Civil Remedy Notice of Insurer Violations
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Filing Number:     811874
Filing Accepted:  3/19/2025
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Complainant
Last/Business Name *  
VANESSA VERAY-RODRIGUEZ AND RAFAEL RODRIGUEZ-FUENTES   First Name  
Street Address * 2238 STRAWBERRY TREE LANE
City, State Zip * ORLANDO, FL 32828
Email Address * CLAY@THEKRFIRM.COM
Complainant Type: * Insured
Insured
Last/Business Name*   VANESSA VERAY-RODRIGUEZ AND RAFAEL RODRIGUEZ-FUENTES   First Name  
Policy # * SIC3192187 Claim #* 202501020554
Attorney
Attorney is Applicable
Last Name* KUHN First Name * CLAYTON Initial
Street Address* 2110 WEST PLATT STREET
City, State Zip* TAMPA , FLORIDA 33606
Email Address * CLAY@THEKRFIRM.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   SLIDE INSURANCE COMPANY
NAIC Company Code 17227
 
Name of individual responsible for violation (if any):* ANY AND ALL PERSONS ASSOCIATED WITH THE CLAIMS HANDLING FROM SLIDE INSURANCE COMPANY
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Unfair Trade Practice
Claim Denial
* 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.
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.

THE POLICY LANGUAGE RELEVANT TO THE VIOLATIONS INCLUDES ALL APPLICABLE LOSS PAYMENT AND COVERAGE PROVISIONS OF POLICY NUMBER SIC3192187 INCLUDING THE DECLARATIONS PAGE AND ALL ENDORSEMENTS TO THE POLICY, WITH RESPECT TO COVERAGES A, B, C, AND D. ADDITIONALLY, ANY SECTIONS RELIED UPON BY THE INSURER IN ITS DENIAL TO FULLY PAY THE CLAIM, INCLUDING THE DUTIES IN THE EVENT OF LOSS PROVISIONS AND THE POLICY'S EXCLUSION OF COVERAGE PROVISIONS.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

Vanessa Veray-Rodriguez and Rafael Rodriguez-Fuentes (hereinafter “Insureds”) are homeowners/property owners with an all-risk policy issued by Slide Insurance Company (hereinafter “Carrier”). On or about October 10, 2024, Insureds’ home located at 2238 Strawberry Tree Lane, Orlando, Florida 32828 sustained significant damage as a result of windstorm event. Specifically, Hurricane Milton created multiple openings to the roof of Insureds’ property. This resulted in interior water damage to various areas of the interior of Insureds’ property including but not limited to, the entryway, dining room, kitchen, multiple bedrooms and closets, bathroom, laundry room, and garage. The Loss is covered under Insureds’ policy issued by Carrier. The Insureds mitigated damages by contacting Loss Restorations LLC who performed mitigation services on the subject property. All of the relevant documents were provided to Carrier. Insureds promptly reported the claim and fully cooperated with all requests for inspections. Carrier assigned Claim No. 202501020554 to the loss. The Insureds have fully cooperated with Carrier’s investigation of the claim, including providing all requested documentation and complying with all post-loss policy conditions. Specifically, the Insureds, with assistance from their public adjuster, submitted an estimate for $133,325.24, which was a fair and reasonable assessment for the repair/replacement of damages. Loss Restorations LLC has an outstanding balance in the amount of $4,879.28 for their mitigation services. After reporting the claim, Carrier retained an unqualified and biased field adjuster to adjust the loss. This adjuster had a financial incentive to adjust the loss in a manner that would minimize Carrier’s losses. This adjuster performed a mere cursory inspection of the property. Instead of adjusting the claim fairly, honestly, in good faith, and with due regard for the Insureds’ interests, this adjuster made a conscious effort to ignore evidence of covered losses to the property. Worse still, Carrier failed to retain qualified experts necessary to identify the repairs necessary to restore the property to its pre-loss condition. Despite Insureds providing Carrier with a detailed estimate, Carrier failed to pay Insureds the amount necessary to repair/replace the damaged property, less the applicable deductible. Instead, Carrier denied full coverage for the loss. This has become a common business practice for Carrier. Under the circumstances surrounding this claim, had Carrier acted fairly and honestly toward the Insureds and with due regard for the Insureds’ interests, Carrier could and should have attempted in good faith to settle this claim. Carrier did not and, instead, dishonestly, and unfairly placed its own interests well ahead of those of the Insureds. In doing so, Carrier violated Section 624.155(1)(b)(1), Florida Statutes. Carrier’s use of unqualified and biased adjusters, and failure to retain experts necessary to identify the repairs necessary to restore the property to its pre-loss condition, evidence Carrier’s failure to adopt and implement standards for the proper investigation of claims in violation of Section 626.9541(1)(i)(3)(a), Florida Statutes. Carrier’s use of unqualified and biased adjusters, and failure to retain experts necessary to identify the repairs necessary to restore the property to its pre-loss condition, evidence Carrier’s failure to conduct a reasonable investigation based upon available information. In denying full coverage for this claim without conducting reasonable investigations based upon available information, Carrier has violated Section 626.9541(1)(i)(3)(d), Florida Statutes. By representing to Insureds that the Policy does not afford full coverage for this loss, Carrier is misrepresenting pertinent facts and/or insurance policy provisions relating to coverages at issue, in violation of Section 626.9541(1)(i)(3)(b), Florida Statutes. When applying the facts present here to Florida law, it is clear that Carrier is acting in bad faith. Florida Statute § 624.02 defines insurance as a contract whereby one undertakes to indemnify another or pay or allow a specified amount or a determinable benefit based on determinable contingencies. Inherent is the fact that payment must be made timely and promptly so that insureds may mitigate their damages and be put back into the position they were in prior to the loss as quickly as possible. Carrier has breached this duty by refusing to properly and timely adjust the loss. Moreover, Section 69B-220.201 of the Florida Administrative Code defines Carrier’s adjusters conduct here as an unfair claims settlement practice. Specifically, Section 69B-220.201(3) provides that “[a]n adjuster shall not approach investigations, adjustments, and settlements in a manner prejudicial to the insured” and that “[a]n adjuster shall make truthful and unbiased reports of the facts after making a complete investigation.” As detailed above, Carrier’s investigation and adjustment of this claim was done in a manner prejudicial to Insureds, was incomplete, and lacked truthful and unbiased reports of the facts. Carrier has more than enough information and is still refusing to accept coverage for the Insureds’ claim. This continued and repeated reckless claim delay and denial of coverage will result in a significant punitive damage award if a bad faith lawsuit is filed. Carrier can cure the defects outlined in this Civil Remedy Notice and avoid a lawsuit for bad faith by immediately accepting full coverage under the subject insurance policy for this claim and by paying Insured’s estimate of $133,325.24, and Loss Restorations LLC in the amount of $4,879.28, less applicable deductible, which is the reasonable amount of the covered loss pursuant to the policy. A copy of this form has been submitted to the Florida Department of Financial Services who has transmitted the same to the following parties providing them notice of the filing of this Civil Remedy Notice: Slide Insurance Company
Comments
User Id Date Added Comment
mthornton@slideinsurance.com 05-16-2025 Via E-mail & Posting on DFS Website Clayton Kuhn, Esq. Kuhn Raslavich 2110 W Platt St Tampa, FL 33606 clay@thekrfirm.com Complainant: Vanessa Veray-Rodriguez, Rafael Rodriguez-Fuentes Insured: Vanessa Veray-Rodriguez, Rafael Rodriguez-Fuentes Claim No: 202501020554 Policy No: SIC3192187 CRN Filing No.: 811874 Dear Clayton Kuhn: Please allow this correspondence to serve as Slide Insurance Company’s (“Slide”)’s response to the Civil Remedy Notice (“CRN”) filed on behalf of Vanessa Veray-Rodriguez and Rafael Rodriguez-Fuentes (“Insured”). The CRN was accepted by the Department on March 19, 2025. Without waiving any objections to the sufficiency of this CRN, and specifically subject to a reservation of all rights and defenses herein, Slide denies it violated any Florida Statutes, codes, rules, or provisions in the applicable policy of insurance in its handling of this matter. Slide challenges the validity of the CRN as it fails to allege policy provisions which are the subject of Complainant’s allegations, does not provide specific facts to support any breach of the policy of insurance or Florida law, nor does the CRN identify anyone at the insurance company who would have knowledge of the purported conduct underlying its allegations. See, e.g., Julien v. United Prop. & Cas. Ins. Co., 311 So.3d 875, 879 (Fla. 4th DCA 2021); Demase v. State Farm Florida Insurance Company, 351 So.3d 136, 138-39 (Fla. 5th DCA 2022) (holding the trial court properly determined a civil remedy notice that failed to state with specificity the relevant policy language was legally insufficient). Therefore, the CRN fails to comply with the statutory requirements and should be returned by the Department. CLAIM FACTS Slide issued a homeowners’ insurance policy to the Insured for property located at 2238 Strawberry Tree Lane, Orlando, Florida, in effect for the period from August 16, 2024 through August 16, 2025, (the “Policy”). On January 13, 2025, the Insured filed a claim for damage to their property from Hurricane Milton. Specifically, the Insured stated the kitchen cabinets had signs of water intrusion and mold. The date of loss was reported as October 10, 2024. Slide acknowledged receipt of the claim and assigned a licensed field adjuster to inspect the property. During the inspection on January 20, 2025, the field adjuster documented water damage to the kitchen cabinet base located below a window. The Insured told the field adjuster there was damage from wind driven rain entering through windows and the pantry had a bad smell. The Insured further stated they had recently been deeded the property through a trust and was undergoing a “refresh” including new paint and repairs. No evidence of damage to the 2-year-old roof, exterior elevations, or other structures was found or reported. Based on the investigation, including the on-site inspection with a licensed field adjuster, Slide notified the Insured on or about February 17, 2025, that the reported damage was the result of wind driven rain through deteriorated windows, not a storm or wind created opening. Therefore, the claim is precluded from coverage pursuant to the unambiguous terms of the Policy. In accordance with the Policy and Florida Statute, an explanation of the coverage decision and underlying circumstances was provided to the Insured and their public adjuster representative. No further communication was received from the Insured or their representatives prior to the filing of this Civil Remedy Notice on March 19, 2025. Therefore, all allegations that Slide failed to address materials submitted by the Insured or conduct a sufficient investigation are meritless. To date, neither the Insured nor their representatives have provided any information that would alter Slide’s understanding of the loss and coverage. Slide maintains that it has acted in accordance with the terms of the subject insurance policy and the law in its adjustment of the claim. The facts and circumstances set forth in the CRN are incomplete, misleading, and do not support the allegations of unfair trade practice, claim denial, or any other violations of Florida law. The facts show Slide promptly investigated the loss, made communications as necessary to adjust the claim, and notified the Insured and/or their representatives of the coverage decision including relevant policy provisions, in accordance with its obligations under Florida law and the Policy. ALLEGED STATUTORY VIOLATIONS The CRN alleges Slide violated §§ 624.155(1)(b)(1), 626.9541(1)(i)(3)(a), 626.9541(1)(i)(3)(b), and 626.9541(1)(i)(3)(d), Fla. Stats. Notwithstanding any challenge to the sufficiency of the CRN, and specifically subject to a reservation of all rights and defenses herein, Slide denies all allegations that it violated Florida law in the handling of the subject claim. As provided in the above narrative, the underlying claim was investigated and adjusted in as thorough and expedient a manner as possible. Following the evaluation of the loss, including an on-site inspection, the Insured was notified of the coverage decision pursuant to the Policy’s terms, conditions, endorsements, limitations, and exclusions. All allegations that Slide misrepresented material facts or Policy provisions, failed to conduct reasonable investigations, and mishandled the claim are without merit. The facts will show Slide has consistently communicated with the Insured and/or their representatives regarding the claim, conducted a reasonable investigation including retaining licensed individuals to evaluate damages, and provided a written explanation of the coverage decisions. On the other hand, the Insured failed to reply to requests for information, provide records to substantiate their claims, or promptly cooperate with the claim investigation, in contravention of their Duties After Loss in the Policy. Thus, Slide maintains that it has acted fairly and honestly towards the Insured and denies all allegations of improper claims handling. CONCLUSION In filing this response, Slide does not intend to waive any rights or defenses afforded under the applicable insurance policy and Florida law; rather, all such rights or defenses are hereby explicitly reserved, without exception or limitation. Should there be any questions or further inquiry with respect to this matter, please contact the undersigned at mthornton@slideinsurance.com. Sincerely, /s/ Marianne Thornton Marianne Thornton, Esq. Staff Counsel
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