Civil Remedy Notice of Insurer Violations
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Filing Number:     769954
Filing Accepted:  6/26/2024
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Complainant
Last/Business Name *  
LALLA   First Name   SUNIL & BHARTI
Street Address * 3518 STUART COURT
City, State Zip * FORT MYERS, FL 33901
Email Address * WITHHELD
Complainant Type: * Insured
Insured
Last/Business Name*   LALLA   First Name   SUNIL @ BHARTI
Policy # * SJ30337597 Claim #* SL22204046
Attorney
Attorney is Applicable
Last Name* FREDERICK First Name * FORREST Initial TODD
Street Address* 4887 BELFORT ROAD, SUITE 200
City, State Zip* JACKSONVILLE , FLORIDA 32256
Email Address * TFREDERICK@MERLINLAWGROUP.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   SLIDE INSURANCE COMPANY
NAIC Company Code 17227
 
Name of individual responsible for violation (if any):* KOREY ANDERSON, MICHELLE VILA, DAVID STUBBS, ZACH MARSTON
Type of Insurance * Residential 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.
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)(c) Failing to acknowledge and act promptly upon communications with respect to claims.
626.9541(1)(i)(3)(g) Failing to promptly notify the insured of any additional information necessary for the processing of a claim.
626.9541(1)(i)(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.

SECTION I – PERILS INSURED AGAINST A. Coverage A – Dwelling And Coverage B – Other Structures I. We insure against risk of direct physical loss to property described in Coverages A and B. II. We do not insure, however, for loss: a. Excluded under Section I – Exclusions; SECTION I – CONDITIONS I. Loss Payment. is replaced by the following: I. 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. Loss will be payable upon the earlier of the following: 1. 20 days after we receive your proof of loss and reach written agreement with you; or 2. 60 days after we receive your proof of loss and: a. There is an entry of a final judgment; or b. There is a filing of a mediation settlement with us. 3. If payment is not denied, within 90 days after we receive notice of an initial, reopened or supplemental claim. However, this provision (I.3.) does not apply if factors beyond our control reasonably prevent such payment.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

Form DFS-10-363, Rev. 10/14/2008, contains a field for the insured to include his email address. Prior to filing the CRN, said form contains an instruction that, in the event the insured does not with for certain information to become part of the public record, the insured must simply include the term “WITHHELD” to satisfy the filing requirement. This is further established through the following statement with appears on Civil Remedy Notices which have been filed: Warning! Information submitted as part of this civil remedy notice is a public record. Data entered into this form will be displayed on the DFS website for public review. Please DO NOT enter Social Security Numbers, personal medical information, personal financial information or any other information you do not want available for public review. As any information contained herein becomes part of the public record, the insured has withheld his email address so as not to make it available for public review and indicated the same accordingly. Furthermore, as the insured is represented by counsel, it would be improper for any representative of Slide Insurance Company to contact the insured directly for any reason utilizing his email address, and, as such, the information is neither material to Slide IC’s ability to correct the violations contained herein nor required by the Department of Financial Services. Slide IC should direct all follow-up correspondences to the abovementioned attorney. Furthermore, as the above section requests people with knowledge as to the allegations in the instant CRN often gets cut off, the following are those responsible for the violations alleged herein: Korey Anderson, Michelle Vila, David Stubbs, Zach Marston, and all other adjusters, supervisors, management and individuals associated with or retained by Slide Insurance Company who are involved in this claim. The facts and circumstances giving rise to the insurer's violation as the insured understands them at this time: SUNIL LALLA AND BHARTI LALLA (hereinafter the “insured” or “Complainant”) purchased a property insurance policy, policy number SJ30337597 (hereinafter the “Subject Policy”) from Slide Insurance Company (hereinafter “Slide IC”) which, at all times material hereto, provided property insurance for the property located at 3518 Stuart Ct, Fort Myers, FL 33901-7737 (hereinafter the “Subject Property”). On or about September 28, 2022, Hurricane Ian, a covered cause of loss, caused direct physical loss and resultant ensuing damages to the Subject Property. The insured timely notified Slide IC of the loss on or about October 01, 2022. Slide IC assigned claim number SL22204046 to the loss (hereinafter the "claim") and assigned adjustment of the claim to Korey Anderson who, in turn, enlisted the assistance of David Stubbs & Zach Marston, an “independent” field adjuster employed by Eberl Claim Services, to perform an inspection of the Subject Property. On October 07, 2022, the Insured’s Public Adjuster (“PA”), Mahlon Jager, submitted his letter of representation to Slide IC. On October 07, 2022, Eberl Claim Services inspected the Subject Property. On December 7, 2022, desk adjuster Korey Anderson provided the initial estimate provided payments of $50,811.16 & $1226.39. On December 27, 2022, the Slide IC sent correspondence requesting estimates, receipts, and other documentation. On or about January 15, 2023, the PA submitted all available requested documentation known to be in existence to the Insured and the PA. On or about January 20, 2023, the PA submitted his letter of representation to Slide IC along with the PA’s estimate of damages totaling $809,538.91. On or about April 20, 2023, adjuster Michelle Vila provided a letter containing a net settlement offer of $2,508.15. The insured has been left with no choice but to hire an attorney in order to file a notice of intent to initiate litigation subject to Fla. Stat. § 627.70152. Based on the documentation previously submitted, and the coverage afforded, Slide IC could have requested participation in alternative dispute resolution in line with the terms and conditions of the Subject Policy and governing Florida law or, at a minimum, engaged in settlement negotiations with the insured in order to allow him to move on from this chapter and effectuate the necessary repairs to the Subject Property; instead, Slide IC chose to sit back and wait before Slide IC ever thought to act in a manner inconsistent with their own self-interest, forcing the insured into hiring an attorney, thereby coming further out of pocket and leaving less of the outstanding due and owing insurance proceeds for actual repairs. This delay in claims adjustment constitutes a pattern of de facto bad faith conduct. The insurer has undervalued the covered loss based solely upon a visual inspection by its adjuster. The Insurer has failed to properly address and evaluate covered damages that were caused by this loss and has failed to issue full payment and otherwise restore the property to its pre-loss condition. The Loss caused substantial, direct, and consequential damages, and the Insurer’s general business practice of willful, wanton, immoral, deceptive, and bad faith claims handling policies, procedures, guidelines, protocol, adjusting, investigating, drawing valuations, and issuing payment for the claims has caused the Complainant to suffer further harm and extra-contractual damages which have accrued and will continue to accrue. The stated misconduct is collectively referred to as “Bad Faith,” and the specific factual and/or legal considerations in relation thereto are further outlined below for its consideration in accordance with Fla. Stat. Sec. 624.155 and the cited legal authorities associated therewith. 1.) Insurer insures thousands of homes throughout Florida, where the Complainant’s residence is located. Even though the Insurer knows that it has a fiduciary duty to its insureds, it failed to institute the necessary policies, procedures, guidelines, protocol, personnel, and contingencies in relation to fully, promptly, and equitably indemnifying its insureds. Consequently, insureds such as the Complainant was forced to: fend for themselves to mitigate damages arising from Insurer’s Bad Faith; incur out of pocket expenses that Insurer was required to afford pursuant to the Policy; absorb the burden, expense, inconvenience and delay associated with an insurer who was not equipped (because it didn’t want to incur the expense associated therewith) to meet its contractual obligations; risk health hazards associated with the presence of moisture, toxic conditions and/or mold due to Insurer’s failure to perform pursuant to the Policy; be placed in situation where they have to incur the costs associated with hiring experts/professionals/counsel to force Insurer to abide by its fiduciary duty and avoid the consequential damages associated with Insurer’s failure to perform pursuant to its fiduciary duty; etc. 2.) Insurer knew that hurricane and windstorm losses such as the one at issue in this claim are of a nature that a thorough and specialized investigation or adjustment of the claim needs to be promptly performed by qualified and prepared personnel to protect its insureds, satisfy its fiduciary duties, and otherwise not engage in the Bad Faith claim handling practices at issue. That said, to the detriment of its insureds and to maximize its financial interests, Insurer disregarded the obvious and known obligations by way of the following: (a.) Not developing, maintaining, and/or instituting policies, procedures, protocols, or guidelines to determine whether adjusters, personnel, and/or vendors utilized to protect its insureds were qualified to duly assess the scope and/or value of the loss or damages. (b.) By way of the cited legal authorities and considerations, the Insurer knew that it would have to promptly hire a significant volume of contractors, uniquely qualified adjusters, and/or engineers to fully, equitably, and honestly assess the scope and/or value of the loss or damages suffered by its insureds. Although the Insurer will hire such experts to establish a lack of coverage as it relates to a specific claim in which it determines coverage may be in dispute, it chooses to avoid such expense for self-gain when it knows that a windstorm and hurricane such as the one at issue in this claim (Hurricane Ian) is undoubtedly covered under the policy. (c.) By way of the cited legal authorities and considerations, the Insurer knew that it would be in its insured’s interests and its obligation under the insurance policy to utilize personnel or vendors to perform moisture meter assessments throughout the insured property to honestly assess the full extent of damages and losses suffered by its insureds. Such practice is a basic, inexpensive, efficient, and industry-wide accepted means of protecting its insureds. However, the Insurer knows that it does not serve its financial interest since it will increase its financial obligations to insureds such as the Complainant. Although the Insurer will implement such methods to establish a lack of coverage as it relates to a specific claim in which it determines coverage may be in dispute, again, it chooses to avoid such expense for self-gain when it knows that a windstorm or hurricane loss such as the one at issue in this claim is undoubtedly covered under the policy. (d.) By way of the cited legal authorities and considerations, the Insurer knew that it would be in its Insureds’ interests and its obligation under the insurance policy to utilize personnel or vendors to perform thermal imaging assessments throughout the insured property to honestly assess the full extent of damages and losses suffered by its insureds. Such practice is a basic, inexpensive, efficient, and industry-wide accepted means of protecting its insureds. However, the Insurer knows it does not serve its financial interest since it will increase its financial obligations to insureds such as the Complainant. Although Insurer will implement such methods to establish a lack of coverage as it relates to a specific claim in which it determines coverage may be in dispute, again, it chooses to avoid such expense for self-gain when it knows that a windstorm or hurricane loss such as the one at issue in this claim is undoubtedly covered under the policy. (e.) By way of the cited legal authorities and considerations, the Insurer knew that it would be in its insureds’ interests and its obligation under the insurance policy to utilize personnel or vendors to perform detailed, thorough, reliable, and qualified assessments of any structural component of the home affected by the Hurricane, including but not limited to just the locations in which moisture made entry. Such practice is a basic, inexpensive, efficient, and industry-wide accepted means of protecting its insureds. However, the Insurer knows it does not serve its financial interest since it will increase its financial obligations to insureds such as the Complainant. Although the Insurer will implement such methods to establish a lack of coverage as it relates to a specific claim in which it determines coverage may be in dispute, again, it chooses to avoid such expense for self-gain when it knows that a windstorm or hurricane loss such as the one at issue in this claim is undoubtedly covered under the policy. (f.) By way of the cited legal authorities and considerations, the Insurer knew that it would be in its insureds’ interests and its obligation under the insurance policy to retain a licensed mold assessor to determine whether there were concealed conditions within the home which necessitated mold remediation and the need for its insureds to take precautionary measures to preserve their physical health and property interests. Such practice is a basic, inexpensive, efficient, and industry-wide accepted means of protecting its insureds. However, the Insurer knows it does not serve its financial interest since it will increase its financial obligations to insureds such as the Complainant. Although the Insurer will implement such methods to establish a lack of coverage as it relates to a specific claim in which it determines coverage may be in dispute, again, it chooses to avoid such expense for self-gain when it knows that a windstorm or hurricane loss such as the one at issue in this claim is undoubtedly covered under the policy. (g.) By way of the cited legal authorities and considerations, the Insurer knew that it would be in its insured’s interests and its obligation under the insurance policy to promptly issue payment for professional and qualified moisture assessments and remediation to, avoid: the development of hazardous and toxic conditions within the residence; preclude the insured from suffering consequential and extracontractual damages; the development of an uninhabitable residence and various risks that may develop; etc. Such practice is a basic, reasonable, necessary, and industry-wide accepted means of protecting its insured. However, the Insurer knows that it does not serve its financial interest since it will increase its financial obligations to insureds such as the Complainant. (h.) By way of the cited legal authorities and considerations, the Insurer knew that it would be in its insured’s interests and its obligation under the insurance policy to promptly issue payment for mold assessments and mold remediation to avoid the development of hazardous and toxic conditions within the residence; preclude the insured from suffering consequential and extra-contractual damages; the development of an uninhabitable residence and various risks that may develop; etc. Such practice is a basic, reasonable, necessary, and industry-wide accepted means of protecting its insured. However, the Insurer knows it does not serve its financial interest since it will increase its financial obligations to insureds such as the Complainant. (i.) By way of the cited legal authorities and considerations, Insurer knew that it would be in its insured’s interests and its obligation under the insurance policy to utilize a licensed mold remediator to consider a licensed mold assessor’s assessments and protocol to honestly determine the true scope and value of damages and/or the loss. Such practice is a basic, inexpensive, efficient, and industry-wide accepted means of protecting its insureds. However, the Insurer knows that it does not serve its financial interest since it will increase its financial obligations to insureds such as the Complainant. Although Insurer will implement such methods to establish a lack of coverage as it relates to a specific claim in which it determines coverage may be in dispute, again, it chooses to avoid such expense for self-gain when it knows that a windstorm or hurricane loss such as the one at issue in this claim is undoubtedly covered under the policy. (j.) By way of the cited legal authorities and considerations, the Insurer knew that it would be in its insured’s interests and its obligation under the insurance policy to carefully consider all policy terms that afford coverage for a windstorm or hurricane loss and thereafter utilize counsel when an adjuster is in doubt to advise them on a claim by claim basis whether it is duly indemnifying its insureds as a matter of law. Such practice is a basic, inexpensive, efficient, and industry-wide accepted means of protecting its insureds. However, the Insurer knows that it does not serve its financial interest since it will increase its financial obligations to insureds such as the Complainant. Although the Insurer will implement such methods to establish a lack of coverage as it relates to a specific claim in which it determines coverage may be in dispute, again, it chooses to avoid such expense for self-gain when it knows that a windstorm or hurricane loss such as the one at issue in this claim is undoubtedly covered under the policy. (k.) By way of the cited legal authorities and considerations, Insurer knew that it would be in its insured’s interests and its obligation under the insurance policy to carefully evaluate on a claim-by-claim basis whether any amounts appropriated for “depreciation” are based on sufficient facts and data, reliable principles and methods, and/or the application of reliable principles and methods. In reality, the Insurer knows that it is arbitrarily, capriciously, deceptively, willfully, and wantonly appropriating depreciation without any claim/item-specific consideration to justify the same. In the aggregate, and unbeknownst to its insureds, this sham practice allows the Insurer to unjustly avoid millions of dollars in benefits owed to its insureds, who are consequently placed in a position wherein they are financially coerced into choosing whether to leave their homes in the state of disrepair or alternatively, searching for handyman and non-licensed vendors to perform makeshift repairs which create secondary risks and potential damages that Insurer will deny coverage for when they arise. (l.) By way of the cited legal authorities and considerations, the Insurer knew that it would be in its insured’s interests and its obligation under the insurance policy to carefully evaluate on a claim-by-claim basis, and only after equitably and fully investigating and adjusting the claim, the amounts owed to the insured for overhead and profit associated with the insured’s reasonable need to utilize a general contractor; taxes associated with the repairs; permit costs associated with the repair; costs associated with various licensed trades that will be needed to effectuate the repairs; whether benefits are owed to the insured for loss of use and/or additional living expenses; personal property that may have been affected by any toxic, mold, and/or moisture conditions that developed in the home; costs associated with maintaining the continuity of the finish or appearance for pairs or sets such as cabinets, flooring, roof coverings, walls, ceilings, etc. (m.) By way of the cited legal authorities and considerations, the Insurer knew that it had an obligation to ensure that software programs, databases, and adjusting practices utilized to estimate the scope and value of the Loss were being utilized in a form that: honestly and fully delineated the line item repairs or costs that needed to be performed; pricing corresponded with licensed professionals - as opposed to handyman or non-licensed professionals; accounted for consideration of actual expenditures incurred by the insureds or otherwise compensable expenses on a repair cost basis; etc. Ultimately, the Insurer knows that the adjusting practices are guided to unlawfully deprive its insureds of benefits owed under the insurance policy, which, in the aggregate, serves to maximize its profits to the detriment of its insureds. (n.) By way of the cited legal authorities and considerations, the Insurer knew that it had an obligation to honestly, promptly, in continuity, reliably, and fairly communicate with its insured in relation to their rights and obligations under the policy, basis for payment and/or nonpayment, policy conditions and/or exclusions which are being considered in relation to payment and/or nonpayment; etc. Not only has the Insurer disregarded said duty, but it knows that it serves its financial interest by ultimately deterring a large volume of insureds from lawfully obtaining benefits. (o.) By way of the cited legal authorities and considerations, the Insurer knew that it had an obligation to treat all insureds equally and honestly. However, and for its own financial interest, they will only start to fully consider its obligations as stated herein if the insured retains legal representation and pursues a legal action that exposes them to liabilities and costs associated with, inter alia, Fla. Stat. Secs. 627.428, 54.071 and 624.155. Even then, they will withhold monies owed unjustly to limit/delay its liabilities in relation to the statutory considerations and otherwise. (p.) By way of the cited legal authorities and considerations, the insurer knows that it has a continuous and ongoing duty not to engage in the bad faith conduct that is the subject of this complaint, even after litigation ensues. However, to advance its own financial interest and avoid the liabilities pursuant to the above-cited statutory authorities, it will direct and utilize counsel to delay the equitable and prompt payment of the claim via delay tactics and by otherwise not implementing policies, procedures, and/or guidelines to ensure that its duties are fulfilled during the course of litigation. Moreover, it will insist upon the insureds to fulfill its own obligations by imposing upon them the burden to establish their full entitlement to benefits for which Insurer knows or should know, are owed or subject to further assessments and considerations for the reasons set forth herein. (q.) By way of the cited legal authorities and considerations, the Insurer knows that it has to assess the application of the policy deductible on a case-by-case basis and only after the claim is fully adjusted and investigated. This practice is necessary to protect the interests of insureds since, pursuant to binding precedent, the policy deductible is subject to being absorbed by losses and/or damages that, inter alia, exceed a limitation of coverage under a certain section of the policy, constitute the full amount of the damages or losses before the application of depreciation or other secondary considerations that serve to, in part, limit full payment from the onset. (r.) By way of the cited legal authorities and considerations, the Insurer knows that it has a duty to duly assess whether benefits are owed to the insured in relation to the costs associated with removing and resetting personal property in relation to repairs and/or remediation work that needs to be performed. This duty is ignored by the Insurer to maximize its own financial interests. Further, they have a duty to assess whether the personal property has been contaminated by way of toxic moisture conditions that developed due to the loss and consequential damages. (s.) By way of the cited legal authorities and considerations, the Insurer knows that it has a duty to issue payment for interest owed in relation to payments that were untimely issued per governing authorities. With that said, and to the detriment of its insureds, it foregoes and/or delays such considerations to maximize its financial interests. (t.) By way of the cited legal authorities and considerations, the Insurer knows that it has a duty to consider the specific circumstances which served to create damages to the insured property. Such concealed conditions can slowly serve to destroy the residence and/or are of a nature that, if claimed months or years later, the insurer will assert that they are not covered pursuant to certain policy conditions or exclusion. Thus causing progressive, unknown, and substantial injury/damages to its insureds and a potential inability to insure the real property, sell the real property, reside in the real property, maintain a safe environment within the real property, assess the necessary scope of repair, etc. (u.) Although from the onset of the Loss, Insurer will have no good faith basis to deny coverage in part and/or in whole for a loss/damage, they will delay notifying insureds that coverage has been accepted, and/or otherwise delay performing, to: maximize its financial interests; unlawfully and deceptively withhold monies for its own use; utilize policy conditions as a shield in litigation; utilize policy conditions at later date to further delay payment when the insured demands performance under the policy; and/or to otherwise implement a deceptive and immoral scheme to deprive insureds of benefits owed under the policy. (v.) Although the Insurer knows that it has a duty to treat all insureds and assignees equally, it will consistently act inconsistently in relation to the application of policy limits; how valuations and/or the scope of repair is assessed, how an insured is required to comply with policy conditions; the application and/or consideration of policy conditions and/or exclusions to bar coverage; the timing and/or circumstances upon which undisputed payments will be made pre-suit and post-suit; etc. The lack of consistency and organization ultimately deprives insureds of their rights under a policy and otherwise creates an inherently dishonest, immoral, and unfair means of adjusting and investigating claims. (w.) The Insurer knows that once the claim is fully and fairly investigated and adjusted, it then has to determine whether certain benefits are owed to the insureds for the cost of insurance in relation to the construction and repairs that need to be performed. These costs are avoided by the Insurer by engaging in the Bad Faith conduct described herein. (x.) The Insurer knows that once the claim is fully and fairly investigated and adjusted, it then has to determine whether certain benefits are owed to insureds for the cost of engineering fees in relation to the construction and repairs that need to be performed. These costs are avoided by the Insurer by engaging in the Bad Faith conduct described herein. (y.) The Insurer’s Bad Faith conduct, as described, places the insured in a position where it has to unnecessarily incur expert fees to secure judicial relief through a legal action. Moreover, and as part of the Bad Faith practice, the Insurer will await the insured’s post-suit retention of an expert to retain a designated and predisposed (due to financial biases) expert to further delay its obligations to its insured and the consequential liabilities that the legislature has imposed to deter Insurer from engaging in the Bad Faith practice. Insurer’s bad faith claims handling practices, as described above, leave insureds, the insured’s counsel, the insurer’s counsel, and even the judiciary guessing as to when and how the Insurer will duly perform. This described Bad Faith conduct not only serves to maximize the Insurer’s prospective financial gains by being able to avoid paying benefits, it also serves to minimize the Insurer’s loss adjusting expense as it sees fit to the invariable detriment of its insureds, the Complainant, and ultimately the tax paying citizens of this State that bear the expense of the judicial system, which needs to unravel the tangled web created by Insurer. To cure the above-stated immoral, deceptive, unlawful and collectively defined general business practice of Bad Faith claims handling practices that are knowingly, willfully, wantonly and/or with a reckless disregard for the insured’s interests being implemented, Insurer must perform as follows within 60 days of receiving this Complaint: 1. Take corrective action in association with the Bad Faith claims handling practices by way of rectifying same and thereafter duly adjusting, investigating and issuing payment for all benefits owed to the Complainant; 2. Confessing judgment in relation to any pending breach of contract action brought forth by the Complainant and/or confessing judgment in relation to any pending declaratory action brought forth by the Complainant; 3. To the extent verified after duly performing under the policy pursuant to citied authorities and considerations, issuing any and all payments owed to the Complainant pursuant to the Complainant's damage estimate as well as interest on benefits that were untimely paid; 4. As it relates to any claims benefits that may remain in dispute or undetermined, fairly, honestly, specifically, meaningfully, and substantively disclosing to the Complainant’s counsel the basis therefor and the means to promptly reach a resolution; 5. And otherwise fulfilling any and all obligations under the policy that it knows, or should know, remain to be performed, including but not limited to issuing full indemnity payment to the Complainant for all ensuing damages. Based on counsel's own research, the bad faith behavior perpetrated by Slide IC occurs so frequently as to indicate a general business practice. Substantially similar bad faith behavior complained of is public record in the form of civil remedy notice of insurer violations filed with the Florida Department of Financial Services. Slide IC averages more than one civil remedy notice for substantially similar bad faith behaviors daily, totaling 774 total notices filed between 1/1/2022 & 12/31/2023. So far in 2024, as of the date of this writing, Slide IC has received 263 CRNs in 177 days. These complaints nearly all contain a common modus operandi: Slide IC drastically undercovers a claim, either through a minimal payment in comparison to the actual damages or a below-deductible letter, along with, and on many occasions, a partial denial of coverage. Once its insured submits documentation that evidences a discrepancy in the adjustment of the claim, Slide IC piecemeals further adjustment, delays adjustment, and ultimately denies or underpays the claims after little to no investigation after the initial independent adjuster inspection. Slide IC will find reasons to delay additional coverage and/or payments. Furthermore, despite each Slide IC adjuster possessing an email address and accepting correspondences via email, Slide IC refuses to provide courtesy copies of correspondences via email to the Public Adjusters, an instantaneous method of communication, and, instead, opts to send all correspondence via US mail so as to even further delay the claim. Slide IC also routinely ignores the required payment for statutory interest despite issuing delayed payments which would otherwise require same. As the bad faith business practices outlined above are so rampant that in the small sample size of claims, it is anticipated that the same practices are generally utilized throughout the litany of claims adjusted by Slide IC and, as such, constitute willful, wanton, and malicious actions in reckless disregard for the rights of its insureds. As such, it is clear that the repeated and generally utilized business practices of Slide IC violates Florida Statutes 624 and 626, as well as the Florida Administrative Code governing adjusters' ethical requirements, and the pattern and practice of de facto bad faith adjustment tactics can be established without the need for any further investigation of Slide IC’s claim files or file management system. Through its actions/inactions, subject to the facts and circumstances understood at this time as outlined herein, Slide IC has violated the following sections of Florida Statutes: §624.155(1)(b)(1) Not attempting in good faith to settle claims when, under all circumstances, it could have and should have done so, had it acted fairly and honestly toward its Insured and with due regard. §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)(c) Failing to acknowledge and act promptly upon communications with respect to claims; §626.9541(1)(i)(3)(g) Failing to promptly notify the insured of any additional information necessary for the processing of a claim; §626.9541(1)(i)(4) Failing to pay undisputed amounts of partial or full benefits owed under first-party property insurance policies within 90 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. Additionally, through its actions/inactions, subject to the facts and circumstances understood at this time as outlined herein, Slide IC has failed to comply with the following sections of Florida Administrative Code: 69B-220.201(3)(b) An adjuster shall treat all claimants equally. 69B-220.201(3)(b)(1) An adjuster shall not provide favored treatment to any claimant. 69B-220.201(3)(b)(2) An adjuster shall adjust all claims strictly in accordance with the insurance contract. 69B-220.201(3)(c) An adjuster shall not approach investigations, adjustments, and settlements in a manner prejudicial to the insured. 69B-220.201(3)(d) An adjuster shall make truthful and unbiased reports of the facts after making a complete investigation. 69B-220.201(3)(e) An adjuster shall handle every adjustment and settlement with honesty and integrity, and allow a fair adjustment or settlement to all parties without any compensation or remuneration to himself or herself except that to which he or she is legally entitled. 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. 69B-220.201(3)(k) An adjuster shall not undertake the adjustment of any claim concerning which the adjuster is not currently competent and knowledgeable as to the terms and conditions of the insurance coverage, or which otherwise exceeds the adjuster’s current expertise. As a direct result of Slide IC's actions, the insured has sustained irreparable harm. Upon information and belief, the aforementioned actions complained of herein, among others, are effectuated by Slide IC so often as to constitute a general business practice evidencing a motive to enhance Slide IC's profits and cause a detrimental effect to its policyholders. Slide IC clearly failed to adopt and implement standards for the proper investigations of claims. As a direct and proximate result of Slide IC's handling of the claim, the insured sustained extra-contractual damages, including, but not limited to, a public adjuster's fee and attorneys’ fees and costs. Slide IC's implemented claims programs and practices that were improper which directly resulted in additional losses to its insured. Slide IC, as part of its routine business pattern and practices, employs outcome-oriented adjusters/vendors/experts who purposely looked for ways to minimize coverage instead of affording coverage to its policyholders. In contrast to the legislative intent which motivated the enumeration of an insurance adjuster’s responsibilities outlined in the Florida Administrative Code, the insured were not afforded the professional duties entrusted and imposed on Slide IC by the Public Trust. The outcome-oriented claim adjustment practices undertaken by Slide IC led to Slide IC's failure to adequately adjust the Claim. Based on the above, it is clear that Slide IC must have a reason to act with such blatant disregard to policy, statute, rules, code, and procedure. The only possible motive an insurance company could have to act in such an egregious manner is that Slide IC is somehow benefiting financially through its bad faith actions. If a financial motive for acting in bad faith proves to be true, Slide IC, and, through the piercing of Slide IC's corporate veil, its officers individually, should be monetarily sanctioned by all entities governing insurance in the State of Florida but also its license to write new insurance policies should be suspended until such a time as it has indemnified all outstanding claims. This notice is given in order to perfect the right to pursue the civil remedy authorized by Section 624.155, Florida Statutes, should Slide IC fail to cure the violations set forth in this Civil Remedy Notice within the given cure period. In order to cure the defects outlined in this Civil Remedy Notice, Slide IC must act as follows: immediately deliver payment of all insurance proceeds due and owing to the insured which would reasonably place the Subject Property back in its pre-loss condition or, alternatively, if appraisal is been requested, complete the appraisal process and deliver payment of the executed award; and keep the claim open for the adjustment of any supplemental claim and payment of any as of yet unincurred costs. If Slide IC disagrees with the extent of the cure requested or asserts that the payment of any of the above cure categories may not be required, Slide IC should cure to the extent it believes it must under the Subject Policy and governing laws to correct the allegations of bad faith contained herein. While it is not being requested as a cure for the bad faith alleged herein, the insured remains willing to entertain any reasonable counteroffer of settlement.
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lallen@slideinsurance.com 08-23-2024 August 24, 2024 Via E-mail & Posting on DFS Website Forrest Todd Frederick, Esq. Merlin Law Group 4887 Belfort Rd., Suite 200 Jacksonville, FL 32256 ffrederick@merlinlawgroup.com RE: Complainant: Sunil Lalla & Bharti Lalla Insured: Sunil Lalla & Bharti Lalla Claim No: SL22204046 Policy No: SJ30337597 Date of loss: 09/28/22 CRN Filing No.: 769954 Dear Mr. Frederick: Please allow this correspondence to serve as Slide Insurance Company’s (“Slide”)’s response to the Civil Remedy Notice (“CRN”) that was filed on behalf of Sunil Lalla and Bharti Lalla (“Insured”). Herein, we include a brief factual history of the underlying claim and actions by Slide which reveals it has acted properly in responding to the underlying claim and in compliance with its contractual and legal obligations. Slide denies each and every allegation brought forth in the CRN and denies any wrongdoing in the handling of the underlying claim. Additionally, Slide denies violating any Florida Statute or Administrative Code as set forth more specifically herein. Moreover, Slide denies violating any provisions or duties set forth in the applicable policy of insurance. Slide further states that the facts and circumstances that are set forth in the CRN, while incomplete and misleading, do not give rise to any violation of any statute or policy provision referenced in the Notice. Furthermore, Slide challenges the validity of the CRN for lacking specificity. See, e.g., Julien v. United Prop. & Cas. Ins. Co., 311 So.3d 875, 879 (Fla. 4th DCA 2021) (affirming dismissal for civil remedy notice’s failure to either strictly, or substantially, comply with statutory specificity requirement); Demase v. State Farm Florida Insurance Company, 351 So.3d 136, 138-39 (Fla. 5th DCA 2022) (holding that the trial court properly determined that a civil remedy notice that failed to state with specificity the relevant policy language was legally insufficient). Finally, the CRN is improper as the Insureds failed to establish that Slide breached the policy of insurance, as required by Fla. Stat. § 624.1551. CLAIM FACTS The underlying claim was reported on September 28, 2022, as a claim for damages related to Hurricane Ian with a DOL of September 28, 2022. On October 7, 2022, Slide promptly sent Independent Field Adjuster Craig Halye to inspect the insured property. Coverage was provided for the non-flood damaged portion of the property and outlined in a letter to Insureds dated December 7, 2022. Following receipt of Insureds’ estimate of repairs the risk was reinspected on April 5, 2023, by Zach Marston, an Independent Field Adjuster on behalf of Slide. Based on this reinspection a supplemental payment was issued to Insureds on April 20, 2023, pursuant to the Policy’s unambiguous terms, conditions, endorsements, limitations, and exclusions. Thus, Slide maintains that it has acted in accordance with the terms of the subject insurance Policy, and the law, and has acted in good faith towards the Insureds. Slide denies that it violated any statutes or committed the acts asserted in the CRN. Slide neither waives nor is estopped from asserting any and all rights that it may have in law or under the terms of the policy. Slide expressly reserves all such rights without exception or limitation. REASON FOR THE NOTICE The CRN alleges the following reasons for the filing of the Notice. However, no specific facts or circumstances are provided to support these allegations. Notwithstanding, Slide denies the allegations as follows: 1. Claim Denial: This allegation is without basis and therefore denied. Slide acted in accordance with its duties and obligations pursuant to the policy of insurance as well as Florida law. Accordingly, Slide’s actions are adequately supported by law and fact. Thus, this allegation is without basis and therefore denied. 2. Failure to Properly Investigate the Claim: There is no basis for this allegation, thus it is wholly denied. 3. Claim Delay: Slide denies any delay in the claims handling process of the underlying loss as is evident from the facts outlined above. Slide promptly acknowledged the claim and timely initiated its investigation of the loss including a prompt inspection of the subject property. Slide acted in accordance with its duties and obligations pursuant to the policy of insurance. Thus, Slide asserts that this allegation is without basis and therefore denied. 4. Unsatisfactory Settlement Offer: Slide denies that it extended any unsatisfactory settlement offers to the Insured. Slide asserts that it has acted in good faith towards its Insured at all times. Thus, this allegation is without basis and therefore denied. 5. Unfair Trade Practice: There is no basis for this allegation, thus it is wholly denied. The Insured has submitted no facts or circumstances to support this allegation. The handling and administration of this claim occurred with the expediency and timeliness allowed by the statutory requirements imposed upon Slide. At no time did Slide, its agents, or its employees delay the handling, administration, or disposition of this claim. The facts show that Slide acted promptly with respect to the investigation of the underlying claim and made communications as necessary to adjust the claim in a prompt and appropriate matter. Information necessary and relevant to the proceeding of the claim, were communicated to the Insured or his representatives in an appropriate manner. Thus, this allegation is without basis and therefore denied. ALLEGED STATUTORY VIOLATIONS The CRN alleges multiple statutory violations. However, no specific facts or circumstances are provided to support these allegations. Notwithstanding, Slide denies each and every allegation of statutory violation individually as follows: 1. 624.155(1)(b)(1): Denied. The underlying claim was investigated and adjusted in as thorough and expedient a manner as possible. Moreover, the Insured has submitted absolutely no facts or circumstances supporting this allegation. 2. 624.155(1)(b)(2): Denied. Accordingly, Slide asserts its full and strict compliance with the statutory requirements imposed upon it.? Moreover, the Insured has submitted absolutely no facts or circumstances supporting this allegation. 3. 624.155(1)(b)(3): Denied. Slide has not failed to promptly settle the underlying claim. The underlying claim was investigated and adjusted in as thorough and expedient a manner as possible.?Following the investigation and evaluation of the underlying claim, the Insured was notified that there is no coverage for the alleged loss pursuant to the Policy’s terms, conditions, endorsements, limitations, and exclusions. Accordingly, Slide asserts its full and strict compliance with the statutory requirements imposed upon it.? Moreover, the Insured has submitted absolutely no facts or circumstances supporting this allegation. 4. 626.9541(1)(i)(2): Denied. Slide has not made any material misrepresentations to the Insured or any other person having an interest in the proceeds payable under the subject policy for insurance. The underlying claim has been investigated and adjusted in as thorough and expedient a manner as possible. Slide routinely communicated relevant information to the Insured and/or their representatives. Thus, any such allegation is without merit and unsupported by the facts of the underlying claim. Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Finally, the Insured has submitted absolutely no facts or circumstances supporting this allegation. 5. 626.9541(1)(i)(3)(a): Denied. This allegation is without basis. Slide has adopted and implemented standards for the proper investigation of claims at all times during the investigation of the subject matter. The aforementioned facts demonstrate that Slide employed proper and customary claims practices in the investigation and adjustment of this claim including, but not limited to, a prompt inspection of the insured property and timely communications with the Insured and/or their representatives. Accordingly, Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Finally, the Insured has submitted absolutely no facts or circumstances supporting this allegation. 6. 626.9541(1)(i)(3)(b): Denied.? This allegation is without basis.? Slide has been forthcoming and truthful regarding the pertinent claim facts and/or insurance policy provisions relating to the reported loss. Slide’s correspondences and communications to the Insured and their representatives proves this fact.? Accordingly, Slide’s asserts its full and strict compliance with the statutory requirements imposed upon it.? Finally, the Insured has submitted absolutely no facts or circumstances supporting this allegation. 7. 626.9541(1)(i)(3)(c): Denied. This allegation is without basis. Slide has consistently acted promptly upon all communications with respect to this claim as previously outlined. Slide has adjusted the underlying loss in as thorough and expedient a manner as possible. Moreover, Slide routinely communicated with the Insured and/or their representatives regarding the underlying claim. Thus, Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Any assertions to the contrary are unsupported by the facts. 8. 626.9541(1)(i)(3)(d): Denied. Slide has not denied the underlying claim without reasonable investigation of the reported loss. As referenced in the factual narrative above, Slide investigated the reported claim and adjusted the loss in as thorough and expedient a manner as possible.? Following the investigation and evaluation of the underlying claim, the Insured was notified that there is no coverage for the alleged loss pursuant to the Policy’s terms, conditions, endorsements, limitations, and exclusions. Accordingly, there is simply no support for this allegation and Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Finally, the Insured has submitted absolutely no facts or circumstances supporting this allegation. 9. 626.9541(1)(i)(3)(e): Denied. This allegation is without basis.? As referenced in the factual narrative above, Slide investigated the reported claim and notified the Insured that there is no coverage for the alleged loss pursuant to the Policy’s terms, conditions, endorsements, limitations, and exclusions. There is simply no support for this allegation and Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Finally, the Insured has submitted absolutely no facts or circumstances supporting this allegation. 10. 626.9541(1)(i)(3)(f): Denied. Slide did not fail to provide an explanation for its denial of the claim. Slide has conducted a reasonable investigation of the reported loss as referenced in the factual narrative above. Thus, there is simply no support for this allegation and Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Finally, the Insured has submitted absolutely no facts or circumstances supporting this allegation. 11. 626.9541(1)(i)(3)(g): Denied.? This allegation is without basis.? Slide promptly notified the Insured and/or their representatives regarding the pertinent claim facts and information needed relating to the claim. Slide’s numerous communications prove this fact.? Accordingly, Slide asserts its full and strict compliance with the statutory requirements imposed upon it.? Finally, the Insured has submitted absolutely no facts or circumstances supporting this allegation. 12. 626.9541(1)(i)(3)(h): Denied.? This allegation is without basis.? Slide clearly and promptly notified the Insured and/or their representatives regarding the pertinent claim facts and specific information needed relating to the claim. Slide’s numerous communications to the insureds and her representatives prove this fact.? Moreover, Slide asserts its full and strict compliance with the statutory requirements imposed upon it.? Finally, the Insured has submitted absolutely no facts or circumstances supporting this allegation. 13. 626.9541(1)(i)(3)(i): Denied. Slide denies any unfair claim settlement practices. Slide has acted fairly and honestly towards the Insured.? The underlying claim was investigated and adjusted in as thorough and expedient a manner as possible.?Following the investigation and evaluation of the underlying claim, the Insured was notified that there is no coverage for the alleged loss pursuant to the Policy’s terms, conditions, endorsements, limitations, and exclusions. Thus, Slide asserts its full and strict compliance with the statutory requirements imposed upon it. Finally, the Insured has submitted absolutely no facts or circumstances supporting this allegation. ALLEGED FLORIDA ADMINISTRATIVE CODE VIOLATIONS The CRN alleges multiple violations of the Florida Administrative Code. However, no specific facts or circumstances are provided to support these allegations. Notwithstanding, Slide denies each and every allegation of violating the Florida Administrative Code individually as follows: 1. 69B-220.201(3): Denied. Slide’s adjusters have at all times acted fairly and honestly towards the Insured in the adjustment of the underlying claim. Slide asserts its full and strict compliance with the requirements of this section of the administrative code. The Insured’s assertions to the contrary are unsupported by the facts. 2. 69B-220.201(3)(b): Denied. Slide’s adjusters have at all times acted fairly and honestly towards the Insured in the adjustment of the underlying claim, treating all claimants equally. Slide asserts its full and strict compliance with the requirements of this section of the administrative code. The Insured’s assertions to the contrary are unsupported by the facts. 3. 69B-220.201(3)(b)2. Denied. Slide asserts its full and strict compliance with the requirements of this section of the administrative code. Slide adjusted this claim strictly in accordance with the insurance contract. The Insured’s assertions to the contrary are unsupported by the facts. 4. 69B-220.201(3)(c): Denied. Slide’s adjusters have at all times acted fairly and honestly towards the Insured in the adjustment of the underlying claim, treating all claimants equally. Slide asserts its full and strict compliance with the requirements of this section of the administrative code. The Insured’s assertions to the contrary are unsupported by the facts. 5. 69B-220.201(3)(d): Denied. Slide’s adjusters have at all times acted fairly and honestly towards the Insured in the adjustment of the underlying claim. Slide asserts its full and strict compliance with the requirements of this section of the administrative code. The Insured’s assertions to the contrary are unsupported by the facts. 6. 69B-220.201(3)(e): Denied. Slide’s adjusters have at all times acted fairly and honestly towards the Insured in the adjustment of the underlying claim. Slide asserts its full and strict compliance with the requirements of this section of the administrative code. The Insured’s assertions to the contrary are unsupported by the facts. 7. 69B-220.201(3)(f): Denied. Slide’s adjusters have at all times acted fairly and honestly towards the Insured in the adjustment of the underlying claim. Slide’s adjusters have also acted with due diligence in achieving a proper disposition of the claim. Slide asserts its full and strict compliance with the requirements of this section of the administrative code. The Insured’s assertions to the contrary are unsupported by the facts. 8. 69B-220.201(3)(o): Denied. Slide does not understand the basis for this alleged violation, as its adjusters are competent and knowledgeable as to the terms and conditions of the operative insurance policy. Slide asserts its full and strict compliance with the requirements of this section of the administrative code. The Insured’s assertions to the contrary are unsupported by the facts. ALLEGED VIOLATIONS OF THE INSURANCE POLICY The CRN fails to allege specific violations of the insurance policy and provides no specific facts or circumstances of wrongdoing. The boilerplate CRN merely sets forth blanket allegations of wrongdoing, without further information. As such, the CRN is defective, as it failed to specifically identify the policy language that is the subject of the alleged violation, and further failed to include sufficient facts to put Slide on notice of the alleged violations. Notwithstanding, Slide denies any and all allegations of policy violations. All actions by Slide were done in compliance with the applicable Policy. As indicated above, Slide thoroughly investigated the reported loss including inspection of the Insured’s property. Thus, it is clear that Slide has acted in compliance with the Policy. Slide asserts that it has at all times complied with the terms of the Policy and has complied with all applicable provisions of the Policy and Florida Statutes in the handling of this matter. STATEMENTS AS TO CURING THE DEFECTS OUTLINED IN THE NOTICE The CRN asserts that Slide must tender all insurance benefits due and owing. Nevertheless, the method for curing violations alleged in a Civil Remedy Notice is not determined by the Insured. Talat Enterprises, Inc. v. Aetna Casualty Surety Co., 753 So. 2d So. 2d 1278 (Fla. 2000). Accordingly, Florida Statutes Section 624.155 does not impose on an insurer the obligation to pay whatever the Insured demands. Section 624.155(2)(d) would have no effect or purpose under such an interpretation. Thus, Slide reasserts that it has acted in good faith towards its Insured at all times. Slide references to all the facts herein, which unequivocally demonstrate Slide’s expedient and timely administration of the Insured’s claim. Slide further asserts its full and strict compliance with the Policy and reiterates that it has acted properly in responding to the underlying claim in compliance with its contractual and legal obligations. Slide denies any wrongdoing in the handling of the underlying claim. Additionally, Slide denies violating any Florida Statute, Administrative Code, or code of ethics. CONCLUSION In conclusion, the documented facts of this claim establish that Slide acted diligently in its claims response and adequately performed its obligations under the policy of insurance and Florida law. Thus, the facts contradict all allegations that Slide has in any manner acted improperly or contrary to its contractual obligations to the Insured in this claim. Herein, Slide has attempted to fully and adequately respond to the allegations the Insureds allege in the Civil Remedy Notice of Insurer Violation filed with the Department. Should there be any questions or further inquiry with respect to this matter, please contact the undersigned at (813) 699-5721 or at lallen@slideinsurance.com. Sincerely, /s/ Latoya P. Allen LATOYA P. ALLEN, Esq. Staff Counsel
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