Civil Remedy Notice of Insurer Violations
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Filing Number:     813036
Filing Accepted:  3/25/2025
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Complainant
Last/Business Name *  
LOVELLE   First Name   VINCENT
Street Address * 3690 BAY CREEK DR
City, State Zip * BONITA SPRINGS, FL 34134
Email Address * VINCELOVELLE@GMAIL.COM
Complainant Type: * Insured
Insured
Last/Business Name*   LOVELLE   First Name   VINCENT
Policy # * FPH3-000103669 Claim #* 01000066865
Attorney
Attorney is Applicable
Last Name* ROSSO First Name * SCOTT Initial M
Street Address* 7171 NORTH FEDERAL HIGHWAY
City, State Zip* BOCA RATON , FL 33487
Email Address * SROSSO@GEDLAWYERS.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   FIRST PROTECTIVE INSURANCE COMPANY
NAIC Company Code 10897
 
Name of individual responsible for violation (if any):* DENISE CARAKER, MARINA PURVIS, KORY KAMKE, NINA WALKER, OMAR LOMBANA, AND ALL ADJUSTERS, SUPERVISORS, AND MANAGEMENT ASSOCIATED WITH OR RETAINED BY FIRST PROTECTIVE INSURANCE COMPANY DBA FRONTLINE INSURANCE IN THE CLAIM.
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Unfair Trade Practice
Claim Delay
Unsatisfactory Settlement Offer
Other : Violation of Adjusters’ Ethical Requirements
Other : Failure to Properly Investigate Claim and with Due Regard to INSUREDS’ Interest
* 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)(3)(c) Failing to acknowledge and act promptly upon communications with respect to claims.
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.

J. Loss Payment. We will adjust all losses with you. We will pay you unless some other person is named in the policy or is legally entitled to receive payment and we have not elected our option to repair. 1. Loss will be payable upon the earlier of the following: a. 20 days after we receive:your proof of loss in compliance with SECTION 1- CONDITIONS, C. Duties After Loss, paragraph ·9, and reach written agreement with you; or b. 60 days after we receive your:proof of loss in compliance with SECTION 1- CONDITIONS, C. Duties After Loss, paragraph 9; and (1) There is an entry of a final judgment; or (2) There is a filing of an appraisal award or a mediation settlement with us. c. If payment is not denied, within 90 days after we receive notice of an initial, reopened or supplemental claim. However, this provision c. does not apply if factors beyond our control reasonably prevent such payment. Failure to comply with this provision c. does not form the basis of a private cause of action against us. 2. If payment is denied in part, we will pay the undisputed amounts within the same time stated unless we have exercised our option under SECTION I -CONDITIONS, I. 3. Payment of a portion of the claim(s) being asserted in a loss under this policy does not act as a waiver of our right to dispute or deny any unpaid portion of any claim(s) that you may assert arose from a loss. 4. Any payment for expenses of engineering reports, professional services, or other expert opinions, reports, or estimates will not be covered or reimbursed unless we first request or approve the report, service, or other opinion. 5. Payments for all losses are deemed made on the date the payment is mailed to the "insured" or any other person named in the policy or legally entitled to receive payment. 6. The preceding paragraph 5. does not relieve our duty to replace any such payment made by check not yet presented to our bank for payment upon your: a. Notice to us that you or other such intended payee named on the check are not in physical receipt of such payment; and b. Request of its reissuance. 7. In no event will we make duplicate payments for the same element of loss because of the "insured's" failure to notify us of the existence of or termination of an "assignment agreement."
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

FLORIDA ADMINISTRATIVE CODE SECTIONS VIOLATED 69B-220.201(3)(c) – An adjuster shall not approach investigations, adjustments, and settlements in a manner prejudicial to the INSUREDS. 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. The violations asserted herein regarding FIRST PROTECTIVE INSURANCE COMPANY DBA FRONTLINE INSURANCE (“FRONTLINE’s”) bad faith actions are based heavily on the facts and circumstances asserted in the below section designated for same as well as violations of the portions of Florida Insurance Code and Florida Administrative Code upon which the bad faith statutes contained within Sections 624.155 & 625.9541 Florida Statutes, as referenced above. In Florida, the work of adjusting insurance claims engages the Public Trust. FIRST PROTECTIVE INSURANCE COMPANY DBA FRONTLINE INSURANCE (“FRONTLINE”) has breached this duty by its adjustment of its INSUREDS’ claim of loss. This complaint is made on behalf of VINCENT AND ALEXANDRA LOVELLE (“THE INSUREDS”). In consideration of the premium paid to it by THE INSUREDS, FRONTLINE issued a Homeowners Insurance Policy, Policy No. FPH3-000103669 (“the Policy”), for THE INSUREDS’ property located at 3690 Bay Creek Dr, Bonita Springs, Florida 34134 (“the Property”). On or around September 28, 2022, while the Policy was in full force and effect, THE INSUREDS property sustained severe damaged, as a result of Hurricane IAN. Specifically, Hurricane IAN’s wind forces and high wind velocity caused damage to the roof, windows, and interior of the subject property. The direct physical loss and ensuing damage sustained by the Property was a result of Hurricane IAN, a covered peril under the Policy, not subject to any Policy exclusions. The loss was sudden and accidental, and, therefore, a covered peril under the policy. THE INSUREDS timely placed FRONTLINE on notice and FRONTLINE, in turn, had its Claims’ Department open a claim and assigned claim number 01000066865 to THE INSUREDS’ loss. Upon being notified of the loss, FRONTLINE assigned adjuster Kory Kamke (“Kamke”) to adjust the damage to THE INSUREDS property on FRONTLINE’S behalf. On October 22, 2022, Kamke inspected THE INSUREDS’ property and FRONTLINE prepared an estimate. FRONTLINE determined that the cost of the damages to the PROPERTY was $203,422.59 for replacement cost value (RCV) and $183,343.79 for actual cost value (ACV) based on Kamke’s scope of damage. FRONTLINE’s purported valuation of the amount needed to properly repair and remediate the conditions at THE INSUREDS’ property is patently grossly inadequate and clearly accounts for only a fraction of the costs that THE INSUREDS incurred to repair the damages to their home. Due to FRONTLINE’s failure to properly adjust the claim, THE INSUREDS’ trust in FRONTLINE to help wore out, and retained an attorney to aid in pursuing contractual rights to obtain due and owing benefits under the Policy. THE INSUREDS’ counsel sent FRONTLINE a Letter of Representation on November 22, 2022 and requested copies of photos, estimates, expert reports related to the claim, a certified copy of the Policy, a copy of claim related correspondence, and any statements or other documents related to the claim. THE INSUREDS were also forced to retain Archer Adjusting & Appraisal (“Archer”) to prepare a full and adequate estimate of damages, as a result of Hurricane IAN winds to determine the cost of reasonable and necessary repairs to return the property to its pre-loss condition. Archer inspected THE INSUREDS’ Property and prepared an estimate, with the assistance of the General Contractor that will and has been retained to perform the repairs to the subject property, the retail estimate prepared by Archer Adjusting & Appraisal was for $1,720,828.85 to bring the home back to its pre-loss condition. However, prior to water and mold remediation being performed, the carrier requested an engineering inspection of the property, pursuant to their letters dated November 22, 2022 and December 15, 2022, “to determine causation, duration to the roof system, screen enclosure and the interior”. On January 13, 2023, the property was inspected by Glenn Stewart, an engineer employed at EDT Forensic Engineering, prior to any water or mold remediation services being conducted. Nonetheless, on February 2, 2023, a letter was sent to FRONTLINE advising that mitigation/remediation work would be conducted at the property and this would be their final opportunity to inspect the property prior to the work commencing. On March 22, 2023, a partial denial letter was issued by FRONTLINE and advising of the payments made on the claim, specifically, a net amount of $164,203.79 (ACV), after the deductible of $19,140.00 and the prior payment of $4,842.35 was applied. Archer’s estimate established the measurements of the repairs necessary to repair the home from the subject loss. Whereas, the invoices of the General Contractor and other contractors were the actual payments due to bring the home back to its pre-loss condition. Moreover, FRONTLINE was provided proof of said payments by the INSUREDS. However, despite FRONTLINE being provided the invoices to bring the home back to its pre-loss condition for reimbursement, the Carrier has failed to issue any payment other than the initial payment made in this case. The INSUREDS have incurred Replacement Cost Value, pursuant to the Policy, for the damages sustained from Hurricane Ian, but the Carrier has failed to make the INSUREDS whole. On multiple occasions, the INSUREDS provided the carrier of the paid invoices for the work that had been performed on the subject property, along with what was paid by the flood carrier. As early as February 13, 2024, THE INSUREDS provided FRONTLINE with their Sworn Proof of Loss and the estimate to support said damages. On February 19, 2024, THE INSUREDS provided detailed responses to the request for information requested by FRONTLINE. On May 9, 2024, FRONTLINE requested information from THE INSUREDS and on June 14, 2024,THE INSURED, again, responded with detailed responses and the material that they had in their possession. On June 28, 2024, THE INSUREDS advised FRONTLINE that they have provide all the photographs and documentation that is in the possession of i-mold and Service Master. Despite being advised FRONTLINE continuously requests items that are not in the client’s possession. THE INSUREDS have repeatedly requested the monies that are owed and incurred. Documentation has been provided to the carrier on numerous occasions supporting the monies that have been paid by THE INSUREDS for the damages that incurred at the property. To that end, the most recent was the Notice of Intent, which outlines all the damages that payment has incurred; rent payments paid, while the home was unlivable; and outstanding items that still need to be addressed, as a result of this claim. Despite, Ms. Walker receiving this information it is blatantly ignored and no additional monies were issued. Thereafter, a payment request was sent to Ms. Walker for the special assessment from the Homeowner’s Association for the subject property, in which the monies have been incurred by THE INSUREDS. Rather than issuing payment, Ms. Walker took the position that a new claim was necessary and that payment would not be issued in the subject claim. Clearly, the special hurricane damage assessment is related to the subject claim, but again FRONTLINE would rather delay than to issue payment to the insured. Additionally, the roof invoice was provided to FRONTLINE and payment for the additional monies incurred have yet to be provided. As such, FRONTLINE owes $984.49 in the special assessment monies that are due plus the monies demanded within the Notice of Intent to Litigate, with supporting documentation, in the amount of $1,158,793.00, after the applicable deductible and prior payments are applied. Therefore, the total owed is $1,159,777.49. Additionally, THE INSUREDS demanded appraisal on two occasions, Nina Walker on behalf of FRONTLINE has wrongfully failed to name their appraiser and commence the appraisal process when demanded by THE INSUREDS. Initially, on the first request made by THE INSUREDS demanding appraisal that the request was denied due to INSUREDS not executing the agreement demanding same. Shortly thereafter, an executed version was provided to FRONTLINE and at that point they took the position that THE INSUREDS are ineligible for Appraisal because full compliance with the policy was not met. Interestingly, FRONTLINE took the position that they do not have enough information to continue with the Appraisal, but still invoked mediation pursuant to the Notice of Intent Statute. Moreover, THE INSUREDS have advised that they have provided any and all documentation within their possession and yet FRONTLINE denied their request for Appraisal, additional monies that have been incurred, and simply delayed any payment that they are entitled to, pursuant to the Policy. FRONTLINE engaged in conduct directly violating its obligation to THE INSUREDS by attributing the INSUREDS’ damages to factors not covered in the policy or simply delaying the payment that the INSUREDS are entitled to. The physical devastation caused by Hurricane Ian, undoubtedly caused the damage to the INSUREDS’ property. However, rather than recognizing the damages caused by the covered loss, FRONTLINE hired an attorney to conduct examinations under oath of THE INSUREDS for multiple hours. Despite being aware of a medical condition, the handling attorney, Mr. Lombana carelessly and intentionally moved the zoom screen quickly despite THE INSURED’S requests for him not to do so. The INSURED was harmed by these actions and had to seek medical treatment from his Neurologist, as a direct result Mr. Lombana’s actions. Despite having multiple inspections of the property, FRONTLINE has completely delayed the process by continuously requesting the same documentation over and over, despite the client advising that they have provided all the documents within their possession. Having THE INSUREDS sitting for examinations under oath for several hours over more than one day. FRONTLINE has also failed to provide any reports of their engineers or adjusters, who inspected the property on their behalf, as to their opinions to mold or necessary repairs. FRONTLINE has continuously delayed the process and THE INSUREDS are out hundreds of thousands of dollars as they wait for FRONTLINE to do the right thing, and that is to bring THE INSUREDS back to their pre-loss condition. FRONTLINE’s misappropriation of the damage caused by Hurricane Ian exemplifies FRONTLINE’s deceptive trade practices and willful misrepresentation of the facts. The entire purpose of insurance is to indemnify THE INSUREDS for a covered loss. Despite the fact that FRONTLINE knows, or should know, that further insurance proceeds and benefits are owed based upon the information provided by THE INSUREDS, to date, FRONTLINE, failed and/or refused to promptly adjust THE INSUREDS’ claim to the detriment of THE INSUREDS. FRONTLINE’s delay in this matter exacerbated the harm and hardship sustained by THE INSUREDS in connection with this loss. FRONTLINE’s failure to attempt in good faith to settle THE INSUREDS’ Hurricane IAN claim when, under all the circumstances, it could and should have done so, had it acted fairly and honestly toward THE INSUREDS and with due regard for its interest, is a violation of Fla. Stat. §624.155(1)(b)(1), in addition to several other applicable Statutes and Administrative Codes cited in this Notice, which prohibit FRONTLINE from approaching claims or treating INSUREDS in the manner in which it has here. Notwithstanding THE INSUREDS’ repeated pleas and the ample opportunity FRONTLINE had to fully investigate the loss since it was timely reported, to date, FRONTLINE failed and/or refused the provide THE INSUREDS with all the insurance proceeds and benefits due and owing, undisputed or otherwise, and has not tendered the full amount needed to repair the Property despite knowing that THE INSUREDS has sustained covered damages. As FRONTLINE must admit, it is implied within every insurance policy a duty of good faith and fair dealings. In an insurance contract, each party is prevented from interfering with the other’s right to benefit from the contract. The obligations of good faith and fair dealings encompass qualities of decency and humanity inherent in its responsibilities as a fiduciary. FRONTLINE is bound to conduct itself with the utmost good faith for the benefit of THE INSUREDS. However, FRONTLINE failed to comply with its obligations in connection with this claim and has not looked at the claim or the contract for insurance with good faith and fair dealing. Instead, FRONTLINE looked for ways to either delay or avoid paying the claim in full and these actions have been to the detriment of THE INSUREDS. The adjusters assigned to this claim have a duty to adjust and treat all claims equally. Since the beginning of this claim, FRONTLINE has engaged in a pattern of delay, denial, and reckless disregard for THE INSUREDS’ rights. The actions of FRONTLINE listed herein have been continuing in nature and given the totality of the circumstances, FRONTLINE’s adjustment, actions, and/or omissions post the filing of this Civil Remedy Notice. THE INSUREDS contend that given the past experience in this matter with FRONTLINE, it is reasonably foreseeable that FRONTLINE’s current actions will extend to its entire conduct in the handing of their claim, including the acts or omissions of FRONTLINE and/or its representatives, until the final resolution of their claim. As such, THE INSUREDS contend adequate notice has been given should FRONTLINE’s actions and violations listed herein continue after the expiration of this notice. The representatives on behalf of FRONTLINE have approached this investigation in a manner prejudicial to THE INSUREDS. FRONTLINE in using either untrained or improperly trained adjusters in connection with this claim. FRONTLINE should have been adjusting the loss with THE INSUREDS but instead, it looked for ways to delay the adjustment of the claim and/or not to pay the claim at all or in full. It is likely that despite never broaching this idea before, now that attorneys are involved, a demand for appraisal is likely forthcoming, further evidencing its bad faith in handling this claim. If FRONTLINE handles all claims in the manner in which THE INSUREDS’ claim was handled, then it is improperly handling all claims. FRONTLINE’s conduct has been reckless and unfair to THE INSUREDS and has caused and continues to cause damage to THE INSUREDS for failing to pay for what is owed in this case and has been incurred. This is a direct result of the delay and avoidance in investigating and paying the claim and the failure of FRONTLINE to fairly and adequately evaluate THE INSUREDS’ claim. FRONTLINE refused and/or failed to comply with the Policy’s cooperation and/or “Loss Payment” provision(s). Under the Policy, FRONTLINE was to timely tender undisputed insurance proceeds and benefits to THE INSUREDS. FRONTLINE failed and/or refused to timely tender owed insurance proceeds and benefits, undisputed or otherwise. This is a breach of the Policy. FRONTLINE has failed and/or refused to settle the claim when it could and should have done so had it acted fairly and honestly towards THE INSUREDS and has failed to take into account the information and evidence provided that contradict its decisions. FRONTLINE’s conduct has been reckless and unfair to THE INSUREDS and has caused and continues to cause additional damages throughout the property. This is evidenced by the delay in paying the claim and the failure of FRONTLINE to evaluate the claim in total. To date, FRONTLINE has failed and/or refused to provide THE INSUREDS with all the necessary insurance benefits due and owing and has not tendered the full amount needed to repair the Property despite knowing that THE INSUREDS have sustained covered damages to their insured property. FRONTLINE refused and/or failed to cooperate and/or “Adjust the Loss” by failing to cooperate with THE INSUREDS during the claims adjustment process in compliance with the Policy’s “Loss Payment” provision. This is a breach of the Policy. FRONTLINE has a contractual obligation not to make a perfunctory investigation and not to ignore evidence that would support THE INSUREDS’ claim. This is a breach of the Policy. FRONTLINE has a contractual obligation not to look the other way when confronted with facts revealing the possibility of coverage and not to avoid coverage by misinterpreting its Policy. This is a breach of the Policy. The concept of insurance is that insurance is the insurer’s granting of timely and prompt indemnity or security against a contingent loss. Florida Statute §624.02 defines “insurance” as a contract whereby one undertakes to indemnify another or pay or allow specified amount or a determinable benefit upon determinable contingencies. Inherent is the fact that payment must be made timely and promptly, so that THE INSUREDS may mitigate its damages and to put THE INSUREDS back into the position it was in prior to the loss as quickly as possible. FRONTLINE breached this duty. FRONTLINE refused and/or failed to timely investigate the loss and tender all due and owing insurance proceeds to THE INSUREDS upon demand. FRONTLINE’s refusal and/or failure to settle the insurance claim when under all circumstances it could have and should have done so had it acted fairly and honestly towards THE INSUREDS is wrongful conduct. Furthermore, THE INSUREDS contends that FRONTLINE’s adjusters and/or representatives financially benefit by such wrongful conduct. The above facts support the reasons for the notice along with the Florida Statutes that have been violated as a direct result of FRONTLINE’S actions or failed actions to date in their investigation and response to this claim. Therefore, to cure the defects outlined in this Civil Remedy Notice, FRONTLINE must: FRONTLINE must properly, thoroughly, and promptly investigate THE INSUREDS’ Property and tender payment to return the Property to its pre-loss condition; FRONTLINE must immediately tender all undisputed insurance proceeds to THE INSUREDS, including any interest owed under applicable Florida law, while continuing to adjust the loss with THE INSUREDS; FRONTLINE must act fairly and honestly towards THE INSUREDS and with due regard for its interest in attempting to settle THE INSUREDS’ claim; FRONTLINE must immediately tender all insurance benefits due and owing to THE INSUREDS under the Policy pursuant to the relevant Policy provisions provided therein that would reasonably place THE INSUREDS’ Property back to its pre-loss condition, as well as any interest owed under applicable Florida law; and FRONTLINE must pay THE INSUREDS the fair value of its insurance claim in relation to the damages sustained and the documents supplied by THE INSUREDS. FRONTLINE must pay THE INSUREDS the replacement cost value that remains unpaid, the monies to repair the unrepaired areas of the home, and to reimburse THE INSUREDS for the monies incurred for rental and the Homeowner’s special assessment, all of which was provided to FRONTLINE during the pre-suit of this claim, in the amount of $1,208,372.19. THE INSUREDS continue to be open to a fair and reasonable settlement of all claims in an effort to avoid additional delay, costs, and expenses, and hereby request the same prior to the expiration of the statutory “cure” period. THE INSUREDS has provided FRONTLINE with all necessary estimates, invoices, receipts, etc., in support of all claims. FRONTLINE must act fairly and honestly in its response to THE INSUREDS’ request for a fair and reasonable settlement offer.
Comments
User Id Date Added Comment
olombana@salehiboyer.com 04-08-2025 VIA ELECTRONIC SUBMISSION: civilremedy@myfloridacfo.com Florida Department of Insurance Civil Remedy Section 200 East Gaines Street Tallahassee, Florida 32399 Re: Insured: VINCENT LOVELLE Policyholder: VINCENT LOVELLE Filer: SCOTT M ROSSO Claim #: 01000066865 Policy #: FPH3-000103669 CRN filing No.: 813036 CRN filing date: March 25, 2025 To Whom It May Concern at The Department of Financial Services: With this correspondence, First Protective Insurance Company d/b/a Frontline Insurance (“Frontline”) responds to the Civil Remedy Notice of Insurer Violations (“CRN”) filed by SCOTT M ROSSO, Esq. on behalf of VINCENT LOVELLE (the “Insured”). Frontline acknowledges that Alexandra Lovelle is also a named insured under the Policy. After reviewing the CRN, Frontline conducted a thorough review of its handling of the Insured’s claim. Frontline denies that it has violated any of the statutes referenced in the CRN. At all times, Frontline has acted in good faith, fairly and honestly toward the Insured and with due regard for their interests. Frontline also argues that the CRN fails to describe the alleged violations and fails to provide any information such as facts and circumstances which would allow Frontline to correct the alleged violations. The Insured alleges multiple violations of various statutory provisions in the CRN. Specifically, the Insured alleges violations of: 624.155(1)(b)(1); 624.155(1)(b)(3); 626.9541(1)(i)(3)(a); 626.9541(1)(i)(3)(c); 626.9541(1)(i)(4): Frontline denies the allegations that it violated the above referenced statutes. Frontline specifically denies each and every one of the Insured’s allegations that Frontline violated the above referenced statutes. In addition to the allegations specifically denied above, Frontline generally denies all allegations presented in this Civil Remedy Notice as Frontline has not violated any statute or rule, including but not limited to the alleged violations of the Florida Administrative Code. Additionally, Frontline re-asserts its response to Claimant’s prior baseless CRN as if full incorporated herein. CRN MUST BE DISMISSED The CRN is legally deficient and does not comply with Florida law, as it lacks the requisite specificity and factual support necessary to allow Frontline an opportunity to cure the alleged violations. Moreover, the allegations contained therein misrepresent the facts and circumstances surrounding the handling of this claim. The CRN requires the Insured to “indicate all statutory provisions alleged to have been violated.” The CRN filed in this matter includes several statutory provisions that could be claimed against an insurance company, regardless of whether they are relevant or applicable to the allegations contained in the Notice. Because the Civil Remedy Notice fails to allege any specific facts and/or circumstances in support of its allegations, Frontline is unable to properly respond; as such, the CRN should be rejected and returned. The CRN is wholly devoid of any factual allegations relating to the monetary amount of any claims, or any reference to communications (or lack thereof) possibly giving rise to any alleged violation. In Julien v. United Property & Casualty Insurance Company, 311 So. 3d 875 (Fla. 4th DCA 2021), the court affirmed the dismissal of the plaintiff's complaint with prejudice, holding that the Civil Remedy Notice (CRN) was deficient because it failed to specify the statutory and policy provisions at issue. The CRN cited thirty-five statutory provisions and listed nearly every provision in the insurance policy without detailing the specific provisions allegedly violated. The court emphasized that such lack of specificity does not satisfy the statutory requirement to "state with specificity" the policy language and statutory provisions at issue. Insured makes the same fatal error in his CRN allegations as did the Plaintiff in Julien. These glaring deficiencies fail to apprise Frontline of the nature of any purported violation and cannot satisfy the statutory standard of “pleading the facts and circumstances” giving rise to the violation with specificity. The CRN fails to cite specific conduct by Frontline that allegedly constitutes bad faith. Instead, the CRN relies on conclusory statements such as "failure to pay the claim in full" and "failure to act in due diligence," which do not satisfy the statutory requirement of detailing specific actions or omissions. The CRN broadly references multiple statutory provisions and Florida Administrative Code sections but fails to provide a detailed factual basis for each alleged violation. Additionally, the CRN references vague provisions regarding loss payment but fails to cite specific policy language that was allegedly violated. Florida law requires the insured to specifically identify the policy provisions at issue so that the insurer can respond appropriately. The failure to do so renders the CRN invalid under Julien. The CRN first addresses Section 624.155(1)(b)(1), Florida Statute. The CRN alleges that Frontline did not attempt in good faith to settle the claim when it could and should have done so under the circumstances. However, the CRN fails to specify when any settlement opportunity or proposal was made, the details of any such proposal, or how Frontline acted in bad faith. The CRN does not explain how Frontline's claim handling was unreasonable or how the insurer's actions prevented resolution of the claim. To the extent the CRN suggests that Frontline should have tendered payment, it does not provide any factual basis for this contention. Frontline timely investigated and evaluated the claim in accordance with the policy terms. Any disagreement regarding the scope or value of damages does not constitute bad faith, as coverage determinations are based on policy provisions and supporting documentation. Frontline promptly inspected the property, issued payment based on observed damages, and engaged in ongoing communications requesting additional support for the supplemental claim. No evidence has been presented that Frontline acted dishonestly or without due regard. The CRN is devoid of specific facts supporting a violation of this statute, and Frontline denies any allegation of bad faith. Regarding Section 624.155(1)(b)(3), Florida Statutes, the Insured fails to provide any support on the bad faith allegations regarding failure to promptly settle claims. The CRN alleges that Frontline failed to promptly settle the claim when the obligation to settle became reasonably clear. However, it does not provide any factual details about when Frontline should have settled, what amount should have been paid, or how any alleged delay caused harm to the insured. Frontline timely acknowledged, inspected, and evaluated the claim. Additionally, the insured has failed to provide essential documentation despite multiple requests. Without the necessary supporting information, Frontline has not been able to process additional payments, and any delay is directly attributable to the insured’s failure to comply with their obligations under the policy. The CRN lacks specific facts to support this allegation, and Frontline denies any violation of this statute. As to Section 626.9541(1)(i)(3)(c), Florida Statutes, the CRN claims that Frontline failed to acknowledge and act promptly on communications regarding the claim. This is incorrect, as Frontline timely acknowledged the claim and has actively communicated with the insured and their representatives. Frontline has sent multiple requests for supporting documentation, including detailed estimates, invoices, and photographs. The insured has not fully complied with these requests, contributing to any delays in claim resolution. The CRN does not specify any unanswered communications or provide evidence that Frontline failed to respond. Therefore, this allegation is without merit, and Frontline denies any violation of this statute. As to Section 626.9541(1)(i)(4), Florida Statutes, Frontline issued the undisputed ACV payment. Additional amounts remain under dispute due to incomplete documentation and lack of support despite numerous request made. Therefore, this allegation is without merit, and Frontline denies any violation of this statute. Furthermore, contrary to the requirement to “describe the facts and circumstances giving rise to the insurer’s violation as you understand them at this time,” the purpose of which is “to enable the insurer to investigate and resolve [the] claim,” the CRN itself only provides unsupported, conclusory, and incorrect allegations with no basis in fact or circumstance. Aside from the fact that the allegations are devoid of adequate specific facts, the tenor and inferences of the allegations are wholly without merit and Frontline denies each and every one. Frontline, at all times, acted fairly, honestly and in good faith in its dealings with the Insured. Frontline at no time misrepresented any pertinent facts or insurance policy provisions. Frontline conducted a reasonable and prudent investigation of the claim and acted upon all communications from the Insured. Finally, Frontline promptly and appropriately communicated with the Insured and provided explanations for the actions and decisions that were made. Frontline retained a field adjuster and conducted an inspection of the subject property, including an engineer inspection to investigate the Insured’s claim and an examination under oath. Thereafter, Frontline made a coverage decision. Frontline acted in good faith, acted fairly and honestly, acknowledged and acted promptly upon receipt of the claim, attempted to determine coverage for the claim pursuant to the terms of the policy, took reasonable steps to investigate the claim, communicated reasonably with the Insured about the claim, and provided the Insured a reasonable explanation for each of its actions. Additionally, the CRN includes "cures" for the alleged violations; however, these demands are improper under Florida law, specifically as outlined in Talat Enterprises, Inc. v. Aetna Casualty and Surety Co., 753 So.2d 1278, 1281 (Fla. 2000). The Talat decision clarifies that the scope of a permissible "cure" in a first-party insurance claim is limited to the alleged non-payment of the contractual amount due under the policy. The court emphasized that, for there to be a "cure," what must be remedied is solely the non-payment of the contractual amount owed pursuant to the express terms and conditions of the policy, after all conditions precedent have been met. Any demand beyond this, including calls for non-monetary actions such as altering claims-handling procedures or paying amounts unrelated to the covered damages, is improper and contrary to Florida law. The law requires a clear, specific, and feasible cure, and a demand for full payment of an inflated and unsupported amount fails to meet this standard. Such a demand does not account for the insurer's legitimate right to investigate claims, consider prior payments, or enforce policy limits and exclusions. In closing, Frontline asserts that the CRN should be rejected and returned by the Florida Department of Financial Services due to its failure to comply with Florida Statutes §§ 624.155 and 626.9541, as well as applicable Florida case law. Regardless of any potential rejection, Frontline denies all allegations contained in the CRN and maintains that no violations have occurred. The company has handled this claim in good faith, in full compliance with policy provisions, and in accordance with Florida law. While this response is intended to comprehensively address the allegations, Frontline's statements are based on the limited information provided in the CRN and the information available to date. If the insured or his representatives believe Frontline lacks relevant facts, they are encouraged to provide any additional information as soon as possible. It is also important to note that this response is not exhaustive and does not preclude the assertion of other valid defenses should they become necessary. Nothing in this letter, nor any act or omission by Frontline or its representatives, shall be construed as a waiver of any rights or defenses available under the policy, at law, or in equity. All such rights and defenses are expressly reserved. We trust this response sufficiently addresses the allegations contained in the CRN. Should you have any questions or require further clarification, please do not hesitate to contact the undersigned. Regards, /s/ Oscar Lombana Oscar Lombana, Esq. on behalf of First Protective Insurance Company d/b/a Frontline Insurance (“Frontline”)
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