Filing Number: 811471
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| Filing Accepted: 3/17/2025 |
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DALE AND DASHANELLE JONES AS PERSONAL REPRESENTATIVE OF THE ESTATE OF DALE L. JONES
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First Name |
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| Street Address
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822 N. A1A HIGHWAY, SUITE 310 |
| City, State Zip
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PONTE VEDRA,
FL
32082
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| Email Address
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RIVERS@TWLGLAWYERS.COM |
| Complainant Type:
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Third Party |
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| Last/Business Name* |
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WORLD DEBT ACQUISITIONS |
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First Name |
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| Policy # * |
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560002012-02 |
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Claim #* |
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UNKNOWN |
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Attorney is Applicable
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| Last Name* |
RIVERS
First Name *
LINJE
Initial
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| Street Address* |
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822 N. A1A HIGHWAY, SUITE 310 |
| City, State Zip* |
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PONTE VEDRA
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FL
32082
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| Email Address * |
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RIVERS@TWLGLAWYERS.COM |
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| Insurer Type
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Authorized Insurer
Unauthorized Insurer
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| Insurer Name |
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| Insurer Name* |
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GUIDEONE NATIONAL INSURANCE COMPANY
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| Insurer Name* |
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| Street Address* |
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| City, State Zip* |
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,
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NAIC Company Code 14167 |
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| Name of individual responsible for violation (if any):*
UNKNOWN
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| Type of Insurance
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Commercial Property & Casualty
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| Reason for Notice
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Unsatisfactory Settlement Offer
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Statutory provision(s) which the insurer allegedly violated.
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| 624.155(1)(b)(1) |
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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.
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| 624.155(1)(b)(3) |
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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.
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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
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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.
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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.
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DFS-10-363
Rev. 10/14/2008
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