Civil Remedy Notice of Insurer Violations
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Filing Number:     820585
Filing Accepted:  5/9/2025
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Complainant
Last/Business Name *  
13435 GULF BLVD LLC   First Name  
Street Address * 13435 GULF BLVD,
City, State Zip * MADEIRA BEACH, FL 33708
Email Address * JODI@LAWHUGGINS.COM
Complainant Type: * Insured
Insured
Last/Business Name*   13435 GULF BLVD LLC   First Name  
Policy # * 6638691093 Claim #* 05000002892
Attorney
Attorney is Applicable
Last Name* PETERS First Name * JODI Initial
Street Address* 6421 N FLORIDA AVE D-598
City, State Zip* TAMPA , FLORIDA 33604
Email Address * JODI@LAWHUGGINS.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   FRONTLINE INSURANCE UNLIMITED COMPANY
NAIC Company Code 10074
 
Name of individual responsible for violation (if any):* KEN ROBINSON
Type of Insurance * Commercial 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)(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)(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)(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).
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.

The Insurer has not provided a copy of the Policy, despite the Insureds’ request. The violations described herein derive from Florida law concerning insurers’ obligations to their insured. See, e.g., Fla. Stat. Chapters 626, 627. Specific policy language that may be relevant to the violations include, but are not limited to, the following: Building Coverage provisions, All Additional Coverages provisions, All Coverages provided by Endorsement or Rider, The Declarations, Page Loss Payment, Settlement provision, and the insurance policy's definition section.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

The Insurer’s adjuster(s) assigned to this claim were/are: Ken Robinson. Hereinafter referred to as the “Adjuster” or “Adjusters”. - On May 9, 2025, the undersigned sought to verify that Adjuster Robinson held a valid Florida adjusting license and appointment, performing a search on https://licenseesearch.fldfs.com for the following terms: ‘Robinson’, and ‘Robinson’ & ‘Ken’. No person matching Adjuster Cox arose in the search results. Although persons named ‘Ken Robinson arose in the search results, it was impossible to verify whether Adjuster Robinson was in fact licensed and appointed. Moreover, none of the entries show any links to the Insurer. Accordingly, it is likely that Adjuster Robinson lacked a Florida adjusting license and/or was not appointed during the administration of this claim. Here, the Insurer has violated Fla. Stat. § 626.112(1)(a) (“No person may be, act as, or advertise or hold himself or herself out to be an insurance agent, insurance adjuster, or customer representative unless he or she is currently licensed by the department and appointed by an appropriate appointing entity or person. [...] Any person who knowingly transacts insurance or otherwise engages in insurance activities in this state without a license in violation of this section commits a felony of the third degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084.”). Here, the insurer violated the provisions of Florida Statute § 626.9541(1)(i)(3)(i) by conducting unfair claim settlement practices. The insurer also violated the provisions of Florida Statute § 624.155(1)(b)(1) by failing to attempt in good faith to resolve this claim 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 his interests. Moreover, the insurer violated the provisions of Florida Statute § 626.9541(1)(i)(3)(b) by misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue. - The Insured suffered a loss due to Hurricane Milton that occurred on or about October 9, 2024. The Insured’s covered property was damaged by the loss. To this date, there has not been a coverage decision on this claim. - The Insured hired Premier Claims (“Premier”) to assist in the proper administration of the insurance claim. Having conducted thorough investigations and analysis, Premier prepared an estimate of costs to repair the damaged property in the amount of RCV $208,626.18. Premier sent the Insurer a letter of representation on October 23, 2024, providing Premier’s claim file and requesting information—including a copy of the policy, claim payment history, and other claim documents. - The Insured submitted a sworn proof of loss to the Insurer on March 14, 2025. The insurer violated the provisions of Florida Statute § 626.9541(1)(i)(3)(e) by 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. . - To date, six months since the claim has been submitted, Adjuster Robinson has yet to make a coverage decision on this claim. The Insurer violated the provisions of Florida Statute § 626.9541(1)(i)(3)(f) by 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. The Insurer violated the provisions of Florida Statute § 626.9541(1)(i)(3)(i) by conducting unfair claim settlement practices as a result. - The roof damage is consistent with hurricane force wind, showing impact from flying debris. Due to the extent of damages and the requirement of a proper repair under Florida law, a full roof replacement would be warranted under the Policy. The Insurer violated the provisions of Florida Statute § 624.155(1)(b)(1) by failing to attempt in good faith to resolve this claim 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 his interests. The Insurer violated the provisions of Florida Statute § 624.155(1)(b)(3) by 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. The Insurer violated the provisions of Florida Statute § 626.9541(1)(i)(3)(d) by denying claims without conducting reasonable investigations based upon available information. The Insurer violated the provisions of Florida Statute § 626.9541(1)(i)(3)(f) by 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. The Insurer violated the provisions of Florida Statute § 626.9541(1)(i)(3)(i) by conducting unfair claim settlement practices. - It has been six months since the claim has been submitted and the Insurer has not made a coverage decision on this claim. The Insurer violated Fla. Stat. § 626.9541(1)(i)(4) by 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 an act of God, prevented by the impossibility of performance, or due to actions by the insured or claimant that constitute fraud, lack of cooperation, or intentional misrepresentation regarding the claim for which benefits are owed. See also Fla Stat § 627.70131(7)(a) ("Within 60 days after an insurer receives notice of [a] ... property insurance claim from a policyholder, the insurer shall pay or deny such claim or a portion of the claim"). Moreover, the insurer violated the provisions of Florida Statute § 624.155(1)(b)(1) by failing to attempt in good faith to resolve this claim 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 his interests. The insurer violated the provisions of Florida Statute § 626.9541(1)(i)(3)(a) by failing to adopt and implement standards for the proper investigation of claims. The insurer violated the provisions of Florida Statute § 626.9541(1)(i)(3)(c) by failing to acknowledge and act promptly upon communications with respect to claims - The Insurer’s conduct in this case is one instance a pattern of business practice designed to avoid or delay coverage determinations for claims, supplemental claims, and/or additional claims by failing to render a determination when requested, failing to make payments of undisputed amounts of claims, and 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. - To cure the conduct giving rise to the violations described herein, insurer must: (i) pay the total replacement cost value of the Insured’s Claim in the amount of $208,626.18, less prior payments and the deductible; (ii) make payment of any pre-judgment interest owed under Florida law; (iii) make payment for the additional expense incurred by the Insured in hiring an attorney; and (iv) implement appropriate standards and procedures for claims investigations and resolution in regard to the outstanding amount of this Claim.
Comments
User Id Date Added Comment
emily@lawhuggins.com 04-01-2026 The Insureds hereby amend the RCV from $208,628.18 to $308,628.18.
kelsasser@bressler.com 07-08-2025 Bressler, Amery & Ross, P.C. 515 E. Las Olas Blvd., Suite 800 Fort Lauderdale, FL 33301 July 8, 2025 Via U.S. Mail, Certified Mail and E-mail: 13435 Gulf Blvd LLC c/o Jodi Peters, Esq. 6421 N Florida Avenue, D-598 Tampa, FL 33604 Jodi@lawhuggins.com Complainant : 13435 Gulf Blvd LLC Policy # : 6638691093 Claim # : 05000002892 DFS Filing # : 820585 Dr. Ms. Peters: We write on behalf of Frontline Insurance Unlimited Company d/b/a Frontline Insurance (“Frontline”) to respond to the Civil Remedy Notice (“CRN”) of Insurer Violations submitted to the Department of Financial Services (hereafter “DFS”) on behalf of 13435 Gulf Blvd LLC (the “Complainant”). DFS accepted the CRN on May 9, 2025, and Frontline is responding to and rejecting all of the allegations against Frontline in connection with the above-referenced claim and otherwise. The CRN alleges violations of the following statutory provisions: 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)(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)(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 the offer of a compromise settlement. 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). 626.9541(1)(i)(3)(i) Failing to pay personal injury protection insurance claims within the time periods required by s. 62.736(4)(b). To summarize Frontline’s response to the allegations in the Complainant’s Civil Remedy Notice, Frontline hereby denies all of the allegations contained in the CRN, including but not limited to any allegations identified above. Simply put, Frontline denies any act or omission that could be construed or found to be deemed bad faith and/or a violation of Florida Statutes § 624.155, § 624.401, § 626.9541, § 627.70131, § 627.702 and Florida Administrative Code §§ 69B-220.201 whether expressly stated in the Civil Remedy Notice or implied. Any and all allegations of bad faith are hereby denied and rejected in their entirety by Frontline. Frontline affirmatively states that it acted in the utmost good faith at all times. Frontline denies and rejects the instant CRN as it fails to comply with the requirements of Fla. Stat. § 624.155. The Complainant is required to set forth specific policy provisions relevant to the violations. Complainant’s CRN fails to do so, stating generally that there is specific policy language that may be relevant to the alleged violations, and listing potentially relevant areas that may contain language relating to the alleged violations. However, the Complainant fails to include actual policy language upon which the Notice is based. The CRN clearly fails to comply with this statutory requirement and as such, is invalid. Additionally, Fla. Stat. § 624.155(1)(b)(1) requires that a CRN “state with specificity”, inter alia, the facts and circumstances giving rise to the violation(s) alleged. The CRN appears to be intentionally light on facts, or perhaps even more troublesome, contain blatantly false sets of facts. More specifically, the CRN alleges that as of the filing of the CRN it had been more than six (6) months with no coverage determination, yet a coverage determination letter was issued with a date of May 5, 2025, several days prior to the filing of this CRN. Additionally, the CRN alleges that they were unable to verify a valid Florida adjusting license for the assigned claims adjuster, Ken Robinson, while simultaneously referring to him as “Mr. Cox.” Not only is any allegation that Mr. Robinson is an unlicensed adjuster in Florida inaccurate, but the refence to him by the incorrect name further supports the boilerplate nature of the allegations lodged on the CRN. Therefore, Frontline vehemently rejects these allegations and maintains that the CRN fails to provide the requisite specificity thereby rendering it invalid on its face. Furthermore, the CRN contains a cure with non-monetary conditions that are illusory and unascertainable due to the lack of specificity in the non-monetary demands. Instead, the Complainant makes the following generalized demand: “implement appropriate standards and procedures for claims investigations and resolution in regard to the outstanding amount of this Claim.” The CRN does not address which standards and procedures are inappropriate and should be changed, nor does it include any facts relating to Insured’s claim to support this demand. Moreover, the CRN states that in order to cure the violations, Frontline must pay RCV in the amount of $208,626.18, less prior payments and deductible; pay pre-judgment interest; and pay for Insured’s attorney fees and costs. As was the case throughout the claim adjustment, the Insured provided no explanation as to how the number was reached or why a complete replacement of the entire roofing system was necessary as a result of the loss. As such, it is impossible to cure the violations in accordance with the CRN’s demands. With regard to the actual underlying facts of the insurance claim from which this CRN arises, on October 29, 2024, Frontline received notice from Premier Claims LLC of alleged hail and wind damage to the roof of the insured location at 13435 Gulf Blvd., Madeira, FL 33708, having reportedly occurred on October 9, 2024. In response, Frontline promptly commenced an investigation, including issuing a claim notification letter dated November 4, 2024, along with a Reservations of Rights (“ROR”) dated November 2, 2024. This ROR reminded the Insured of possible coverage concerns for any unscheduled fences and trees, as well as the Exclusion of Cosmetic Damage to Roof Surfacing Endorsement. This ROR also expressly included a request for information, including, in most relevant part, a Sworn Statement in Proof of Loss. To date, no Sworn Statement in Proof of Loss has been submitted to Frontline for the subject loss and claim as unambiguously required under the terms of the policy. Frontline also retained building consulting firm, M6 Building Solutions (“M6”), as well as engineering firm, Root Cause Consulting (“RCC”) to assist in its investigation. To that end, after several attempts to coordinate an inspection, the first inspection was completed by Bryon Maynor with M6. This inspection revealed that the insured location had already been cleaned and painted on the exterior where damage had reportedly occurred. Mr. Maynor also observed that patches had been made to areas of the TPO roofing system that were reportedly necessitated by the loss. Mr. Maynor concluded that it appeared the insured location had been subject to tidal surge. A second inspection was that completed by RCC professional engineer, Scott Roberts on February 14, 2025. Based on Mr. Roberts’ inspection, RCC issued a reporting finding that approximately 32 ft. of fascia and gutters were damaged by wind forces associated with the subject loss. Similarly, there was evidence of 9 impact locations noted on the roof surface and evidenced in photographs supplied which were consistent with wind borne debris and/or impacted-related damage to the roof membrane. Importantly, the impacted areas of the roofing system amounted to approximately 1% of any given roof section and therefore could be repaired in accordance with Florida Building Code. RCC also noted some unrelated damage, including debonded portions of the roof membrane above the right front central parapet wall consistent with long-term moisture accumulation and long-term wear, coupled with deficient materials or methods used at the time of installation. Finally, RCC concluded that given the interior repair efforts undertaken before its inspection, they were precluded from observing the reported interior staining and moisture intrusion and could not opine on the exact extent or duration of the reported moisture intrusion. It is of the utmost importance to note that the policy requires that the Insured comply with policy conditions in the event of loss to covered property, including permitting an inspection to prove the loss or damage. Notwithstanding, RCC further opined that the gap in the seam above the central parapet wall, staining at the garage wall of the north building, and reported moisture intrusion at the right-side wall were all inconsistent with damage from a storm related opening. Ultimately, Frontline issued a coverage determination letter dated May 5, 2025, advising of the findings of its investigation, including its valuation of the damages to Location 1 Building 1 and Location 2 Building 2, both of which fell below the applicable deductibles of $25,000 and $15,000, respectively. Importantly, the coverage letter expressly advised the Insured of the findings of RCC as it relates to the TPO roofing system, absence of any interior damage from a storm related opening, and material alterations that hindered RCC from opining on extent and duration of reported interior moisture intrusion. Moreover, an estimate from M6 supporting Frontline’s below deductible determination was provided to the Insured. As such, Frontline expressly rejects any and all allegations that it failed to conduct a reasonable or thorough investigation, failed to provide a reasonable explanation in writing of the facts and policy provisions in support of its determination, or that it misrepresented pertinent facts or policy provisions. To the extent that this response does not address each and every allegation of bad faith conduct made by the Complainant and the Insured, Frontline hereby expressly and vehemently denies any and all allegations of bad faith conduct or omission set forth in the CRN, and/or any alleged violation of Fla. Stat. § 624.155 or any other statutory section set forth therein. Again, Frontline insists that it has acted, at all times, in utmost good faith. Contrary to the unsupported statements contained in the CRN, the facts of this case are that Frontline promptly investigated the reported loss, conducted a thorough and fair independent investigation, and issued its coverage decision based upon all information presented. Frontline at all times treated the Insured with respect, acted with candor, conducted its investigation in good faith, and complied with all of its obligations under the Policy. Frontline performed its duties under the subject policy of insurance and applicable Florida law and did not at any time whatsoever act in bad faith towards this Insureds in the handling of the subject claim. To the extent that the statutory violations and administrative code violations cited in the CRN are applicable to the actions of an Insurance Company, Frontline affirmatively asserts that it did not violate any of the cited provisions. Should you need any additional information from Frontline regarding the foregoing, please feel free to contact the undersigned. Very truly yours, /s/ Krista L. Elsasser Krista L. Elsasser, Esq.
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