Civil Remedy Notice of Insurer Violations
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Filing Number:     824589
Filing Accepted:  6/2/2025
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Complainant
Last/Business Name *  
JACKSONVILLE PLAZA 1, LLC DBA SOUTEL PLACE   First Name  
Street Address * 4750 SOUTEL DRIVE
City, State Zip * JACKSONVILLE, FL 32208
Email Address * JAXSONVILLEPLAZA1@GMAIL.COM
Complainant Type: * Insured
Insured
Last/Business Name*   JACKSONVILLE PLAZA 1, LLC DBA SOUTEL PLACE   First Name  
Policy # * GLPRNC000080-02 Claim #* 63522-086403
Attorney
Attorney is Applicable
Last Name* STRUBLE First Name * MATTHEW Initial
Street Address* 325 FIFTH AVENUE, SUITE 103
City, State Zip* INDIALANTIC , FLORIDA 32903
Email Address * SERVICE@STRUBLECOHEN.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   GREAT LAKES INSURANCE SE
NAIC Company Code
 
Name of individual responsible for violation (if any):* AND ALL ADJUSTERS, SUPERVISORS, MANAGEMENT AND INDIVIDUALS ASSOCIATED WITH OR RETAINED BY GREAT LAKES INSURANCE SE RELATED TO THIS CLAIM.
Type of Insurance * Commercial Property & Casualty   
Reason for Notice *
Claim Denial
Claim Delay
Unsatisfactory Settlement Offer
* Statutory provision(s) which the insurer allegedly violated.
 
624.155(1)(b)(1) Not attempting in good faith to settle claims when, under all the circumstances, it could and should have done so, had it acted fairly and honestly toward its insured and with due regard for her or his interests.
626.9541(1)(i)(3)(a) Failing to adopt and implement standards for the proper investigation of claims.
626.9541(1)(i)(3)(b) Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue.
626.9541(1)(i)(3)(d) Denying claims without conducting reasonable investigations based upon available information.
626.9541(1)(i)(3)(g) Failing to promptly notify the insured of any additional information necessary for the processing of a claim.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

There are no policy provision specifically at issue or in dispute, the policy provides coverage resulting from hurricane but Great Lakes Insurance SE has failed to extend coverage for repairs needed for the insured property.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

Insurer issued an insurance policy bearing policy number GLPRNC000080-02 with effective dates of coverage from March 27, 2022 to March 27, 2023, which insured the property located at 4750 Soutel Drive, Jacksonville, Florida 32208. The policy was in effect when the property sustained damage on or about 11/10/2022, when damage was caused by a hurricane. Great Lakes Insurance SE (“Insurer”) received notice of the claim for property damage resulting from hurricane, and related damages on or about 11/10/2022. The damage was reported to Insurer which assigned Claim Number 63522-086403 to the claim and investigated the claim. Insurer failed to retain the experts needed to perform the inspection and needed to address the damage at issue and determine the repairs needed to restore the property. Insurer has been provided with documents establishing that the claim is covered, despite this being apparent from the condition of the property alone. Insurer has failed to extend coverage for payments owed and has refused to attempt to settle the claim with its insured. Insurer’s delay in issuing payment is causing and will cause the insured to sustain extra-contractual damages not covered by the property, including loss of use and enjoyment of the property and related damages, costs associated with hiring adjusters and experts, among other damages and these uninsured damages would not have occurred but for the insurer ’s failure to timely issue payments owed. In this claim and as a business practice, insurer fails to retain experts needed to investigate claims, ignores evidence establishing coverage and avoids covered repairs to attempt to avoid issuing payments owed pursuant to the insurance policy. Insurer can cure these violations by attempting to settle the claim in good faith and issuing payment for the remaining contractual damages owed. As Insurer is aware, issuing payment for contractual damages owed will preclude recovery of extra-contractual damages already incurred, and that will be incurred, and the contractual damages should immediately be paid and be paid within 60 days from the date of this notice. Due to applicable Florida Statutes, and the insurance policy’s payment provisions, the payment issued should also include interest. If insurer contends there is somehow more information needed that was not already provided, it should immediately advise the insured’s attorney what information is needed. Insurer has been provided with information establishing that the claim is covered but has failed to extend coverage for the claim. Insurer’s denial of the claim and refusal to issue payment is a breach of the insurance policy. This notice is being given in order to perfect the right to pursue the civil remedy authorized by this section.
Comments
User Id Date Added Comment
service@strublecohen.com 07-09-2026 Pursuant to amicable settlement, the Insured/Complainant hereby withdraws this Civil Remedy Notice of Insurer Violations. /s/ Eduardo Ramirez, Esq., Counsel for Jacksonville Plaza 1, LLC DBA Soutel Place
tgoff@bakerdonelson.com 07-31-2025 Dear Sir or Madam: Baker, Donelson, Bearman, Caldwell & Berkowitz PC (“Baker Donelson”) has been retained by Great Lakes Insurance SE (“GLISE”) to respond to that certain Civil Remedy Notice (“CRN”) assigned File Number 824589 by the Florida Department of Financial Services and filed by Jacksonville Plaza 1, LLC d/b/a Soutel Place (the “Insured”), concerning Policy # GLPRNC000080-02, with an effective period from March 27, 2022 through March 27, 2023 (the “Policy”). In response to the CRN, GLISE states as follows: As a preliminary matter, GLISE denies all allegations set forth in the Insured’s CRN, submits that no such violations have occurred, and maintains the CRN should be rejected and returned by the Department of Financial Services due to its failure to comply with Florida law. The CRN is form-pled and generic, with unsupported conclusions of fact and determinations of law. In fact, the information and documentation comprising the claim file materials fail to show a bona fide claim for bad faith conduct. The Insured is mistaken concerning material aspects of the claim adjustment, and it appears the Insured is misinformed about the actions GLISE took in adjusting this claim. The allegations and oversights in the CRN do not reflect the facts surrounding this claim and the Policy, and the CRN should accordingly be rejected. The CRN form requires that the Complainant, “Pursuant to Section 624.155, F.S. please indicate all statutory provisions alleged to have been violated.” The Insured’s CRN cites five different statutes as allegedly violated, accusing GLISE of not attempting in good faith to settle claims; failing to adopt and implement standards for the proper investigation of claims; misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue; denying claims without conducting reasonable investigations based upon available information; and failing to promptly notify the insured of any additional information necessary for the processing of a claim. These statutory duties have absolutely no bearing on the instant dispute, and their citation hinders GLISE’s ability to reasonably understand the Insured’s complaints. Indeed, the facts identified in the CRN do not support the alleged violation of these statutory provisions, and the vague and generic nature of the violations alleged highlights the suspect purpose behind the CRN. Thus, the CRN should be rejected and returned accordingly. Florida’s form for Civil Remedy Notice of Insurer Violations instructs complainants, in relevant part, as follows: “To enable the insurer to investigate and resolve your claim, describe the facts and circumstances giving rise to the insurer’s violation as you understand them at this time.” Though the Insured’s CRN sets forth certain facts and circumstances regarding the claim, the CRN fails to provide facts that would give rise to the violations alleged or that would otherwise support a claim for bad faith. The CRN’s failure to specify the facts that purportedly triggered its filing demonstrates yet another reason why the CRN should be rejected and returned. Accordingly, GLISE respectfully requests the Civil Remedy Notice of Insurer Violations be rejected for the reasons cited above. Notwithstanding the foregoing, GLISE now responds to the few facts alleged in the CRN. As noted above, GLISE issued a Commercial Lines Policy to the Insured, bearing policy number GLPRNC000080-02, with effective dates from March 27, 2022 to March 27, 2023 (i.e., the Policy), subject to and in accordance with the Policy’s terms, conditions, limitations, exclusions, and endorsements, and all applicable provisions of Florida law, for the subject property located at 4750 Soutel Drive, Jacksonville, Florida 32208 (hereinafter, the “Property”). Notice of this Hurricane Nicole loss (DOL: November 10, 2022) was provided on September 16, 2024, nearly two years after the purported date of loss. Prior to reporting the claim, the Insured had retained Horizon Public Adjusters (the “PA”) on or about September 3, 2024. International Programs Group (“IPG”) was assigned to adjust and administer the Claim on behalf of GLISE, and an independent adjuster (the “IA”) was assigned to inspect the loss. On or about October 12, 2024, the IA inspected the Property, and found no visible evidence of physical or cosmetic wind/hail damage to the roof, instead observing signs of age, wear and tear, and deterioration, with ponding in multiple areas and an inadequate drainage system. The roof was thought to be 25 years old, and interior damage appeared to be confined to a few examples of fallen/stained ceiling tiles in tenant spaces. The TPA sent correspondence to the Insured and PA on October 21, 2024 and November 19, 2024, requesting supporting documentation and damage evidence and advising that the claim was still under investigation. Instead of providing the requested information, the Insured, through its then-counsel, Eric Tarrash, Esq. with Tarrash & Tarrash, filed a Notice of Intent to Initiate Litigation (“NOI”) (No. 224270) on January 8, 2025, demanding $1,066,918 in damages. Attached to the NOI was an estimate prepared by the PA, totaling $1,322,480.01 (RCV) / $1,315,256.86 (ACV). Given that a coverage determination had not yet been made, Baker Donelson conferred with Mr. Tarrash, who withdrew the NOI on or about January 20, 2025. Thereafter, GLISE retained Rimkus Consulting Group (the “Engineer”) who inspected the Property on January 31, 2025. The Engineer concluded: 1. The lack of detached, curled, scraped, torn or missing modified bitumen covering (Mod Bit) was consistent with no wind damage to the roof. 2. The reported windstorm and rainstorm on November 10, 2022, did not cause the inadequate slope, inadequate drainage, or water intrusion through at the roof. 3. Inadequate slope and drainage, standing water, accumulated sediment, thermal expansion and contraction, alligator cracking, and deferred maintenance, caused the roof to deteriorate and allow moisture to infiltrate through the roof covering. These conditions had been ongoing for at least 20 years and were not caused by any singular weather event. 4. The lack of roof drains at the low point of the roof was a construction deficiency. 5. The wind speed at the Building on November 10, 2022, was 54 mph, which was not considered a reportable wind event. The Engineer also noted that there had seventeen reportable wind events between 58 and 83 mph at the Property from February 7, 2015 to February 6, 2025, with twelve of them between February 8, 2015 and the date of loss. On February 18, 2025, GLISE issued a coverage determination letter to Mr. Tarrash, denying the claim and citing the Engineer’s findings and applicable Policy language. The next day, on February 19, 2025, Mr. Tarrash filed another NOI (No. 231420) on behalf of the Insured. GLISE responded by reaffirming the denial. On May 16, 2025, a different counsel, StrubleCohen (the “Insured’s Counsel”), sent its letter of representation to GLISE, and on June 2, 2025, Insured’s Counsel submitted a Sworn Statement in Proof of Loss (“SPOL”) to GLISE, wherein the Insured claimed $1,322,480.01 (RCV) / $1,315,256.86 (ACV) in damages for the loss. In response, GLISE sent correspondence on June 17, 2025, demanding the Examination Under Oath (“EUO”) of the Insured, and requesting certain additional information, as follows: i. All bids, proposals, estimates, contracts, receipts, or invoices related to any roof repairs, improvements, or replacements contemplated or performed at the Property within the last five (5) years. ii. All bids, proposals, estimates, contracts, receipts, or invoices related to any repairs or improvements contemplated or performed to the interior or exterior of the Property within the last five (5) years. iii. All photographs depicting the claimed damage to the Property resulting from Hurricane Nicole on November 10, 2022. iv. All records concerning post-loss mitigation efforts you performed after Hurricane Nicole on November 10, 2022. In response to the request for information, the Insured provided claims correspondence, the PA’s Estimate, the SPOL, and two roofing bids – one from SRNR Global LLC, dated July 12, 2025, totaling $864,000, and another from Truepoint Roofing, dated July 15, 2025, totaling $825,000. The EUO of the Insured’s designated representative, John Clemenza, took place on July 16, 2025. Of particular relevance, Mr. Clemenza testified that he was unsure whether a tarp had ever been placed on the roof of the Property, and he could not recall the significance of the reported date of loss or whether the Insured’s property manager had advised of any damages to the Property from Hurricane Nicole. As of the date of filing the instant response, Mr. Clemenza’s testimony and the Insured’s responsive documents are in review with GLISE and Baker Donelson. In other words, GLISE’s investigation of the Insured’s claim is still ongoing. The CRN’s allegations are largely just a list of statutory duties which essentially mirror the previously cited statutes, including allegations that GLISE has: 1) failed to settle the claim in good faith; 2) failed to issue payment for damages owed; 3) failed to retain the experts needed to perform the inspection; and 4) failed to extend coverage despite having information that establishes the claim is covered. However, as described above, GLISE promptly acknowledged the Insured’s claim and engaged multiple qualified professionals to investigate the loss. During GLISE’s investigation, it was revealed that there was no wind damage to the Property, and thus, coverage was denied. Moreover, the Insured violated the Policy’s post loss conditions by failing to promptly report the claim and failing to take reasonable steps to prevent further damage to the Property. The Insured has offered no allegations, details, or evidence to support the finding that this claim was improperly adjusted, much less provided a basis by which it could support a claim for bad faith. Absent any evidence contradicting its well-reasoned and extensively supported conclusions, GLISE has no reason to alter its coverage position. To cure the violations, the CRN does not provide any specific demands, but rather, vaguely states that “issuing payment for contractual damages owed will preclude recovery of extra-contractual damages already incurred, and that will be incurred, and the contractual damages should immediately be paid…within 60 days from the date of this notice.” As discussed above, GLISE has completed the adjustment in accordance with Florida law and the express terms and conditions of the Policy and did not find any basis for coverage. Furthermore, in addition to there being no wind-caused damage to the Property, the Insured provided extremely belated notice of a claim with a date of loss of which the Insured has no recollection. Thus, absent any proof indicating otherwise, no coverage can or should be afforded at this time, and no basis exists to afford the Insured the relief requested. Accordingly, for the reasons set forth above, GLISE respectfully requests that the Civil Remedy Notice of Insurer Violations be rejected and returned. While this response is meant to be comprehensive, it is based upon the limited, vague allegations set forth in the Insured’s CRN and information made available to GLISE to date. Accordingly, this response to the Insured’s CRN is not necessarily exhaustive and shall not preclude GLISE from asserting any other valid reason(s) for the rejection and return of the Insured’s CRN. Further, GLISE expressly reserves all available rights and defenses available to it under the subject insurance policy, as well as Florida law. GLISE has always complied with the provisions of the applicable policy of insurance, while consistently acting fairly, honestly, and in good faith towards the Insured, with the utmost regard for the Insured’s interests. Neither this response, nor any actions taken by GLISE, should be construed as a waiver of any rights or defenses available under the subject policy, or Florida law. We trust this correspondence adequately addresses the matters raised in the Insured’s CRN, but please do not hesitate to contact us with any questions, concerns or requests for additional information concerning this matter. Sincerely, David B. Levin
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