Civil Remedy Notice of Insurer Violations
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Filing Number:     811471
Filing Accepted:  3/17/2025
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Complainant
Last/Business Name *  
DALE AND DASHANELLE JONES AS PERSONAL REPRESENTATIVE OF THE ESTATE OF DALE L. JONES   First Name  
Street Address * 822 N. A1A HIGHWAY, SUITE 310
City, State Zip * PONTE VEDRA, FL 32082
Email Address * RIVERS@TWLGLAWYERS.COM
Complainant Type: * Third Party
Insured
Last/Business Name*   WORLD DEBT ACQUISITIONS   First Name  
Policy # * 560002012-02 Claim #* UNKNOWN
Attorney
Attorney is Applicable
Last Name* RIVERS First Name * LINJE Initial
Street Address* 822 N. A1A HIGHWAY, SUITE 310
City, State Zip* PONTE VEDRA , FL 32082
Email Address * RIVERS@TWLGLAWYERS.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   GUIDEONE NATIONAL INSURANCE COMPANY
NAIC Company Code 14167
 
Name of individual responsible for violation (if any):* UNKNOWN
Type of Insurance * Commercial Property & Casualty   
Reason for Notice *
Unsatisfactory Settlement Offer
* 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.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

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

On October 6, 2022, Defendants HART ROAD LODGE, LLC a Foreign Limited Liability Company d/b/a HOME 1 GREAT STAY, WDA HOLDINGS LLC, and WORLD DEBT ACQUISITIONS d/b/a JDH DEVELOPERS, managed, operated, controlled, and/or owned the property at 10885 Harts Road known as Home 1 Great Stay (“subject premises”) Despite the Hotel and the surrounding area being the site of rampant violent crimes prior to the incident in this case, Defendants continually failed to appreciate the grave importance of, inter alia, securing access with adequate controls, effectively stationing security patrols on-site, and otherwise reasonably ensuring that trespassers and/or criminal assailants cannot freely enter and exit the premises. The subject premises had zero effective security measures in place prior to and at the time of the incident. Dale Leonard Jones, deceased, (“Jones”) was guest at the subject premises. At that same time and place, Erik Allen, a convicted felon, entered the subject premises armed with a weapon. Mr. Allen was not a guest at the hotel or an invitee of any guest at the subject premises. Mr. Allen was a trespasser. Upon entering the subject premises, Mr. Allen engaged in a physical altercation with Mr. Jones. After defending himself, Mr. Jones told Mr. Allen he needed to leave the property. Unbeknownst to Mr. Jones, Mr. Allen had a weapon on his person. Mr. Allen walked down the stairs and pretended to leave the property. Mr. Allen removed his weapon from its concealed position and pointed the firearm towards Mr. Jones on the second floor. Mr. Allen opened fire striking Mr. Jones twice. Emergency services were called to the subject premises to render aid to Mr. Jones. He was transported by ambulance to the hospital where Mr. Jones would later die from the gunshot wounds he suffered. The damages identified in Plaintiffs’ Economist Report are $20,985,654. Guide One National Insurance failed to provide any offer and did not engage in any settlement discussions. Guide One National Insurance's conduct is unreasonable and unfair to the beneficiaries of the Estate of Dale Leonard Jones. An initial demand was sent to Guide One National Insurance on January 16, 2025.
Comments
User Id Date Added Comment
LegalWorkRequests@guideone.com 05-09-2025 Please be advised that a response on behalf of GuideOne National Insurance Company, has been submitted under separate cover to the Complainant's counsel, Linjee Rivers via email to Rivers@TWLGLawyers.com, on May 8, 2025.
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