Civil Remedy Notice of Insurer Violations
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Filing Number:     812003
Filing Accepted:  3/20/2025
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Complainant
Last/Business Name *  
WRIGHT   First Name   WILLIAM
Street Address * 8455 IMPERIAL CIR
City, State Zip * PALMETTO, FL 34221
Email Address * SERVICE@PROPERTYPEOPLELAW.COM
Complainant Type: * Insured
Insured
Last/Business Name*   WRIGHT   First Name   WILLIAM
Policy # * ATM203300 Claim #* AM158650
Attorney
Attorney is Applicable
Last Name* ILANI First Name * DANIEL Initial
Street Address* 80 SW 8TH STREET, SUITE 2590
City, State Zip* MIAMI , FLORIDA 33130
Email Address * SERVICE@PROPERTYPEOPLELAW.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   AMERICAN TRADITIONS INSURANCE COMPANY
NAIC Company Code 12359
 
Name of individual responsible for violation (if any):* ALL ADJUSTERS, SUPERVISORS, MANAGERS, ATTORNEYS, AND INDIVIDUALS ASSOCIATED WITH AND/OR RETAINED BY AMERICAN TRADITIONS INSURANCE COMPANY CONCERNING THE CLAIM AT ISSUES; AMERICAN TRADITIONS INSURANCE COMPANY’S DESK ADJUSTER(S); AMERICAN TRADITIONS IN
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Claim Denial
Claim Delay
Unsatisfactory Settlement Offer
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)(2) Making claims payments to insureds or beneficiaries not accompanied by a statement setting forth the coverage under which payments are being made.
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)(3)(g) Failing to promptly notify the insured of any additional information necessary for the processing of a claim.
626.9541(1)(i)(3)(h) Failing to clearly explain the nature of the requested information and the reasons why such information is necessary.
626.9541(1)(i)(3)(i) Failing to pay personal injury protection insurance claims within the time periods required by s. 627.736(4)(b).
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

AMERICAN TRADITIONS INSURANCE COMPANY failed to adequately adjust and pay the claim covered under the subject insurance policy. Specifically, but not limited to, AMERICAN TRADITIONS INSURANCE COMPANY failed to properly apply the Loss Settlement and Loss Payment provisions of the policy. In addition to the policy sections specifically cited herein, any endorsements or changes to said sections are relevant to the Insured’s claim for civil remedy. There may be additional policy language relevant to this violation that may be discovered.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

AMERICAN TRADITIONS INSURANCE COMPANY (hereinafter the “Insurance Company”) issued a homeowners insurance policy to its insured, WILLIAM & MARY WRIGHT (the “Insured”), for the insured property located at 8455 Imperial Cir, Palmetto, FL 34221. The subject Policy afforded various types of coverages including coverage for damage to dwelling, other structures, personal property, and for loss of use. On or about October 16, 2024, while the subject Policy was in full force and effect, the Insured’s home was damaged as a result of a covered loss. The Insured subsequently notified the Insurance Company of this loss. Thereafter, the Insurance Company acknowledged the loss and assigned claim number AM158650 to the loss. The Insured complied with all policy conditions and cooperated with the Insurance Company’s investigation efforts. The Insurance Company performed a cursory inspection and failed to retain the unbiased experts necessary to adequately inspect the property to restore the property to its pre-loss condition. Shortly after, the insurance company denied this loss based upon an unqualified evaluation of the damages. Notably, the Insurance Company failed to retain an expert to inspect the property to fully evaluate this claim, relying solely on an inadequate inspection concerning a subject matter and claim their representative is ill-equipped and unqualified to properly evaluate. The Insured and Insured’s representative provided the Insurance Company with all claim-related documents including an estimate to repair covered damages in the amount of $99,381.24 and other supporting documentation and/or information. Nonetheless, the Insurance Company continues to disregard and ignore the Insured’s claim and request for adequate payment. The Insurance Company has failed to issue proper payment for the claim and has failed to issue sufficient payment to compensate the Insured for damages and repairs covered by the policy and held to be contractually covered by Florida law. The Insured provided the Insurance Company with documentation evaluating the loss, and rather than issuing the proper payment or attempting to reach an agreement with its Insured, the Insurance Company is delaying and denying the claim. Upon information and belief, the Insurance Company performs the subject actions as a business practice, including delaying the claim and/or issuing insufficient payments in an attempt to dissuade its insured from pursuing the claim to the detriment of its insured to increase financial profits. Based upon self-serving conclusions regarding the cause of loss, the Insurance Company’s conclusions are disconcerting because they are demonstrably incorrect. Further, they directly conflict with the only first-hand accounts of the loss. To be clear, the Insured had personal knowledge of the condition of the property prior to the date of the loss and the amounts owed to make the necessary repairs. That said, the Insurance Company’s refusal to properly investigate, adjust, and fully compensate the Insured for their claim evidences the Insurance Company’s violation of Section 626.9541(1)(i)(3)(a), Florida Statutes, which requires the Insurance Company to “adopt and implement standards for the proper investigation of claims.” All available information leads to one conclusion—the Insured’s property was damaged by a covered cause of loss for which the Insured is entitled to full and complete compensation. The Insurance Company’s obligation to promptly settle the Insured’s claim is undeniable, and therefore, the Insurance Company has also violated sections 624.155(1)(b)(1), Florida Statutes. The Insurance Company’s conduct is egregious because the Insurance Company purposely ignored relevant facts, even facts from its own experts, that would have confirmed coverage for the Insured’s loss to avoid having to compensate the Insured for damages. To make matters even worse, the Insurance Company has failed to timely respond to the Insured and issue payment for the damages to the property to allow necessary repairs. The actions taken by the Insurance Company in the handling and adjustment of the Insured’s claim are willful, wanton, and in disregard for the rights of the Insured, and have occurred with such frequency as to indicate a general business practice in violation of the law. The practice includes the Insurance Company’s ongoing inaction of ignoring relevant and accessible information that supports coverage in order to avoid compensating its Insured for covered losses. To be clear, the recent ruling in Fortune v. First Protective Insurance Company d/b/a Frontline Insurance, out of Florida’s 2nd District Court of Appeal, clears up what this carrier must do the cure this CRN. Similar to here, In Fortune, the Insureds timely filed a claim with their homeowners insurance policy upon suffering damage to their property. The Insurer investigated the claim and denied, contending that the amount of damage did not exceed the Insureds’ deductible. Upon presenting the public adjuster’s estimate and all other materials to the insurance company, the Insurer invoked the appraisal process under the policy.Thereafter, the Insureds filed a Civil Remedy Notice alleging that the insurer made a lowball offer and “flagrantly breached” its duty to attempt in good faith to settle claims, under applicable Florida statutes. Additionally, the Insureds alleged that the Insurer refused to reassess its payment of benefits and the basis for payment and that the Insurer “turn[ed] a blindeye and refuse[d] to properly adjust and settle the claim.” Noteworthy in Fortune is that although the Homeowners' CRN did not state a specific cure amount, it did state that they had provided their public adjustor's estimate to the Insurer which covered "the full scope of necessary repairs to the direct and ensuing damages." Thus, the Insured had the public adjuster's estimate and knew the amount the Homeowners sought. Neither the statute nor this court's precedent requires the CRN to contain a specific amount sought to cure the alleged bad faith. See § 624.155(3)(b); see Hunt v. State Farm Fla. Ins. Co., 112 So. 3d 547, 549 (Fla. 2d DCA 2013) (recognizing that an appraisal award satisfies the condition precedent of "a determination of liability and extent of damages owed"). In addition to the above statutory violations, the Insurance Company’s adjuster violated the following ethical requirements of Florida Administrative Code 69B-220.201. (3) Code of Ethics…An adjuster shall put the duty for fair and honest treatment of the claimant above the adjuster’s own interests in every instance. The following are standards of conduct that define ethical behavior, and shall constitute a code of ethics that shall be binding on all adjusters: (b) An adjuster shall treat all claimants equally. 2. An adjuster shall adjust all claims strictly in accordance with the insurance contract. (c) An adjuster shall not approach investigations, adjustments, and settlements in a manner prejudicial to the insured. (d) An adjuster shall make truthful and unbiased reports of the facts after making a complete investigation. (e) An adjuster shall handle every adjustment and settlement with honesty and integrity, and allow a fair adjustment or settlement to all parties without any remuneration to himself except that to which he is legally entitled. (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. (o) An adjuster shall not undertake the adjustment of any claim concerning which the adjuster is not currently competent and knowledgeable as to the terms and conditions of the insurance coverage, or which otherwise exceeds the adjuster’s current expertise. In Florida, the work of adjusting insurance claims engages the public trust. During the adjustment of the Insured’s claim, the Insurance Company breached this duty by failing to adhere to and comply with the above referenced obligations. To cure the defects outlined above, the Insurance Company must: 1. Immediately pay the Insured a cure of $99,381.24for losses suffered as a result of the claim; 2. Immediately issue payments for statutory interest for the late payments and owed profit/overhead; 3. Act fairly and honestly towards the Insured and with due regard for their interests; 4. Hire a fair and unbiassed adjuster and experts to properly assess the Insured’s damages; 5. Tender any additional insurance proceeds due and owing to the Insured that would reasonably place the Insured back into a pre-loss condition; 6. Timely adjust the claim with the insured and avoid/limit any additional delay, costs, and prejudice that the Insurance Company’s conduct above has caused and continues to cause the Insured; and 7. Compensate the Insured for the attorneys’ fees and costs accrued as a result of the Insurance Company’s bad faith conduct. 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
Tom@zinoberdiana.com 05-16-2025 May 16, 2025 Via Electronic Posting to the DFS Website Department of Financial Services Civil Remedy Section 200 East Gaines Street Tallahassee, Florida 32399-6322 Re: Insureds: William Wright and Mary Wright Insurer: American Traditions Insurance Company Filing No.: 812003 Claim No.: AM158650 Policy No.: ATM203300 Date of Loss: 10/9/24 (reported 10/16/24) Property: 8455 Imperial Circle, Palmetto, Florida 34221 Dear Sir or Madam: This correspondence shall serve as a formal response on behalf of American Traditions Insurance Company (hereinafter “American Traditions”) to the Civil Remedy Notice of Insurer Violation (hereinafter “Notice”) filed by Daniel Ilani, Esq., on behalf of William Wright and Mary Wright (hereinafter “Insureds”) that was accepted by the Department of Financial Services (hereinafter “Department”) on March 30, 2025. The Department’s Filing Number is 812003. I. The Notice fails to satisfy the requirements of Florida law and should be rejected. As to the content of the Notice, it is important to note that the Notice fails to comply with the specific requirements mandated by Florida Statutes §624.155. As such, the Notice should be rendered null and void, and should be rejected by the Department. Specifically, the Notice fails to comply with Florida Statute 624.155(3)(b)(2), Florida Statutes, which requires that the Notice state, with specificity, the facts and circumstances giving rise to the alleged violation. Rather than complying with this requirement, the Notice includes jumbled assertions of unqualified opinion, legal conclusions, conjecture, and inaccurate statements of fact cast in the light most favorable to the attorney who drafted the Notice. The Notice states that, the Insureds demand that in order to “cure” the Civil Remedy Notice of Insurer Violation, American Traditions must: 1.) Pay the insured $99,381.24; 2.) Immediately issue payments for the late payments and owed profit/overhead. The Florida Supreme Court has stated that “cure” demands beyond the contractual amount due are not allowed. The Court addressed this issue in the case of Talat Enterprises, Inc v. Aetna Cas. & Sur. Co., 753 So. 2d 1278 (Fla. 2000): The Court rejects as unsupported Talat’s contention that the insurer must not only pay the claim within the sixty-day window, but must also pay all compensatory damages that flow from any delay in settling the claim. Section 624.155 does not impose on an insurer the obligation to pay whatever the insured demands. The sixty-day window is designed to be a cure period that will encourage payment of the underlying claim, and avoid unnecessary bad faith litigation. Surely an insurer need not immediately pay 100% of the damages claimed to flow from bad faith conduct in order to avoid the chance that the insured will succeed on a bad faith cause of action. If the insurer may avoid a bad faith action only by paying in advance every penny of the damages that it faces if it loses at trial, the insurer would have no reason to pay. Furthermore, few insureds would restrict their demands to compensatory damages. 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 interpretation. The law does not support such an expansive and illogical reading of Fla. Stat. Ann. § 624.155(2)(d). The Notice is invalid because the complainants have conditioned American Traditions’ ability to “cure” by demanding that American Traditions must “issue payments for statutory interest.” That is not allowed. Finally, it is of primary importance to American Traditions that it is provided an opportunity to respond to the concerns of its policyholders which it routinely does as a matter of course. Instead, the Notice in this matter provides nothing more than general statements regarding a statute applicable to the investigations of insurance claims and unsupported allegations of fact that purportedly support the incorrect notion that American Traditions denied the Insureds’ claim in bad-faith. The deficiencies in this Notice precludes American Traditions from providing an adequate response as provided for in Section 624.155, Florida Statutes. Therefore, American Traditions requests that the Department reject the Notice as a result of the deficiencies noted hereinabove. II. Despite the deficiencies, American Traditions denies all allegations contained in the Notice. Notwithstanding the deficiencies in the Notice, American Traditions denies it committed the acts and violated the statutes cited in the Notice. American Traditions hereby denies each and every allegation contained in the Notice, either explicitly or implicitly, and denies any wrongdoing in the handling of this matter. American Traditions has acted fairly and with due diligence throughout the entire investigation and handling of this claim. To the extent that this reply does not fully address and respond to the allegations set forth by the Notice, such deficiency is the direct result of the lack of specificity and the overall vague nature of the allegations therein. American Traditions denies each and every allegation contained in the Insureds’ Civil Remedy Notice and responds to them individually as follows: The Notice lists four (4) reasons for submitting the Notice which are: 1) Claim Denial; 2) Claim Delay; 3) Unsatisfactory Settlement Offer; and 4) Unfair Trade Practice. As indicated in detail below, the Notice fails to establish or set forth any specific facts that would support the allegations asserted in support of the perceived violations. Specifically, American Traditions responds as follows: Claim Denial • This allegation is wholly without basis and therefore denied. Counsel for the Insureds should immediately withdraw this allegation from his Notice. At all times material to this claim, American Traditions acted timely, diligently and responsibly in its pursuit of coverage. Furthermore, claim denial, in and of itself, is not a valid basis for filing this Notice. Lastly, American Traditions provided coverage for the claim pursuant to the terms and conditions of the subject policy and the Insureds’ claim history. Claim Delay • This allegation is wholly without basis and therefore denied. Counsel for the Insureds should immediately withdraw this allegation from the Notice as well. At all times material to this claim, American Traditions acted timely, diligently and responsibly in its pursuit of coverage. Any perceived delays alleged in the Notice are not due to the actions of American Traditions nor did American Traditions have control over any such actions causing any perceived delay. Specifically, the loss was reported to American Traditions on or about October 16, 2024. On November 18, 2024, American Traditions provided the Insureds with its coverage determination. At all times, American Traditions worked diligently to timely respond to and adjust every claim, including the claim described in the Civil Remedy Notice of Insurer Violation Unsatisfactory Settlement Offer • This allegation is wholly without basis in law or fact and is therefore denied. Counsel for the Insureds should immediately withdraw this allegation from the Notice as it cannot be established by any credible evidence. At all times material to this claim, American Traditions acted in good faith towards its insureds and provided its coverage determination pursuant to the terms and conditions of the subject policy. Unfair Trade Practice: • This allegation is wholly without basis in law or fact, and is therefore denied. Counsel for the Insureds should immediately withdraw this allegation from his Notice as it cannot be established by any credible evidence. At all times material to this claim, American Traditions acted in good faith towards its insureds, as it does on every claim. Alleged Statutory Violations The Complainant lists thirteen (13) statutory provisions which have allegedly been violated by American Traditions. In response, American Traditions denies each of the allegations of statutory violation as all are wholly without merit, and responds as follows: • §624.155(1)(b)(1): Denied. At all times material to this claim, American Traditions acted fairly and honestly towards the Insureds and with due regard for their interests. American Traditions engaged in a thorough investigation of the subject claim. At no time has American Traditions acted dishonestly or unfairly toward the Insureds and/or their representatives. All actions have been performed in good faith for the purpose of moving the claim towards a just and equitable resolution. • §624.155(1)(b)(2): Denied. Insureds should immediately withdraw this allegation from the Notice as it cannot be established by any credible evidence. American Traditions provided payment with a detailed explanation of the payment and provided the estimate on which payment was based. Absolutely no facts or circumstances supporting this allegation have been provided by Insureds in the Civil Remedy Notice. • §624.155(1)(b)(3): Denied. Insureds should immediately withdraw this allegation from the Notice as it cannot be established by any credible evidence. All actions have been performed in good faith and for the purpose of moving the claim towards a just and equitable resolution. Absolutely no facts or circumstances supporting this allegation have been provided by the Insured in the Civil Remedy Notice. • §624.155(1)(i)(2): Denied. Insureds should immediately withdraw this allegation from the Notice as it cannot be established by any credible evidence. All actions have been performed in good faith and for the purpose of moving the claim towards a just and equitable resolution. Absolutely no facts or circumstances supporting this allegation have been provided by the Insured in the Civil Remedy Notice. • §626.9541(1)(i)(3)(a): Denied. Insureds should immediately withdraw this allegation from the Notice as it cannot be established by any credible evidence. American Traditions has always implemented standards for investigating and adjusting claims commensurate with the requirements of Florida Statutes, and it will continue to do so. All actions have been performed in good faith and for the purpose of moving the claim towards a just and equitable resolution. Absolutely no facts or circumstances supporting this allegation have been provided by Insureds in the Civil Remedy Notice. • §626.9541(1)(i)(3)(b): Denied. Insureds should immediately withdraw this allegation from the Notice as it cannot be established by any credible evidence. American Traditions has always implemented standards for investigating and adjusting claims commensurate with the requirements of Florida Statutes, and it will continue to do so. All actions have been performed in good faith and for the purpose of moving the claim towards a just and equitable resolution. Absolutely no facts or circumstances supporting this allegation have been provided by Insureds in the Civil Remedy Notice. • §626.9541(1)(i)(3)(c): Denied. Insureds should immediately withdraw this allegation from the Notice as it cannot be established by any credible evidence. American Traditions has always implemented standards for investigating and adjusting claims commensurate with the requirements of Florida Statutes, and it will continue to do so. All actions have been performed in good faith and for the purpose of moving the claim towards a just and equitable resolution. Absolutely no facts or circumstances supporting this allegation have been provided by Insured in the Civil Remedy Notice. • §626.9541(1)(i)(3)(d): Denied. Insureds should immediately withdraw this allegation from the Notice as it cannot be established by any credible evidence. American Traditions has always implemented standards for investigating and adjusting claims commensurate with the requirements of Florida Statutes, and it will continue to do so. American Traditions conducted two inspections of the property. Absolutely no facts or circumstances supporting this allegation have been provided by the Complainant in the Civil Remedy Notice. • §626.9541(1)(i)(3)(e): Denied. Insureds should immediately withdraw this allegation from the Notice as it cannot be established by any credible evidence. American Traditions has always implemented standards for investigating and adjusting claims commensurate with the requirements of Florida Statutes, and it will continue to do so. All actions have been performed in good faith and for the purpose of moving the claim towards a just and equitable resolution. Absolutely no facts or circumstances supporting this allegation have been provided by Insureds in the Civil Remedy Notice. • §626.9541(1)(i)(3)(f): Denied. The Insureds should immediately withdraw this allegation from the Notice as it cannot be established by any credible evidence. American Traditions reasonably investigated this claim and issued a coverage determination letter with a reasonable explanation in writing to the insured of the basis in the insurance policy. Any allegation to the contrary is without merit and baseless. All actions have been performed in good faith and for the purpose of moving the claim towards a just and equitable resolution. • §626.9541(1)(i)(3)(g): Denied. The Insureds should immediately withdraw this allegation from the Notice as it cannot be established by any credible evidence. American Traditions reasonably investigated this claim and issued a coverage determination letter with a reasonable explanation in writing to the insured of the basis in the insurance policy. In addition, American Traditions sent correspondence to the Insureds on multiple occasions detailing specifically what information was necessary to further conduct its investigation. Any allegation to the contrary is without merit and baseless. All actions have been performed in good faith and for the purpose of moving the claim towards a just and equitable resolution. • §626.9541(1)(i)(3)(h): Denied. The Insureds should immediately withdraw this allegation from the Notice as it cannot be established by any credible evidence. American Traditions reasonably investigated this claim and issued a coverage determination letter with a reasonable explanation in writing to the insured of the basis in the insurance policy. In addition, American Traditions sent correspondence to the Insureds on multiple occasions detailing specifically what information was necessary to further conduct its investigation. Any allegation to the contrary is without merit and baseless. All actions have been performed in good faith and for the purpose of moving the claim towards a just and equitable resolution. • §626.9541(1)(i)(3)(i): Denied. The Insureds should immediately withdraw this allegation from the Notice as it cannot be established by any credible evidence. There have been no claims related to personal injury protection made by the Insured. Absolutely no facts or circumstances supporting this allegation have been provided by the Complainant in the Civil Remedy Notice. Alleged Violations of Policy of Insurance The Notice requires the Insureds to reference the specific policy language that is relevant to the violation. Rather than complying with this requirement, counsel for the Insureds has referred to what amounts to the entire policy and which does not provide any specificity as to the alleged violation. The Notice also fails to provide any factual basis to support the purported violation of the policy. Nonetheless, American Traditions states with confidence that it acted promptly, fairly, and in good faith towards the Insureds at all times material to the adjustment and investigation of this claim. American Traditions denies violating any provision or duty set forth in the policy. Alleged Factual and Circumstantial Support for the Insureds’ Notice The Notice requires the Insureds to “describe the facts and circumstances giving rise to the insurer’s violation as you understand them at this time.” In part, the Notice incorporates vague and unsubstantiated allegations which purportedly give rise to the violation. Therefore, these portions of the Notice should be dismissed for failure to properly complete the form pursuant to Florida Statute §624.155, as the alleged violations are without basis in law or fact. The allegations set forth are so vague and non-specific that they fail to allow a reasonable response. Nevertheless, American Traditions asserts that all actions taken have been made entirely in good faith and for the purposes of fair, just and timely disposition of this matter. Additionally, and to the extent possible, American Traditions specifically responds to each of the following allegations set forth in this section of the Notice below. The facts of this matter are clear, and these are they: American Traditions provided homeowners insurance coverage to the Insureds, William Wright and Mary Wright, for property located at 8455 Imperial Circle, Palmetto, Florida 34221 (the “Insured Property”) under the terms of policy number ATM203300 (the “Policy”). On October 16, 2024, the Insureds reported a claim for damages to the Insured Property related to Hurricane Milton, which occurred approximately one week prior. American Traditions immediately retained an independent adjuster to inspect the claimed damages. The adjuster inspected the Insured Property on October 29, 2024, and found there to be no storm-related damage to the roof, but did find damage otherwise related to Hurricane Milton. Specifically, the adjuster noted damage to a section of the roof panels to the carport and attached garage/weathertight room, as well as damage to the gutters and a screen door. In addition, the adjuster found minimal damage to the siding, window shutters, one window screen and one downspout. Lastly, damage was noted to the shed door and exterior wall of the shed. Because there was no storm created damage on the roof, the interior damages being claimed were not covered. Pursuant to the adjuster’s inspection, American Traditions advised the Insureds of what damage was covered under the Policy and what was not. In addition, American Traditions provided payment based on the adjuster’s estimate, less the applicable hurricane deductible. The actions taken by American Traditions categorically disprove the Insureds allegation that the claim was denied. To date, the Insureds have provided nothing to support their claim other than an estimate that exceeds policy limits and includes damage that was not reported at the outset of the claim. Based on the facts presented in detail above, American Traditions asserts that all actions taken have been made entirely in good faith and for the purposes of fair, just and timely disposition of this matter. Additionally, American Traditions has specifically responded to the unsubstantiated allegations set forth in the Notice with the true facts of this matter as have been set forth hereinabove. Further, American Traditions wholly denies the Insureds’ allegations contained within the Notice, and in support thereof asserts that it acted in accordance with Florida law, its policy of insurance, and in good faith towards the Insureds, as well as other American Traditions policyholders. III. Demands to Cure Defects The Notice states that to cure the alleged defects, American Traditions can pay the Insureds $99,381.24, statutory interest, and attorneys’ fees and costs. This demand is being made despite the Insureds’ failure to provide any documentation and/or evidence indicating that this amount is due and owing nor with any nod to the fact that the amount being demanded greatly exceeds the policy limits of $61,000.00. American Traditions again asserts that it engaged in a thorough investigation of the subject claim and incurred a significant expense in doing so. IV. Conclusion In closing, American Traditions first believes that the Civil Remedy Notice does not comply with section 624.155, Florida Statutes, and should therefore be rejected and returned by the Department of Financial Services due to its failure to comply with § 624.155, Fla. Stat., and Florida case law. Regardless of the lack of compliance, American Traditions denies all allegations contained in the Civil Remedy Notice and submits there are no violations. American Traditions denies all of the allegations contained in the Civil Remedy Notice and note that the Notice is riddled with inaccuracies. Due to the lack of any reliable or authoritative basis in fact or circumstances to support such allegations, we request, through this response, that the Department of Financial Services return the Notice for lack of specificity in accordance with Florida Statutes. While this response is meant to be comprehensive, American Traditions’ response above is based upon the limited information provided in the Civil Remedy Notice and the information we have to date. If William Wright or Mary Wright feel that we are not in possession of all the facts, please inform us immediately. Please note that American Traditions’ response is not necessarily exhaustive and does not preclude us from asserting any other valid reason for the lack of compliance with F.S. § 624.155. Also, this letter, or any act or failure to act on the part of American Traditions or any agent or representative of American Traditions should not be construed as a waiver of any rights or defenses, including but not limited to proper notice and service by William Wright or Mary Wright, available to them by contract or at law as all such rights and defenses are hereby specifically reserved. We trust that this response addresses the allegations of insurer violation alleged in the Civil Remedy Notice of Insurer Violation. Should you have any questions regarding this matter or need anything further, please do not hesitate to contact the undersigned. Best Regards, William R. Burke William R. Burke, Esquire Zinober Diana & Monteverde, P.A. Bill@ZinoberDiana.com
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