Civil Remedy Filing

Civil Remedy Notice of Insurer Violations

Filing Number: 824999

Filing Accepted: 6/3/2025

Print Filing

Complainant

Last/Business Name *

WORD OF LIFE MINISTRIES, INC

First Name

Street Address *

6111 SOUTH PINE BOULEVARD

City, State Zip *

FORT MYERS, FL 33919

Email Address *

PASTORGWA@GMAIL.COM

Complainant Type: *

Insured

Last/Business Name*		WORD OF LIFE MINISTRIES, INC.		First Name
Policy # *		2019-811411-04		Claim #*		SDA22039720

Attorney

Attorney is Applicable

Last Name*	SAMMAN First Name * LAYLA Initial
Street Address*		1700 NW 64TH STREET, SUITE 460
City, State Zip*		FORT LAUDERDALE , FLORIDA 33309
Email Address *		LSAMMAN@SCHILLINGSILVERS.COM

Violation

Insurer Type *		Authorized Insurer Unauthorized Insurer

Insurer Name
Insurer Name*		UNDERWRITERS AT LLOYD'S, LONDON
Insurer Name*
Street Address*
City, State Zip*		,
NAIC Company Code

Name of individual responsible for violation (if any):* BRAD RIEGLER
Type of Insurance * Commercial Property & Casualty

Reason for Notice *

	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.
	626.9541(1)(i)(3)(a)		Failing to adopt and implement standards for the proper investigation of claims.
	626.9541(1)(i)(3)(b)		Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue.
	626.9541(1)(i)(3)(d)		Denying claims without conducting reasonable investigations based upon available information.

* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

1. Coverage A - Covered Property Covered Property, as used in this Coverage Part, means the type of property described in this Covered Property Section and limited in the Property Not Covered Section, if a Limit of Insurance is shown in the Declarations for that type of property. B. Covered Causes of Loss The Covered Causes of Loss included in this policy means all loss and/or damage arising from the following: 1. Windstorm or Hail which means direct action of wind or direct action of hail, accompanied by wind or not, which causes loss or damage. 15. Loss Settlement Conditions

* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

Word of Life Ministries, Inc. (hereinafter referred to as the “Insured” or “Word of Life,”) purchased a policy of insurance from Certain Underwriters at Lloyd’s, London and Other Insurers Subscribing Authority B60451056862201, and Independent Specialty Insurance Company (hereinafter “Insurers,”) to cover the property located at 6111 S Point Boulevard, Fort Myers, Florida 33919 (hereinafter “Property”) from the Insurers, bearing policy number 2019-811411-04 (“Policy”) with effective dates from April 30, 2022, through April 30, 2023. On or about September 28, 2022, the Property sustained extensive damage as a result of Hurricane Ian. The Insured timely provided notice of the loss and reported the claim to the Insurers, which assigned claim number SDA22039720 (“Claim.”) To assist in the handling of the Claim, Word of Life retained a public adjuster, Phoenix Claims Consulting. Through their public adjuster, Word of Life hired DDC Group, a licensed Certified Building Contractor. DDC Group inspected the Property and created estimates for remediation and stabilization to save and preserve the Insured Property. DDC also created an estimate for restoration services to return the Property to its pre-loss condition. DDC Group further involved the mitigation services of Restoration Performance Group (“RPG,”) a company to perform environmental testing services named Environmental Testing & Assessment, LLC (“ETA,”) and air conditioning testing services provided by Building Science Authority (“BSA.”) All invoices and estimates to either save and preserve Insured Property and/or to return the Property to its pre-loss condition exceeded the Policy limits for Coverage A under the policy in the amount of $3.5 Million Dollars. Despite the exponential amount of information provided to the Insurers regarding the extent of the damages sustained to the Property, the Insurers failed to properly adjust the loss with Word of Life. On or about January 23, 2023, the Insurers issued a coverage determination letter, making an advance on the building settlement for the loss to the Property in the amount of $100,000.00. The Insurers retained EFI Global to inspect the Property following the Insurers’ determination of coverage. On or about June 1, 2023, the Insurers made a supplemental payment in response to EFI Global’s inspection of the property. The Insurers issued further payment in the amount of $260,768.10. On or about June 14, 2024, following a subsequent review of the Claim, the Insurers made an additional payment for rebuild in the amount of $72,424.60, and for mitigation in the amount of $188,914.85. Despite the supplemental payments made, the Insurers substantially undervalued the Claim. It is clear by the extensive damage caused to the Property that the payments made by the Insurers do not to allow Word of Life to return the Property to its pre-loss condition. Throughout the handling of the Claim, the Insurers have made every effort to suppress the value of the Claim. Furthermore, instead of working with Word of Life to fully adjust the loss to a conclusion which would allow Word of Life to return the Property to its pre-loss condition, the Insurers did nothing more than create further issues for Word of Life. Specifically, on or about October 21, 2022, multiple consultants with Sedgwick, who is a third-party administer acting on behalf of the Insurers, appeared at the Insured Property. The Consultants created a hostile environment and demanded that mitigation services terminate immediately. Based on the conduct and direction of the Sedgewick Consultants, Word of Life made the decision to halt all efforts to protect the Property. What goes against all common sense is the Insurers’ instruction to stop all mitigation efforts when the Insurers did no testing and gathered no information as to whether the mitigation efforts were necessary. Instead of allowing Word of Life to prevent the Property from sustaining further damage, the Insurers chose to risk that the damage to the Property would worsen. To make matters worse, at the time of the Insurers’ claims adjuster’s inspection, the claims adjuster presented himself to Word of Life wearing a tactical vest labeled “Claimanator,” with a demeanor that frightened the members of the Church at Word of Life. This claims adjuster made it clear that it was his way or the highway in regard to both the handling of the Claim as well as the future with respect to the damage status and evaluation thereof at Word of Life. Instead of working with Word of Life to resolve the Claim and assist in restoring the Property, the Insurers allowed their claims adjuster to disrupt the process and continue to delay the Property’s return to its pre-loss condition. What is most disturbing is that the “Claimanator” wore a tactical vest. One can imagine the intent of this individual to wear such a specific item to inspect a House of Worship. Following the initial inspection of the Property, Sedgwick Consultants again inspected the Property. However, during Sedgwick’s inspection, the claims adjusters very aggressively and repeatedly requested that the Public Adjuster show him “some water damage” because he “didn’t see any, because there wasn’t any.” Furthermore, Sedwick’s claims adjusters called Pastor Anastasi and representatives of Word of Life, along with the mitigation team, liars, arguing that the Property was not wet and did not show any significant signs of water intrusion. Each and every statement made by Sedgwick’s claims adjuster does not align with the facts. What really shows the intent and professionalism of Sedgwick’s representatives is the statements made regarding bringing in “real restoration people” rather than “the people off the streets” in reference to members of DDC Group and RPG Restoration, all of which were actively working to prevent the Property from further damage. As a surprise to no one, following the Insurers’ instruction to stop all mitigation efforts, the moisture levels at the Property spiked. Furthermore, the Insurers retained a mold assessor to inspect the Property to determine if mold was present. At the time of the inspection, the mold assessor strategically chose to test portions of the Property where they knew no mold would exist. The Insurers retained HVACI to inspect the HVAC systems on the Property. HVACI’s report confirmed that 14 of the 15 HVAC systems on the Property needed to be replaced due to hurricane related damages, and that the damages extended into the soft side ventilation ducts. Despite HVACI’s findings, the Insurers failed to make any additional payments to replace the damages HVAC systems. Other than inspecting the property, the Insurers made no effort to adjust the loss with Word of Life despite their legal obligation to do so. Instead, the Insurers continuously undervalued the Claim. After being provided with estimates for repairs to return the Property to its pre-loss condition, invoices for emergency mitigation services, and environmental assessment reports, the Insurers still failed to properly adjust the loss. The Insurers continued their sub-par investigation by gathering historical data of the Property to attempt to use it to their advantage. However, the historical data is inconsistent with all of the Insurers’ post-claim underwriting. Throughout the adjustment of the Claim, the Insurers continuously claimed that the roofing system on the Property had prior damage, and all claimed damage to the roofing system is a result of wear and tear rather than the reported cause of loss - Hurricane Ian. However, what the Insurers fail to admit is their full knowledge that there was nothing wrong with the roofing system prior to the date of loss and Hurricane Ian. The Insurers know full and well that there was no prior damage to the roofing system. The Insurers know this as a result of the inspections done of the Property at the time of purchase, wherein the Insurers underwrote an insurance policy without a single mention of damages to the roofing system. The evidence of damage to the roofing system as a result of Hurricane Ian speaks for itself. But to speak even further, the evidence of clay roofing tiles from the neighboring residential complex landing and sticking straight into the ground on the front lawn of the Property speaks volumes as to the wind speed at the Property on the date of loss. Despite this, the Insurers continued to fail to properly adjust the loss with Word of Life. As a result of Hurricane Ian and the damages sustained to the Property, mitigation services were rendered to the Property. These mitigation services included, but were not limited to, dry-out services to remove the excess water which infiltrated the property after the loss, and an attempt to dry any lingering moisture throughout the Property. The dry-out services went on continuously for months in an attempt to prevent the Property from sustaining further damage, and to address the trapped moisture in the foam of the roofing structure. Upon receiving invoices for the rendered services, the Insurers failed to make payments to fulfill those invoices. The Insurers knew Word of Life incurred additional expenses for the mitigation services rendered to the Property, however, the Insurers intentionally failed to release the full payment amount to Word of Life. This is just another example of the Insurers’ deliberate and strategic plan to continuously suppress the value of the Claim. 626.9541(1)(i)(3)(a) Failing to adopt and implement standards for the proper investigation of claims Word of Life states the above recitation of facts as if fully set forth herein as applicable to Florida Statute 626.9541(1)(i)(3)(a), and would further state: The Insurers had numerous opportunities to inspect the Property and properly adjust the loss. Instead, the Insurers sent a claims adjuster to the Property that had no interest or intention of properly inspecting the Property. The Insurers further sent a mold assessor to the Property that had no interest or intention of properly inspecting the Property for mold. Instead, the mold assessor only tested portions of the Property in which he knew no mold would present itself. The Insurers had all information and documentation from representatives at DDC, RPG, SBA, and ETA for any and all necessary remediation, mitigation, and rebuild efforts to the Property, yet failed to make any effort to properly investigate the damage to properly adjust the loss. 626.9541(1)(i)(3)(b) Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue. Word of Life states the above recitation of facts as if fully set forth herein as applicable to Florida Statute 626.9541(1)(i)(3)(b), and would further state: The Insurers flat refused to acknowledge that the subject policy requires “[the Insurers] to adjust all loss[es] with [Word of Life].” The Insurers have made no effort to properly adjust the loss with Word of Life. Instead, the Insurers continuously chose not to release the monies owed under the invoices presented to them for the incurred expenses for emergency mitigation services rendered to protect and restore the Property. Furthermore, the Insurers were provided with estimates created by DDC group for repairs to return the Property to its pre-loss condition, however, the Insurers failed to make any effort to issue payment in accordance with the estimates. 626.9541(1)(i)(3)(d) Denying claims without conducting reasonable investigations based upon available information. Word of Life states the above recitation of facts as if fully set forth herein as applicable to Florida Statute 626.9541(1)(i)(3)(d), and would further state: The Insurers failed to make any additional supplemental payments that would allow Word of Life to return the Property to its pre-loss condition. The Insurers were wholly aware that the payments made throughout the adjustment of the Claim do not even begin to repair even the roofing system of the Property, let alone allow all repairs to be completed. The Insurers were wholly aware of the extensive damage caused to the Property by Hurricane Ian, however the Insurers failed/refused to adjust the loss with the Insured. Based on the above, it is irrefutable that the Insurers knowingly and intentionally performed a sub-par investigation into the claim to the detriment of Word of Life. The financial detriment caused to Word of Life is a direct result of the Insurers’ reckless investigation. In other words, the Property is left in a state of disrepair with damages worsening as the Insurers continue to suggest they cannot adjust the Claim because they cannot be bothered to take the time to acknowledge the information which has been provided to them. The Insurers continue to make no effort to properly adjust the loss with Word of Life. The Insurers have quite frankly done nothing as they continue to disadvantage Word of Life. Upon information and belief, the aforementioned actions complained of herein are being perpetrated by the Insurers so often as to constitute bad faith conduct as a general business practice, evidencing a motive to enhance the Insurers’ profits, and designed to cause a detrimental effect to its policyholders. The above clearly depicts that the Insurers failed/refused to adjust this claim in bad faith and that Certain Underwriters at Lloyd’s, London and Other Insurers Subscribing to Binding Authority B60451056862201 is in direct violation of Unfair Claims Practices, by knowingly failing to issue payment based on the estimates and invoices provided to them. This notice is given in order to perfect the right to pursue the civil remedy authorized by Section 624.155, Florida Statutes, should the Insurers fail to cure the violations set forth in this Civil Remedy Notice within the given cure period. Therefore, to cure the defect outlined in this Civil Remedy Notice, the Insurers must: Immediately tender all insurance benefits in the amount of $2,877,892.45. Word of Life still hopes that this claim can be resolved amicably. Failure to cure the defects as described herein will result in additional extra-contractual damages. Should the Insurers fail to cure the violations set forth in this Civil Remedy Notice within the given cure period, Word of Life reserves the right to seek restitution through litigation.

Comments

User Id		Date Added		Comment
LSamman@schillingsilvers.com		07-22-2025		Pursuant to a confidential settlement agreement, the subject Civil Remedy Notice is hereby withdrawn.

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. Before submitting a Notice using this system, please verify that all text has been entered correctly and completely. Once the Notice has been submitted, the text cannot be changed or deleted.

DFS-10-363
Rev. 10/14/2008