Jury Demand in Pasquale Barrasso Plaintiff vs. Tower Hill Signature Insurance Company Defendant| Trellis.Law

On October 19, 2020 a Jury Demand was filed involving a dispute between Barrasso, Pasquale, and Tower Hill Signature Insurance Company, for 3 in the District Court of Broward County.

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Case Number: CACE-20-017334 Division: 02
Filing # 115218337 E-Filed 10/19/2020 04:47:39 PM

IN THE CIRCUIT COURT OF THE 17"
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA

PASQUALE BARRASSO, CASE NO.:

Plaintiff,
Vv.

TOWER HILL SIGNATURE
INSURANCE COMPANY,

Defendant.
/

PLAINTIFF’S COMPLAINT FOR BREACH OF CONTRACT &
DEMAND FOR JURY TRIAL

COMES NOW Plaintiff, PASQUALE BARRASSO, through the undersigned counsel, and

hereby files this Complaint against Defendant, TOWER HILL SIGNATURE INSURANCE

COMPANY, and as grounds therefore states as follows:

1 This is an action for damages in excess of THIRTY THOUSAND DOLLARS

($30,000.00), exclusive of interest, attorneys’ fees and costs, and is otherwise within the

jurisdictional limits of this Court.

2. At all times material hereto, Defendant was an insurance company authorized to do

business in the State of Florida and doing business in Broward County, Florida.

3 At all times material hereto, the damaged property was located in Broward County,

Florida.

4 Prior to Hurricane Irma, the Plaintiff sought and purchased homeowner’s insurance

from Defendant to cover the property located at 4122 Oxbow Drive, Coconut Creek, Florida 33073

(hereinafter “Insured Property”). Said policy of insurance, which is believed to be Policy Number

Page 1 of 4

#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/19/2020 04:47:36 PM.**#**
P000963092, was issued by Defendant to the Plaintiff to provide property insurance coverage for

the Insured Property.

5 At all times material hereto, the Plaintiff and Defendant had a policy of insurance,

Policy No. P000963092 (hereinafter “Contract”). A copy of The Contract is attached hereto and

incorporated herein by reference as “Exhibit A”.

6. The Plaintiff has paid the premiums for the Contract prior to Hurricane Irma.

7 The Insured Property sustained direct physical damage as a result of Hurricane

Irma.

8 The Contract was in full force and effect as of September 9, 2017.

9 Defendant received timely notice of the loss.

10. Defendant assigned the loss reported by the Plaintiff a claim number believed to be

3300347936.

11. Defendant and its agents requested and were given access and the opportunity to

inspect the Insured Property and the reported damage arising from the loss.

12. Defendant has failed to issue any payments for the damages to the Insured Property

as Defendant represented the damages to be below the policy deductible.

13. This is an action relating to Defendant’s breach of Contract for its failure to

properly pay the full amount of insurance proceeds owed to the Plaintiff.

14. Jurisdiction and venue of this matter are proper in the Circuit Court for Broward

County, Florida.

COUNT I- BREACH OF CONTRACT

15. The Plaintiff realleges and reincorporates paragraphs 1-14 as if fully stated herein,

and further alleges as follows:

Page 2 of 4
16. During the above Contract period the Insured Property sustained direct physical

damages as a result of Hurricane Irma.

17. The Plaintiff provided notice of the loss the Defendant.

18. Prior to the initiation of this lawsuit, Defendant has acknowledged coverage under

the Contract for part of the damages referenced herein, and has refused or otherwise failed to issue

full payment to the Plaintiffs for the physical damages to the Insured Property sustained during the

Contract period, as Defendant wrongfully represented the damages to the Insured Property to be

below the Contract’s deductible.

19. The Plaintiffs have complied with all obligations and conditions precedent to this

lawsuit which would entitle the Plaintiff to recover benefits under the Contract, or such conditions

have been waived.

20. The Defendant has failed to provide complete coverage for the physical damages

that occurred during the Contract period.

21. This failure is contrary to the terms of the Contract and constitutes a breach of the

Contract.

22. The Plaintiff has been damaged by this breach in the form of unpaid insurance

proceeds needed to restore the Insured Property to its pre-loss condition as a result of the Defendant

refusing to pay the full amount owed under the Contract.

23. As a direct and proximate result of Defendant’s breach of Contract, the Plaintiffs

has been required to retain the services of the undersigned attorneys to represent and protect the

interests of the Plaintiff and the Plaintiff has become obligated to pay them a reasonable fee for

their services in bringing this action.

Page 3 of 4
24. In the event that the Plaintiff prevails in this action, Plaintiff is entitled to an award

of attorneys’ fees and costs pursuant to section 627.428, 626.9373 and 57.041, Florida Statutes

and/or other Florida Law.

WHEREFORE, the Plaintiff demands judgment against Defendant for damages, including

but not limited to damages owed under the Contract, attorneys’ fees and costs.

DEMAND FOR JURY TRIAL

The Plaintiff further demands a trial by jury of all issues so triable as a matter of right.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a certified copy of the foregoing has been served on Defendant.

KANNER & PINTALUGA, P.A.
Attorneys for Plaintiff
925 S. Federal Highway, Sixth Floor
Boca Raton, FL 33432
Phone: (561) 424-0032
Fax: (561) 853-2188
Court Phone Number: (1-888) 824-7834
Email: aaltman@kpattorney.com
alexandre@kpattorney.com
FirstPartyEService@kpattorney.com

By:_/s/ Alexis Altman
MAX M. MESSINGER, ESQ.
Florida Bar No.: 69988
ALEXIS ALTMAN, ESQ.
Florida Bar No.: 0105040

Page 4 of 4
Exhibit "A"

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Tower Hill
Insurance

Your Homeowners Insurance Policy
This page is intentionally left blank
iy |

a
Tower Hill
Insurance
Dear PASQUALE BARRASSO,
Your Policy Number:
P000963092
Thank you for renewing your policy with Tower Hill Insurance Group
You are a valued member of a growing community of more than
Insurance Company:
Tower Hill Signature
350,000 Florida homeowners who trust Tower Hill’s Family of
Companies to protect their homes. Policy Effective Date:
December 31, 2016
Since 1972, Tower Hill has weathered every Florida storm and been
there when our customers need us the most — when it’s time to Your Insurance Agency:
rebuild. We appreciate your business, and assure you that our DTRT Insurance Group Inc
employees, in partnership with your insurance agent, will work
(888) 946-3305
Agency Code: FL1636
tirelessly to deserve the trust you have placed in us.
Your renewal offer contains
To Protect Your Castle, Look to the Tower.
important information about
deductible options that may
Tower Hill Insurance Group, LLC help reduce your premium.

Please contact your insurance
agent to discuss these options,
or with any coverage
questions.

How to Contact Tower Hill
CALL Our Customer Service Center at 800.342.3407
Monday - Friday, 8:00 a.m. to 6:00 p.m. (ET)
+ Find out about available payment plans or receive help with billing
questions

O
+ Pay by phone (American Express, Discover, MasterCard, Visa, or
from your bank account)
Save the
Visit Us ONLINE at THIG.com
Trees
Register at Customer Login to:
. View your Tower Hill policy documents Manage your Tower Hill policy
. Review your account balance documents and payments
Make an online payment online at THIG.com.
. Go paperless
GO PAPERLESS.
Report a CLAIM
* Call our 24-hour hotline at 800.216.3711 as soon as possible after Why choose paperless?
a loss occurs.
e Convenience. All policy
Reach Us by MAIL and payment documents
+ If you pay your bill by mail, please use the payment coupon and will be stored in one place,
envelope included with your invoice. securely online.
+ Write the policy number in the memo field of your check. If you are
sending a money order or cashier's check, include your name as it e Go Green. Reducing
is listed on your policy. paper use is good for the
+ Mail payments to Tower Hill Insurance Group, PO Box 865001, environment.
Orlando, FL 32886-5001.
+ To send other correspondence regarding your policy, please mail
to PO Box 147018, Gainesville, FL 32614-7018.

Tower Hill Insurance | PO Box 147018, Gainesville, FL 32614 | customerservice@thig.com | THIG.com
IMPORTANT INFORMATION ABOUT YOUR POLICY PREMIUM

Your renewal premium amount reflects the following
changes:
Want more
covera for
your
+ Changes made by you and your agent prior to or during the
renewal process (if applicable);
premium dollars? + Any recent rate changes implemented by your insurance
company;
Ask your agent about our
broadened coverage options
with Emerald or Emerald You may be able to reduce your policy premium
Deluxe. The Emerald options if you qualify for additional discounts or credits including:
provide additional coverage,
including personal property + Protective device credit (such as eligible alarm and sprinkler
replacement cost, increased systems);
personal liability, personal injury + Sinkhole Loss Coverage exclusion.
protection - and more.

You can also reduce your policy premium by changing
deductibles.
Get extra protection

}
for Deductible credits depend on your Coverage A (Dwelling
you rmost
Structure Coverage) amount, your current deductible and your
valuable home’s location.
property.
For example, an Orange County home with Coverage A equal to
The Scheduled Personal $200,000, with a $1,000 All Other Perils deductible and 2%
Property Endorsement Hurricane deductible could save 2.5% by changing to a
provides coverage for certain $1,000/5% deductible. For this home you could save as much as
categories such as jewelry, 14% by switching to a $2,500/5% deductible.
silverware, golf equipment,
coin collections, or fine art at Selecting a higher deductible option will result in a premium
higher limits than your base credit; however, in the event of a covered loss, you will be
policy allows. responsible for higher out-of-pocket expenses. Conversely,
selecting a lower deductible will result in a higher premium,
though your out-of-pocket expenses would be lower in the event
of a covered loss.
Receive a 2.5%
premium discount ng Hurricane deductible changes can only be made at your policy
renewal. All Other Perils (AOP) deductible changes can be
made during the policy term. Please contact your agent for details
when you buy your flood on other conditions that may apply.
policy through a Tower Hill
company. Please note that Be sure to discuss these options with your insurance agent, who
your homeowners policy does can help you decide which one best suits your individual situation.
NOT include flood coverage.
To learn more, contact your Your agent will be able to request changes on your behalf.
insurance agent today!

Tower Hill Insurance | P.O. Box 147018, Gainesville, FL 32614 | customerservice@thig.com | THIG.com
fs) Tower Hill
. Insurance

NOTICE OF CHANGE IN POLICY TERMS
IMPORTANT NOTICE — PLEASE READ CAREFULLY

The purpose of this Notice of Change in Policy Terms is to inform you of changes to the terms, coverages, duties
and/or conditions of your renewal policy as described below:
The following provisions in the Special Provision — Florida Endorsement have changed:
DEFINITIONS
The definition for unoccupied has been revised and the definition for Replacement Cost has been added to
your policy:
“Unoccupied” means the dwelling is not being inhabited as a residence.
“Replacement Cost” means the reasonable and customary cost, including labor and material costs, as
determined by “us” to repair or replace the damaged property, or any of its parts, with material of like kind
and quality, not subject to a deduction for deterioration, depreciation and obsolescence.
SECTION | - ADDITIONAL COVERAGES
. Reasonable Repairs has been revised to include that we, your insurance company, will pay for
measures taken to repair other damaged property only if that property is covered under this policy
and the damage to that property is caused by a Peril Insured Against. This does not increase the limit
of liability or relieve you of your duties as set forth in the policy.
SECTION I - PERILS INSURED AGAINST COVERAGE A and COVERAGE B.
. The following is not a covered cause of loss: birds, vermin, rodents, marsupials, animals, reptiles,
fish, insects, or pests, including but not limited to, termites, snails, raccoons, opossums, armadillos,
flies, bed bugs, lice, ticks, locusts, cockroaches, and fleas.
. Dropped objects to the interior of a building are not covered unless the roof or an outside wall of the
building is first damaged. Damage to the dropped object is not covered.
SECTION I - EXCLUSIONS
. Your policy will now include an exclusion for Assignee(s) or Third Parties that states we will not be
responsible for any payments to any assignees or third parties for payments of losses that are not
covered under this policy.
SECTION | - CONDITIONS
. Under Duties After Loss, your policy now includes the requirement that to the degree reasonably
possible, you must allow us to inspect all damaged property prior to its removal from the insured
location.
Under Duties After Loss, your policy now includes the requirement to allow us to re-inspect the
property to confirm repairs invoiced by assignees or third parties were completed or following a
supplemental claim or re-opened claim.
Under Mediation or Appraisal, your policy now includes the requirement that if you and we fail to
agree on a settlement, scope of repair, or method of repair regarding the loss, you must notify us of
your disagreement in writing prior to filing a suit.
Under Suit Against Us, your policy now includes the requirement that if you and we fail to agree on a
settlement, scope of repair, or method of repair regarding the loss, you must notify us of your
disagreement in writing prior to filing a suit.
Under Our Option, the options which we, as your insurance company, have when settling a claim
have been expanded.
Under Mortgage Clause, the word “mortgagee” includes a trustee that holds a mortgage.
. The Venue Condition’s section title was revised to Choice of Law.
. Under Salvage, you now may request to keep the damaged insured property.
SECTION II - CONDITIONS
. The Venue Condition’s section title was revised to Choice of Law.
SECTION | AND II —- CONDITIONS
. Under Concealment or Fraud, your policy now includes a provision that we, as your insurance
company, may not provide coverage when one or more insured(s) has made a material false
statement.

NOCPT (10/12) Page 1
Under Concealment and Fraud, your policy now includes a provision that we, as your insurance
company, may not deny a claim filed by you based on credit information available in public records if
the policy is in effect for more than 90 days.
Under Cancellation and Nonrenewal, we will now provide 120 days’ notice of cancellation or
nonrenewal for all policyholders. The delivery or mailing of notice of cancellation will be provided to
the first-named insured shown in the Declarations.
Under Cancellation and Nonrenewal, your policy now includes a provision that we, as your insurance
company, may not cancel or nonrenew your policy based on credit information available in public
records or the lawful use, possession or ownership of a firearm.
The following provisions in the Sinkhole Loss Coverage Endorsement have changed:
DEFINITIONS
. Under the definition for Neutral Evaluator we have added language clarify license requirements for a
professional engineer.
Under the definition for Professional Engineer we have revised the language to clarify that the
professional engineer must have experience and expertise in the identification of sinkhole activity or
other potential causes of structural damage.
Under the definition for Principal Building we have added language to include that decks are covered
if it is an extension of the foundation and made of the same material and/or under the same roof line
of the principal building.
NEUTRAL EVALUATION
. We have added a requirement that a claim for sinkhole loss coverage must be filed within 2 years
after you knew or reasonably should have known about the loss.
We have clarified that you or we may file a request with the Department for neutral evaluation and
that the other party must comply with the request.
We have clarified that we will pay the reasonable cost associated with the neutral evaluation.
However, if a party chooses to hire a court reporter or stenographer to record and document the
neutral evaluation, that party shall bear such costs.
. We have also clarified that the recommendation of the neutral evaluator will not be binding on you or
us.
SECTION I - CONDITIONS
. Under Loss Settlement, your policy now includes a provision that states that we must inform you in
writing of your potential liability for reimbursement and give you an opportunity to withdraw the claim
for a sinkhole claim submitted without good faith grounds.
A Suit Against Us provision was added to clarify that no action can be brought against us unless there
has been full compliance, any report, investigation or findings regarding a sinkhole loss on property
insured are provided to us at least 60 days prior to filing any suit, and the action is started within 5
years after the dates of the loss.
The descriptions in this notice are intended to be for informational purposes only. Please review your policy and
endorsement language carefully. In the event of a conflict, the language in your policy and its endorsements will
be controlling.
To accept the renewal offer, simply pay the renewal premium as provided in the accompanying notice. If
applicable, your mortgage company will receive the renewal offer and make payment on your behalf. Our receipt
of the premium payment for the renewal policy is deemed to be your acceptance of the new policy terms.
If you have any questions concerning this notice or any other policy matter, please contact your insurance agent
for assistance.
Thank you for choosing Tower Hill for your home insurance needs. We appreciate your business.
Tower Hill Insurance Group, LLC

ce: policyholder file

NOCPT (10/12) Page 2
Tower Hill Si ature
Insurance mpany
l@ P.O. Box 147018 Gainesville, FL 32614-7018

Ee HOMEOWNERS
DECLARATIONS
POLICY NUMBER
P000963092
THIS IS NOTA BILL. Renewal
Payment notice will be sent separately Issued On:
to: Mortgagee 11/05/2016

Insured AGENCY FL1636
PASQUALE BARRASSO. DTRT Insurance Group Inc
4122 OXBOW DR 2265B WEST HILLSBORO BLVD
COCONUT CREEK, FL 33073-5116 DEERFIELD BEACH, FL 33442
PHONE NUMBER: (888) 946-3305

POLICY PERIOD: 12/31/2016 to 12/31/2017. Each period begins and ends at 12:01 AM standard time at the insured location.
INSURED LOCATION: 4122 OXBOW DR
COCONUT CREEK, FL 33073-5116
Coverage is provided where a premium or limit is shown for the coverage.
SECTION | - PROPERTY COVERAGE LIMIT SECTION II - LIABILITY COVERAGE LIMIT
COVERAGE A - Dwelling $278,000 COVERAGE E - Personal Liability $300,000
COVERAGE B - Other Structures $27,800 Each Occurrence
COVERAGE C - Personal Property $139,000 COVERAGE F - Medical Payments to Others $5,000
COVERAGE D - Loss of Use $55,600 Each Person

BREAKDOWN OF PREMIUM:
Charge: Limit Premium
Section | and Il Premium $1,597.00
Catastrophic Ground Cover Collapse Coverage Incl
Covered Porch Surcharge Incl
Limited Fungi, Wet or Dry Rot, or Bacteria Coverage $10,000/$10,000 Incl
Loss of Use - Increased Limit Incl
Ordinance or Law Coverage 25% $318.00
Personal Property Replacement Cost without Holdback $953.00
Sinkhole Loss Coverage - 10% Sinkhole Deductible $14.00
Unscheduled Other Structures - Increased Limit Incl
Emergency Management Preparedness and Assistance Trust Fund (EMPAT) Fee $2.00
Managing General Agency (MGA) Fee $25.00

Credits Premium
All Other Perils Deductible Credit Incl
Building Code Effectiveness Grading Schedule (BCEGS) Credit Incl
Hurricane Deductible Credit Incl
Loss Free Credi Incl
New Home Discount Incl
Protective Devices Credit Incl
Residential Windstorm Loss Mitigation Devices Credit Incl

Total Policy Premium: $2,909.00

DEDUCTIBLE (Section | Only):
The Calendar Year Hurricane Deductible is $5,560 (2% of Coverage A).
The Sinkhole Loss Deductible is $27,800 (10% of Coverage A).
The All Other Perils Deductible is $2,500.

- In case of loss under Section |, we cover only that part of the covered loss over the deductible stated.

RP-HO-DEC (08/12) Page: 1
POLICY NUMBER
P000963092

Mortgagee Information:
CC: OCWEN LOAN SERVICING, LLC
ITS SUCCESSORS &/OR ASSIGNS
PO BOX 6723
SPRINGFIELD, OH 45501
Loan Id: 7143589237

Important: Please notify your agent immediately if the mortgage company shown is incorrect.

BASIC RATING INFORMATION:

CONSTRUCTION CONSTRUCTION
PROGRAM FORM CODE TERRITORY COUNTY
YEAR TYPE

RPFLHO- HO-3 350 BROWARD 2001 Masonry

FIRE PROTECTION BUILDING CODE WIND PROTECTIVE
ROOF TYPE PROTECTIVE DEVICE
CLASS (BCEG) GRADE DEVICE

4 4 Central Station Burglar Alarm
Hip Class A (All Openings) Central Station Fire Alarm

PREMIUM SUMMARY: Hurricane Premium: $1,558.00
Non-hurricane Premium: $1,351.00

APPLICABLE FORMS AND ENDORSEMENTS:
RPIC HO 09 COV (04/09), HO 00 03 (04/91), HO 04 16 (04/91), HO 04 21 (10/94), HO 04 96 (04/91), HP-0477-00 (01/09),
1L-0001 (11/01), IL-0010 (02/11), IL-0301-00 (09/11), IL-0503-00 (10/13), IL-P-001 (01/04), IL-WMCA (04/11), Privacy Notice
(05/13), RP-CKLS HO (06/11), RPI HO 09 04 90 (03/11), RPI HO 09 2370 (03/08), RPI HO 09 DN (09/06), RPI HO 09 ED
(12/08), RPI HO 09 ELE (02/10), RPI HO 09 FCE (10/13), RPI HO 09 HD (01/06), RPI HO 09 OTL (06/11), RPI HO 09 SLD
(01/16), RPI HO 09 SP (01/16)
NOTICES:
. This policy does not provide Animal Liability coverage.
. This policy does not provide Flood coverage.
. Your Building Code Effectiveness Grading schedule adjustment is -6%. The adjustments can range from a surcharge of
1% to a discount of -12%.
This Declarations replaces all previously issued policy Declarations, if any. This Declarations together with your policy
and endorsements completes your policy. Refer to your policy and endorsements for details regarding your coverages,
limits, and exclusions.
To request the complete copy of your policy including all forms, endorsements, terms and conditions, please contact
our Customer Service Center at (800) 342-3407 between the hours of 8:00 am and 6:00 pm, Monday through Friday
(Eastern Time), excluding holidays.

RENEWAL NOTICES:
. Premium change due to coverage change $93.00.
. Premium change due to rate increase/decrease $0.00.

THIS POLICY CONTAINS A SEPARATE DEDUCTIBLE FOR
HURRICANE LOSSES, WHICH MAY RESULT IN HIGH
OUT-OF-POCKET EXPENSES TO YOU.

RP-HO-DEC (08/12) Page: 2
POLICY NUMBER
P000963092

ee THIS POLICY CONTAINS A SEPARATE DEDUCTIBLE FOR
SINKHOLE LOSSES, WHICH MAY RESULT IN HIGH
OUT-OF-POCKET EXPENSES TO YOU.

LAW AND ORDINANCE COVERAGE IS AN IMPORTANT
COVERAGE THAT YOU MAY WISH TO PURCHASE. YOU
MAY ALSO NEED TO CONSIDER THE PURCHASE OF
FLOOD INSURANCE FROM THE NATIONAL FLOOD
INSURANCE PROGRAM. WITHOUT THIS COVERAGE, YOU
MAY HAVE UNCOVERED LOSSES. PLEASE DISCUSS
THESE COVERAGES WITH YOUR INSURANCE AGENT.

Lg cette —
COUNTERSIGNATURE:
Countersigned by Authorized Representative: Stephen E. Allnutt Prepared: 11/05/2016

AGENCY PHONE: (888) 946-3305
CUSTOMER SERVICE: (800) 342-3407
QUESTIONS: If you have questions about your insurance policy or coverages, please contact your agent.
If you have payment or billing questions, please call the Customer Service number or contact your
agent.
TO FILE A CLAIM: Tower Hill Insurance Services, LLC PHONE: (800) 216-3711 (24 hours a day, 7 days a week)
PO Box 143180 FAX: (352) 248-2167
Gainesville, FL 32614-3180
FRAUD HOTLINE: (866) 265-6590 (Toll Free and Confidential)

RP-HO-DEC (08/12) Page: 3
This page is intentionally left blank
IMPORTANT NOTICE

THIS NOTICE FORMS A PART OF YOUR POLICY PLEASE READ IT CAREFULLY

The enclosed renewal will become effective on the effective date provided the premium is paid.
If your premium is to be paid by your mortgagee, they have been billed; otherwise you will receive a
Premium Renewal Notice under separate cover.
NOTE: This renewal will not become effective unless the premium is paid on or before the
effective date.

IL-0001 1101
POLICY NUMBER: HOMEOWNERS
IL-0010 (02/11)
IMPORTANT NOTICE REGARDING YOUR INSURANCE COVERAGE

ORDINANCE OR LAW SELECTION / REJECTION OF
COVERAGE: 0%, 10%, 25% AND 50%
Ordinance or Law coverage provides payment for the increased costs you incur to repair or replace the damage
to your covered structure in compliance with any local, state or federal law, ordinance or regulation affecting
repair or construction of such structures. Refer to the Ordinance or Law provisions in the policy for complete
details and limitations.
You have the option to select Ordinance or Law coverage limits of 10%, 5% or 50% of the Coverage A limit of
liability that displays on your Declarations, or you may reject Ordinance or Law Coverage from your policy.
In the event that you don’t make an affirmative selection of coverage, your Ordinance or Law Coverage limit will
equal what is already included in your policy.
PLEASE SIGN FOR ONE OF THE FOLLOWING OPTIONS
Option One: 0% Ordinance or Law Coverage
| wish to reject the Ordinance or Law coverage, and | do not wish to select the higher limits of
10%, 25% or 50%.

Signature of Named Insured Date Signed
oo nnn nnn nnn nnn nnn OR enn
Option Two: 10% Ordinance or Law Coverage
| wish to select the 10% Ordinance or Law coverage limit, and | do not wish to select the higher
limits of 25% or 50% or the lower limit of 0%.

Signature of Named Insured Date Signed
aoa === 8 === === === === === === -- OR ao---- 8-8 - === === === ===.
Option Three: 25% Ordinance or Law Coverage
| wish to select the 25% Ordinance or Law coverage limit, and | do not wish to select the higher
limit of 50% or the lower limits of 0% or 10%.

Signature of Named Insured Date Signed
aoa === 8 === === === === === === -- OR ao---- 8-8 - === === === ===.

Option Four: 50% Ordinance or Law Coverage
| wish to select the 50% Ordinance or Law coverage limit, and | do not wish to select the lower
limits of 0%, 0% or 25%.

Signature of Named Insured Date Signed

For Agent Use Only:
For requests to increase Ordinance or Law coverage to 10%, 25% or 50%, you must first complete the replacement
cost estimator tool through the Rating and Policy Management system, and complete the following information:
Estimated Replacement Cost
Date Completed
When processing an increase in Ordinance or Law coverage, you may need to adjust the Coverage A limit of liability
to match the estimated replacement cost, as necessary.
Retain this page for your records.

IL-0040 (02/11) Page 1 of 1
IL P 001 01 04

U.S. TREASURY DEPARTMENT'S OFFICE OF FOREIGN
ASSETS CONTROL ("OFAC"
ADVISORY NOTICE TO POLICYHOLDERS
No coverage is provided by this Policyholder Notice nor can it be construed to replace any provisions of your
policy. You should read your policy and review your Declarations page for complete information on the coverages
you are provided.
This Notice provides information concerning possible impact on your insurance coverage due to directives issued
by OFAC. Please read this Notice carefully.
The Office of Foreign Assets Control (OFAC) administers and enforces sanctions policy, based on Presidential
declarations of "national emergency". OFAC has identified and listed numerous:
. Foreign agents;
. Front organizations;
. Terrorists;
. Terrorist organizations; and
. Narcotics traffickers;
as "Specially Designated Nationals and Blocked Persons". This list can be located on the United States Treas-
ury's web site — http//www.treas.gov/ofac.
In accordance with OFAC regulations, if it is determined that you or any other insured, or any person or entity
claiming the benefits of this insurance has iolated U.S. sanctions law or is a Specially Designated National and
Blocked Person, as identified by OFAC, this insurance will be considered a blocked or frozen contract and all
provisions of this insurance are immediately subject to OFAC. When an insurance policy is considered to be such
a blocked or frozen contract, no payments nor premium refunds may be made without authorization from OFAC.
Other limitations on the premiums and payments also apply.

*** Important Information ***
About Your Personal Residential Insurance Policy

12/31/2016

Dear Homeowner,

Hurricanes have caused tens of billions of dollars in insured damages and predictions of
more catastrophic hurricanes making landfall in Florida have triggered increases in
insurance premiums to cover potential future losses. Enclosed is information regarding
wind loss mitigation that will make your home more resistant to wind and help protect
your family during a catastrophic event. In addition to reducing your hurricane wind
premium by installing mitigation features, you may also reduce the likelihood of out of
pocket expenses, such as your hurricane deductible, you may otherwise incur after a
catastrophic event.

Sincerely,

TOWER HILL SIGNATURE INSURANCE COMPANY

What factors are considered in establishing my premium?
Your location: The closer a home is to the coast, the more vulnerable it is to damage
caused by hurricane winds. This makes the hurricane-wind premium higher than for
similar homes in other areas of the state.
Your policy: Your insurance policy is divided into two premiums: one for damage caused
by hurricane force winds (hurricane-wind) and one for all other damage (all perils), such
as fire.
Your deductible: Under the law, you are allowed to choose a $500, 2%, 5% or 10%
deductible, depending on the actual value of your home. The larger your deductible, the
lower your hurricane-wind premium. However, if you select a higher deductible your out-
of-pocket expenses in the event of a hurricane claim will be higher.
Improvements to your home: The state requires insurance companies to offer discounts
for protecting your home against damage caused by hurricane winds. Securing your
roof so it doesn’t blow off and protecting your windows from flying debris are the two
most cost effective measures you can take to safeguard your home and reduce your
hurricane —wind premium. These discounts apply only to the hurricane-wind portion of
your policy.
The costs of the improvement projects vary. Homeowners should contact a licensed
contractor for an estimate. You can find a Certified Contractor in your area by visiting
the Florida Department of Business and Professional Regulation online at
www.myfloridalicense.com.
Your maximum discount: Discounts are not calculated cumulatively. The total discount
is not the sum of the individual discounts. Instead, when one discount is applied, other
discounts are reduced until you reach your maximum discount of 88%.

IL-WMCA (04/11) Page 1 of 4
How can | take advantage of the discounts?

Homeowners will need a qualified inspector such as a general, building, or residential
contractor licensed under Section 489.111, Florida Statutes, or a professional engineer
licensed under Section 471.015, Florida Statutes, who has passed the appropriate
equivalency test of the Building Code training program as required by Section 553.841,
Florida Statutes, or a professional architect licensed under Section 481.213, Florida
Statutes, or a building code inspector certified under Section 468.607, to inspect the
home to identify potential mitigation measures and verify improvements. For a listing of
individuals and/or inspection companies meeting these qualifications contact your
insurance agent or insurance company.

The following is an example of how much you can reduce your insurance
premium if you have mitigating features on your home. The example is based on
your hurricane-wind premium* of $3,730.00 which is part of your total annual
premium of __ $2,909.00 _ . Remember, the discounts shown only apply to the
hurricane-wind portion of the premium and the discounts for the construction
techniques and features listed below are not cumulative.

*Wind mitigation credits apply to that portion of your premium that covers the
peril of wind, whether or not a hurricane exists.

Current hurricane loss mitigation features provide your policy with a discount of
84%, or _$3,133.00__.

Homes built prior to the 2001 building code
Estimated* Annual
Description of Feature Estimated* Premium
Premium ($) is
Discount Percent
Reduced by:

Roof Covering (i.e., shingles or tiles)
. Meets the Florida Building Code. ae

. Reinforced Concrete Roof Deck.
(If this feature is installed on your home you
most likely will not qualify for any other 88% $149.00
discount.)

How Your Roof is Attached
ae ae
. Using a 2" nail spaced at 6" from the edge of
the plywood and 12" in the field of the
plywood.

Using a 2 1/2" nail spaced at 6" from the edge ae ae
of the plywood and 12" in the field of the
plywood.

Using a 2 1/2" nail spaced at 6" from the edge ae ae
of the plywood and 6" in the field of the
plywood.

IL-WMCA (04/11) Page 2 of 4
Estimated* Annual
Description of Feature Estimated* Premium
Premium ($) is
Discount Percent
Reduced by:

Roof-to-Wall Connection
. ae ae
Using Toe Nails — defined as three nails
driven at an angle through the rafter and into
the top roof.

Using Clips - defined as pieces of metal that ae ae
are nailed into the side of the rafter/truss and
into the side of the top plate or wall stud.
Using Single Wraps — a single strap that is ae ae
attached to the side and/or bottom of the top
plate and are nailed to the rafter/truss.
Using Double Wraps - straps are attached to ae ae
the side and/or bottom of the top plate and are
nailed to the rafter/truss.

Roof Shap:
. Hip Roof — defined as your roof sloping down ae ae
to meet all your outside walls (like a pyramid).
. Other. ae ae

Secondary Water Resistance (SWR)
. SWR - defined as a layer of protection 87% $112.00
between the shingles and the plywood
underneath that protects the building if the
shingles blow off.
No SWR. ae ae

Shutters
. None. ae ae

Intermediate Type —shutters that are strong
enough to meet half the old Miami-Dade ae ae
building code standards.
Hurricane Protection Type -- shutters that are ae ae
strong enough to meet the current Miami-
Dade building code standards.

* Estimate is based o

Case Info

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Bowman, John B. Track Judge’s New Case

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Jury Demand: Pasquale Barrasso Plaintiff vs. Tower Hill Signature Insurance Company Defendant

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