUTLINE OF YOUR EDISON INSURANCE COMPANY HO-3 HOMEOWNERS POLICY SECTION I - PROPERTY COVERAGE Coverage A - Dwelling Protects against covered loss to your dwelling and structures attached to your dwelling. It also protects against covered loss to building materials located on your residence premises which are being used in connection with your residence premises. Coverage B - Other Structures Protects against covered loss to structures on your residence premises not physically attached to the dwelling. This coverage does not apply to land, including land on which other structures are located. Additional Coverages These additional coverages include limitations and may not completely protect you against loss: • Debris Removal • Reasonable Repairs • Trees, Shrubs and Other Plants • Fire Department Service Charge • Property Removed • Credit Card, Fund Transfer Card, Forgery and Counterfeit Money • Loss Assessment • Collapse • Glass or Safety Glazing Material • Landlords Furnishings • "Fungi," Wet or Dry Rot, Yeast or Bacteria • Law and Ordinance PERILS INSURED AGAINST Coverage A - Dwelling and Coverage B - Other Structures This policy insures against risk of direct loss to covered property under Coverages A and B, unless not covered or excluded from coverage as described elsewhere in the policy. Loss Settlement For Coverage A - Dwelling, we will initially pay at least the actual cash value of the insured loss, less any applicable deductible. We shall pay any remaining amounts necessary to perform such repairs as work is performed and expenses are incurred or we will pay a licensed contractor after the insured signs a contract and as repairs are made to the covered property. If a total loss of the covered dwelling occurs, we shall pay the replacement cost coverage without reservation of any depreciation in value, subject to policy limits. HOMEOWNERS 3 -SPECIAL FORM SECTION I -PROPERTY COVERAGES A. Coverage A — Dwelling. 1. We cover: a. The dwelling on the "residence premises" shown in the Declarations, including structures attached to the dwelling; and b. Materials and supplies located on or next to the "residence premises" used to construct, alter or repair the dwelling or other structures on the “residence premises". This coverage does not apply to land, including landscaping and land on which the dwelling is located, except as otherwise provided under SECTION I Additional Coverages 3. Trees, Shrubs and Other Plants. This coverage does not apply to loss to “screened enclosures,” aluminum framed carports or awnings due to hurricane damage. B. Coverage B — Other Structures. 1. We cover other structures on the "residence premises" set apart from the dwelling by clear space. This includes structures connected to the dwelling by only a fence, utility line, or similar connection. This coverage does not apply to land, including landscaping and land on which the other structures are located, except as otherwise provided under SECTION I Additional Coverages 3. Trees, Shrubs and Other Plants. This coverage does not apply to loss to “screened enclosures,” aluminum framed carports or awnings due to hurricane damage. We do not cover other structures: 1. Used in whole or in part for “business”; or 2. Rented or held for rental to any person not a tenant of the dwelling, unless used solely as a private garage. The limit of liability for this coverage will not be more than the limit of liability shown on the Declarations for Coverage B. Use of this coverage does not reduce the Coverage A limit of liability. ADDITIONAL COVERAGES These additional coverages include limitations and may not completely protect you against loss: • Debris Removal • Reasonable Repairs • Trees, Shrubs and Other Plants • Fire Department Service Charge • Property Removed Credit Card, Fund Transfer Card, Forgery and Counterfeit Money • Loss Assessment • Collapse • Glass or Safety Glazing Material • Landlords Furnishings • "Fungi," Wet or Dry Rot, Yeast or Bacteria • Law and Ordinance LOSS SETTLEMENT For Coverage A - Dwelling, we will initially pay at least the actual cash value of the insured loss, less any applicable deductible. We shall pay any remaining amounts necessary to perform such repairs as work is performed and expenses are incurred or we will pay a licensed contractor after the insured signs a contract and as repairs are made to the covered property. If a total loss of the covered dwelling occurs, we shall pay the replacement cost coverage without reservation of any depreciation in value, subject to policy limits.

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

***ADDITIONAL STATUTORY PROVISIONS ALLEGED TO HAVE BEEN VIOLATED ARE AS FOLLOWS: *** §624.155 (5) No punitive damages shall be awarded under this section unless the acts giving rise to the violation occur with such frequency as to indicate a general business practice and these acts are: (a) Willful, wanton, and malicious; (b) In reckless disregard for the rights of any insured; or (c) In reckless disregard for the rights of a beneficiary under a life insurance contract; (8) The damages recoverable pursuant to this section shall include those damages which are a reasonably foreseeable result of a specified violation of this section by the authorized Insurer and may include an award or judgment in an amount that exceeds the policy limits. §Insurer’s duty to acknowledge communications regarding claims; investigation (3) Unless otherwise provided by the policy of insurance or by law, within 10 working days after an insurer receives proof of loss statements, the Insurer shall begin such investigation as is reasonably necessary unless the failure to begin such investigation is caused by factors beyond the control of the Insurer which reasonably prevent the commencement of such investigation. FLORIDA ADMINISTRATIVE CODE SECTIONS & OTHER APPLICABLE STATUTES Fla. Stat. §626.877 Every adjuster shall adjust or investigate every claim, damage, or loss made or occurring under an insurance contract, in accordance with the terms and conditions of the contract and of the applicable laws of this state. 69B-220.201(3)(b)(2) An adjuster shall adjust all claims strictly in accordance with the insurance contract. 69B-220.201(3)(c) An adjuster shall not approach investigations, adjustments, and settlements in a manner prejudicial to the insured. 69B-220.201(3)(f) An adjuster, upon undertaking the handling of a claim, shall act with dispatch and due diligence in achieving a proper disposition of the claim. 69B-220.201(3)(j) An adjuster shall not knowingly fail to advise a claimant of the claimant’s claim options in accordance with the terms and conditions of the insurance contract. 69B-220.201(3)(m) An adjuster shall not knowingly fail to advise a claimant of their rights in accordance with the terms and conditions of the contract and applicable laws of the state of Florida. In Florida, the adjustment of insurance claims is a matter of public trust, and EDISON INSURANCE COMPANY (the “Insurer” or “Edison”) breached this duty in its handling of Claim No. EDI966088 (the “Claim”) filed by Bradley Parker (the “Insured”) for substantial damage to his home, located at 17266 Gulf Pine Circle, Wellington, FL (the “Property”). The Property was covered under Policy No. EDH5391649-02 (the “Policy”). Edison's actions constitute statutory bad faith in violation of Florida Statutes, particularly under Section 624.155 and Section 626.9541, governing unfair claim settlement practices. Edison engaged in unfair, deceptive, and unlawful claim settlement practices, including failing to properly investigate, failing to promptly settle a valid claim, and undervaluing the loss. These actions constitute bad faith and entitle the Insured to statutory remedies, including damages beyond the policy limits. Rather than handling the claim in good faith, Edison engaged in a deliberate pattern of misconduct, which included failing to promptly pay all benefits due under the Policy, failing to fairly and thoroughly investigate the Claim, and placing its financial interests ahead of the Insured by undervaluing and delaying the claim. Additionally, Edison failed to properly train, evaluate, and manage adjusters to ensure clear streamlined communication, fair and accurate claims handling, failed to provide specific facts and reasons for non-payment of covered losses, and engaged in unfair claim underpayment and unreasonable delay, in violation of Florida law. On information and belief, Edison’s conduct is not an isolated incident but rather a systemic practice affecting numerous policyholders across Florida. If pervasive, Edison’s tactics indicate a deliberate business model designed to confuse, deny, underpay, and delay the payment of claims to maximize its revenues and investment income while minimizing claim payouts. On October 9, 2024, the Property suffered significant damage due to Hurricane Milton, a covered peril under the Policy. The Insured promptly reported the loss to Edison and retained Public Adjuster Robert Soler (“Mr. Soler”) of Horizon Public Adjusters LLC to assist in the claim. On or about October 16, 2024, Edison dispatched independent adjuster Michael Dana Beard (“Mr. Beard”) to inspect the Property. However, on November 3, 2024, Edison provided the Insured with a damage estimate that made no mention of Mr. Beard’s inspection. Instead, the estimate was attributed to Stephen Duff (“Mr. Duff”), raising serious concerns about the integrity of Edison’s damage assessment. The estimate grossly undervalued the loss, listing a total replacement cost value (“RCV”) of $22,149.05, with depreciation of $547.48, leaving an actual cash value (“ACV”) of $21,601.57—an amount far below the actual damage sustained. Edison adjuster Tyra Hewitt (“Mrs. Hewitt”) misled the Insured by stating that the estimate was “preliminary in nature” and that no final coverage determination had been made. However, the very next day, on November 4, 2024, Edison contradicted its own statements by issuing a Coverage Determination Letter through adjuster Mary Heath (“Mrs. Heath”), denying the claim outright. The letter stated: “Based on the estimate, the damage to your property was less than your deductible. Therefore, we are unable to make payment for your claim.” The enclosed estimate was identical to the grossly inadequate assessment from November 3, 2024, effectively serving as a de facto denial while Edison deliberately misrepresented the status of its “investigation.” This contradictory and deceptive conduct is a clear violation of Florida law, which requires insurers to conduct a full and fair investigation before denying a claim. Recognizing the severe undervaluation of the claim, Mr. Soler took immediate corrective action on November 11, 2024, submitting a Proof of Loss along with a detailed estimate of damages totaling $468,102.98 RCV and $466,835.04 ACV. He also provided over 250 high-resolution photos documenting the interior and exterior damage, as well as a contents inventory listing the personal property affected by the Loss. Rather than acknowledging or addressing these clear and substantial damages, Edison deliberately prolonged the process by passing the claim from one adjuster to another, leading to unnecessary delays and confusion: • November 12, 2024 – Adjuster Rasheda Stamps (“Mrs. Stamps”) acknowledged receipt of the Proof of Loss and confirmed that the documents had been uploaded for review by Supervising Adjuster Joy Chouest (“Mrs. Chouest”). • November 27, 2024 – Adjuster Kendal Gillard (“Mr. Gillard”) emailed the Insured, stating: “The claim has been reopened for supplement. PA estimate and RAD Drone reports have been received. We will reach out once the review is complete.” • December 3, 2024 – Adjuster Sheena Alexander (“Mrs. Alexander”) informed the Insured that a reinspection had been scheduled, while Ranell Green (“Mrs. Green”) stated that a desk adjuster was assigned, creating further delays. • December 13, 2024 – Paul Bogdan (“Mr. Bogdan”) conducted the reinspection, with both the Insured and Mr. Soler present. • January 10, 2025 – Mrs. Chouest falsely assured Mr. Soler that a determination would be provided that day, yet no determination was issued. Instead of conducting a transparent and good faith evaluation, Edison continued its pattern of conflicting estimates, adjuster swapping, and evasive responses, demonstrating an intentional strategy of bad faith claims handling. On January 24, 2025, Edison issued a settlement offer of $58,414.33, which was far below the actual damages sustained and failed to account for the Insured’s public adjuster’s documented estimates. The settlement was based on an estimate that deliberately omitted higher damage assessments and was issued without explanation for the discrepancies in the multiple estimates Edison had produced. Despite the Insured’s repeated efforts to seek clarification, Edison ignored further communications and failed to explain how the final settlement was reached. The deliberate omission of a higher estimate provided by adjuster Erica Pilgrom (“Mrs. Pilgrom”) on January 24, 2025, raises further concerns that Edison intentionally manipulated the claim valuation to minimize its payout obligations. Edison’s handling of this claim is not merely a case of poor claims management—it is a calculated bad faith scheme aimed at: • Minimizing payouts through fraudulent undervaluation. • Using delay tactics to wear down policyholders. • Confusing insureds with conflicting estimates and adjuster swapping. • Systematically underpaying claims while maximizing Edison’s financial gains. Despite having ample opportunity to conduct a full and fair investigation, Edison failed to provide just compensation, forcing the Insured to seek legal representation. To this day, the claim remains unresolved due to Edison’s deceptive and unlawful actions. A review of the claim documents and photographs demonstrates a mishandled, underpaid loss, deliberately undervalued as part of a widespread pattern of misconduct designed to maximize Edison’s profits. This conduct is unacceptable, unlawful, and a direct breach of the trust policyholders place in their insurer. As a direct result of Edison’s bad faith actions, the Insured was left with no choice but to retain legal counsel to compel Edison to properly investigate and pay the claim as required by Florida law. Edison Insurance Company has repeatedly violated Florida statutes through its bad faith handling of the insured’s claim. These violations include failing to settle in good faith, misrepresenting key facts, engaging in unreasonable delays, and failing to conduct a proper investigation. Despite clear evidence of extensive hurricane damage and a detailed proof of loss with supporting documentation, Edison refused to settle the claim promptly and fairly. Instead, it made an unreasonably low settlement offer, far below the documented damages. Additionally, Edison engaged in deceptive practices by issuing a settlement offer without proper justification, providing conflicting information, and initially calling its estimate “preliminary,” only to use the same estimate to deny the claim the following day. Edison intentionally delayed the claims process by repeatedly switching adjusters, causing unnecessary confusion and disruption. Between November 2024 and January 2025, at least six different adjusters handled the claim, preventing timely resolution. The insurer’s initial damage estimate omitted significant losses and failed to reflect the full extent of the damages. The final settlement offer disregarded the public adjuster’s assessment, and Edison failed to explain the discrepancies between its multiple conflicting estimates. Edison’s tactics appear to be part of a broader business strategy designed to underpay claims and delay payments, maximizing its financial gain at the expense of policyholders. If this conduct is widespread, it constitutes a clear violation of Florida’s insurance laws. Edison’s conduct violates multiple provisions of Florida law, including Florida Statutes § 626.9541(i) – Unfair Claim Settlement Practices. The insurer engaged in material misrepresentation by providing false information regarding the claim’s status and valuation in an attempt to settle for less than what the insured was entitled to receive. For example, adjuster Tyra Hewitt called the estimate “preliminary,” yet the next day, adjuster Mary Heath used the same estimate to deny the claim. Edison also omitted the findings of independent adjuster Michael Dana Beard, undermining the claim’s accuracy. Furthermore, Edison failed to properly investigate the claim by disregarding the findings of independent adjusters, swapping adjusters multiple times, and conducting a reinspection without issuing a revised determination. The insurer’s denial of the claim was unreasonable, as it stated the damages did not exceed the deductible, despite a public adjuster’s estimate of $468,102.98 RCV and $466,835.04 ACV, supported by over 250 high-resolution photos documenting extensive damage. Edison also failed to provide written justifications for the discrepancies in its multiple estimates and for its final settlement offer of $58,414.33—an amount significantly lower than the actual damage assessment. Additionally, Edison unlawfully altered or omitted key damage assessments without justification, violating Florida laws requiring transparency in claim evaluations. Edison’s actions also constitute a violation of Florida Statutes § 624.155 – Bad Faith Failure to Settle. The insurer failed to act in good faith by refusing to fairly settle the claim despite clear evidence of a covered loss. It intentionally undervalued and delayed the claim in order to avoid paying its full policy obligation. Edison prioritized its financial interests over its policyholder obligations by engaging in deceptive and obstructive claims-handling tactics. On information and belief, Edison’s actions are part of a systemic pattern of bad faith claims handling, including conflicting estimates, frequent adjuster swapping, misleading communications, failure to account for the full scope of damages, and the issuance of unfair and unjustified underpayments. Given these serious violations, Edison must take immediate corrective action. The insured demands that Edison immediately pay all undisputed benefits owed under the policy, conduct a good-faith reevaluation of the claim incorporating the public adjuster’s estimate and supporting evidence, provide a detailed written explanation for discrepancies in estimates and claim determinations, cease and desist from continued bad faith claims-handling practices, and fully compensate the insured for damages incurred due to its bad faith conduct, including attorneys' fees, costs, and any applicable statutory damages. Under Florida law, Edison has 60 days from the date of this notice to cure its violations. If Edison fails to do so, the insured will pursue all available legal remedies, including filing a civil remedy notice and seeking damages beyond policy limits. Edison’s continued bad faith handling of this claim has caused undue financial hardship and distress to the insured. If the insurer does not act promptly, legal action will proceed under Florida’s bad faith insurance laws to ensure full compensation. The Insurer can cure this default by the following: 1. Tender RCV $386,230 plus attorneys’ fees and costs. 2. Stipulate to Insured’s entitlement to reasonable attorneys’ fees and costs. 3. Create adequate guidelines for the proper investigation and evaluation of claims like Insured’s and for the training and supervision of Insurer’s employees or others associated in Insurer’s claims handling processes and begin the implantation of these guideline and policy changes. 4. Act fairly and honestly toward Insured and with due regard for her interests in attempting to settle Insured’ Claim. Failure to cure all defects during the 60-day safe harbor period may result in additional extra-contractual damages.

Comments

User Id		Date Added		Comment
Mattos@becklawpa.com		05-12-2025		Department of Financial Services Civil Remedy Section 200 East Gaines Street Tallahassee, FL 32399-0322 Re: Civil Remedy Notice of Insurer Violation Complainant(s) : Bradley Parker Insured(s) : Bradley Parker Policy Number : EDH5391649-02 Claim No. : EDI966088 DFS File Number : 811334 Acceptable Date : March 14, 2025 Insurer : Edison Insurance Company To Whom It May Concern: Please be advised that we represent Edison Insurance Company (“Edison”) in the above-referenced matter. Kindly consider this to be Edison’s report to the Department on the disposition of the alleged violations. Edison maintains that it has not been in any violation of the law, as alleged by the referenced Civil Remedy Notice (“CRN”) filed by Bradley Parker (the “Insured”). Further, Edison maintains that the CRN is defective on its face and it fails to comply with the requirements outlined under Florida Statute 624.155. Edison hereby objects to the Departments acceptance of the above referenced CRN based on the deficiencies. By way of background, this matter involves alleged Hurricane Milton damage that occurred on or about October 10, 2024. After the report of the alleged damage, Edison immediately inspected the property on or about October 16, 2024. As a result of that inspection, Edison determined the amount of damage(s) covered was less than the applicable policy Hurricane deductible of $23,458.00. Therefore, no payment was made. On or about November 3, 2024, Edison informed the Insured of the same. In addition, on or about December 13, 2024 Edison conducted a re-inspection of the property. As a result of that inspection, Edison tendered payment to the insured in the amount of $33,160.95 for Coverage A – Dwelling, $13,524.38 for Coverage A -Screen Enclosure and $11,729.00 for Coverage A pursuant to the policy’s Matching of Undamaged Property Endorsement. On or about January 22, 2025, Edison informed the Insured of the same. On or about March 12, 2025, Edison sent correspondence to the insured indicating that there was no supplemental coverage for the claim and have therefore determined that the initial assessment was appropriate. On March 14, 2025, the Insured, through their legal counsel, filed a CRN against Edison, which is a pre-requisite to a bad faith lawsuit under Florida Statute 624.155. This CRN alleges that Edison engaged in “Claim Denial, Claim Delay, Unsatisfactory Settlement Offer, Unfair Trade Practice, Violations of various statutes and Fla. Admin. Code, Misconduct toward Insured, Unreasonable Investigation, Intentionally bullying Insured” Additionally, the CRN alleges that Edison has violated Florida Administrative Codes and Statutes, including 624.155, F.S.: 624.155(1)(b)(1); 624.155(1)(b)(3); 626.9541(1)(i)(2); 626.9541(1)(i)(3)(a); 626.9541(1)(i)(3)(b); 626.9541(1)(i)(3)(c); 626.9541(1)(i)(3)(d); 626.9541(1)(i)(3)(e); 626.9541(1)(i)(3)(f) and 626.9541(1)(i)(4). The CRN requires the Complainant "pursuant to section 624.155, F.S. please indicate all statutory provisions alleged to have been violated." The CRN filed in this matter includes almost every statutory provision that could be claimed, regardless of whether they are relevant or applicable to the alleged facts contained in the CRN. Because the CRN fails to identify any specific statutes, without a shred of factual specificity to support them, Edison is unable to properly respond and it does not comply with F.S. § 624.155. As already mentioned, Edison maintains this CRN filed by the Insured is defective on its face. Although Florida Statute 624.155 requires the Insured to include requisite factual specificity, this CRN merely contains boilerplate broad language, used routinely in a litany of other filings. In fact, the Insured’s counsel’s law firm who filed this CRN has filed over 200 CRNs in approximately the past 3 years against over 30 different carriers. With regards to the CRN, it contains generic improper and legally insufficient allegations. The purpose of a CRN is to place the carrier on notice of specific violations so that they can be corrected during the statutory “cure” period. This CRN fails to meet this requirement and as such, should not be able to proceed on such a defective and improper CRN that contains nothing but accusations and conclusions without any specificity. Further, the CRN goes on to allege that the carrier “…engaged in a deliberate pattern of misconduct, which included failing to promptly pay all benefits due under the Policy, failing to fairly and thoroughly investigate the Claim, and placing its financial interests ahead of the Insured by undervaluing and delaying the claim.” These allegations as stated are improper, factually incorrect, do not comply with the specificity requirements set forth in Florida Statute 624.155, and is unfairly vague to put the carrier on notice of any alleged violations. The CRN goes on to allege that the carrier, “intentionally delayed the claims process by repeatedly switching adjusters, causing unnecessary confusion and disruption. Between November 2024 and January 2025, at least six different adjusters handled the claim, preventing timely resolution. The insurer’s initial damage estimate omitted significant losses and failed to reflect the full extent of the damages.” And “…mishandled, underpaid loss, deliberately undervalued as part of a widespread pattern of misconduct designed to maximize Edison’s profits.” As stated, the facts of this matter clearly show that Edison acted fairly towards its Insured at all times with regards to this claim. An adjuster was assigned to the claim immediately and promptly contacted the Insured to conduct an inspection of the residence on October 16, 2024. As a result of that inspection, Edison determined the amount of damage(s) covered was less than the applicable deductible and therefore, no payment was made. On or about November 3, 2024, Edison informed the Insured of the same. In addition, on or about December 13, 2024 Edison conducted a re-inspection of the property. As a result of that inspection, Edison tendered payment to the insured in the amount of $33,160.95 for Coverage A – Dwelling, $13,524.38 for Coverage A -Screen Enclosure and $11,729.00 for Coverage A pursuant to the policy’s Matching of Undamaged Property Endorsement. On or about January 22, 2025, Edison informed the Insured of the same. On or about March 12, 2025, Edison sent correspondence to the insured indicating that there was no supplemental coverage for the claim and have therefore determined that the initial assessment was appropriate. Therefore, the Insured’s claim that Edison violated Florida Statutes in this matter is misplaced as Edison acted fairly towards its Insured and in accordance the terms and conditions of the policy. For these foregoing reasons, Edison denies all allegations contained in the CRN filed by the Insured, and maintains that the CRN is defective on its face and should be dismissed. The CRN alleges that in order to “cure” the Insured, Edison must: “1. Tender RCV $386,230 plus attorneys’ fees and costs. 2. Stipulate to Insured’s entitlement to reasonable attorneys’ fees and costs. 3. Create adequate guidelines for the proper investigation and evaluation of claims like Insured’s and for the training and supervision of Insurer’s employees or others associated in Insurer’s claims handling processes and begin the implantation of these guideline and policy changes. 4. Act fairly and honestly toward Insured and with due regard for her interests in attempting to settle Insured’ Claim.” Edison stands by its decision that the number is unreasonable and overinflated to bring the Insured’s property back to its pre-loss condition. The CRN also contains “cures” that are not available under the policy of insurance or under the Civil Remedy Statute. Based on the information outlined above, Edison requests that the DFS re-consider its acceptance of the above-referenced CRN and further requests that the DFS provide Edison a list of the guidelines and requirements utilized by the DFS in determining to accept this defective CRN. As outlined above, Edison maintains that it has not been in violation of any law and that the CRN, as filed, is defective on its face as it fails to meet the specificity requirements of Florida Statute 624.155. Should the Department require additional information, please do not hesitate to contact us. Sincerely, JOSHUA S. BECK, ESQ.

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