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Filing # 152050001 E-Filed 06/23/2022 11:34:55 AM
IN THE CIRCUIT COURT FOR THE
TWELFTH JUDICIAL CIRCUIT IN AND
FOR SARASOTA COUNTY, FLORIDA.
CASE NO.
SHAUN WILLIAMS and LISA M.
WILLIAMS
Plaintiffs,
Vv.
TOWER HILL SIGNATURE INSURANCE
COMPANY,
Defendant.
/
COMPLAINT
Plaintiffs, SHAUN WILLIAMS and LISA M. WILLIAMS, by and through undersigned
counsel, hereby sue Defendant, TOWER HILL SIGNATURE INSURANCE COMPANY, and
in support thereof allege as follows:
1. This is an action for an amount in excess of $30,000.00, exclusive of attorney fees,
costs, and interest.
2. At all times material hereto, Plaintiffs were and are residents of Sarasota County,
Florida and sui juris.
3. At all times material hereto, Defendant was and is an insurance company authorized
to and did write homeowners insurance policies within the State of Florida, and specifically within
Sarasota County, Florida.
4 At all times material hereto, Plaintiffs were and are the owners of the property
located at 5345 Talisman Terrace, North Port, FL 34286, Sarasota County.
Filed 06/23/2022 02:01 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL5. At all times material hereto, the subject property was insured under a policy of
insurance issued by Defendant to Plaintiffs, specifically, policy number P010229398. Said policy
is incorporated herein in its entirety pursuant to Fla. R. Civ. P. 1.130; further, Defendant has a
copy of said policy in its possession.
6. At all times material hereto, the policy of insurance was in full force and effect.
7. The policy of insurance provides, in pertinent part, that Defendant provides
coverage for property damage, including contents, rendered to Plaintiffs’ property that is the result
of an accident, whether natural in cause or not, and the policy is required to comply with the
provisions of Florida law.
8. On or about July 10, 2021, Plaintiffs’ property was damaged directly and/or
indirectly by wind and/or water creating an opening in the roofing system.
9. As a result thereof, Plaintiffs sustained damages to the property that required
reasonable, related and/or necessary repairs and replacements, as well as appropriate cleaning and
other remedial measures.
10. _—_— Plaintiffs gave timely notice to Defendant of such loss, and did thereafter deliver to
Defendant a full and particular account of Plaintiffs’ expenses and losses as a result of the loss.
11. Defendant assigned claim number 3300385863 to identify the loss.
12. Defendant has failed to establish that it had reasonable proof that it was not
responsible for the payment of Plaintiffs’ damages and/or loss, and has failed to pay the requested
amounts for repairs and/or replacement, plus applicable interest, pursuant to the terms of the policy
of insurance, in breach of Plaintiffs’ contract with Defendant.
13. All conditions precedent to the filing of this action have been complied with, met,
or otherwise waived.14. Defendant’s conduct has caused Plaintiffs to retain the services of the undersigned
counsel to prosecute this action, and Plaintiffs are entitled to attorney fees and costs pursuant to
Florida law, and specifically pursuant to Section 627.428 and/or Section 626.9373, Florida
Statutes.
WHEREFORE, based on the foregoing, Plaintiffs, SHAUN WILLIAMS and LISA M.
WILLIAMS, demand judgment against Defendant, TOWER HILL SIGNATURE
INSURANCE COMPANY, for damages, interest, attorney fees, costs, and any other such relief
that this Honorable Court deems just and proper.
DEMAND is hereby made for trial by jury of all issues so triable as a matter of right.
DATED this 23 day of June 2022.
MORGAN LAW GROUP, P.A.
55 Merrick Way, Suite 404
Coral Gables, Florida 33134
Phone: (305) 569-9900
Fax: (305)443-6828
e-Service: mlg.eservice@morganlawegroup.net
By: _/s/Philip Rhodes
Thomas J. Morgan, Jr., Esq.
Florida Bar No. 127612
Phillip Rhodes, Esq.
Florida Bar No.: 118395
prhodes@morganlawgroup.net
/m]
Preview
Filing # 152050001 E-Filed 06/23/2022 11:34:55 AM IN THE CIRCUIT COURT FOR THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA. CASE NO. SHAUN WILLIAMS and LISA M. WILLIAMS Plaintiffs, Vv. TOWER HILL SIGNATURE INSURANCE COMPANY, Defendant. / COMPLAINT Plaintiffs, SHAUN WILLIAMS and LISA M. WILLIAMS, by and through undersigned counsel, hereby sue Defendant, TOWER HILL SIGNATURE INSURANCE COMPANY, and in support thereof allege as follows: 1. This is an action for an amount in excess of $30,000.00, exclusive of attorney fees, costs, and interest. 2. At all times material hereto, Plaintiffs were and are residents of Sarasota County, Florida and sui juris. 3. At all times material hereto, Defendant was and is an insurance company authorized to and did write homeowners insurance policies within the State of Florida, and specifically within Sarasota County, Florida. 4 At all times material hereto, Plaintiffs were and are the owners of the property located at 5345 Talisman Terrace, North Port, FL 34286, Sarasota County. Filed 06/23/2022 02:01 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL5. At all times material hereto, the subject property was insured under a policy of insurance issued by Defendant to Plaintiffs, specifically, policy number P010229398. Said policy is incorporated herein in its entirety pursuant to Fla. R. Civ. P. 1.130; further, Defendant has a copy of said policy in its possession. 6. At all times material hereto, the policy of insurance was in full force and effect. 7. The policy of insurance provides, in pertinent part, that Defendant provides coverage for property damage, including contents, rendered to Plaintiffs’ property that is the result of an accident, whether natural in cause or not, and the policy is required to comply with the provisions of Florida law. 8. On or about July 10, 2021, Plaintiffs’ property was damaged directly and/or indirectly by wind and/or water creating an opening in the roofing system. 9. As a result thereof, Plaintiffs sustained damages to the property that required reasonable, related and/or necessary repairs and replacements, as well as appropriate cleaning and other remedial measures. 10. _—_— Plaintiffs gave timely notice to Defendant of such loss, and did thereafter deliver to Defendant a full and particular account of Plaintiffs’ expenses and losses as a result of the loss. 11. Defendant assigned claim number 3300385863 to identify the loss. 12. Defendant has failed to establish that it had reasonable proof that it was not responsible for the payment of Plaintiffs’ damages and/or loss, and has failed to pay the requested amounts for repairs and/or replacement, plus applicable interest, pursuant to the terms of the policy of insurance, in breach of Plaintiffs’ contract with Defendant. 13. All conditions precedent to the filing of this action have been complied with, met, or otherwise waived.14. Defendant’s conduct has caused Plaintiffs to retain the services of the undersigned counsel to prosecute this action, and Plaintiffs are entitled to attorney fees and costs pursuant to Florida law, and specifically pursuant to Section 627.428 and/or Section 626.9373, Florida Statutes. WHEREFORE, based on the foregoing, Plaintiffs, SHAUN WILLIAMS and LISA M. WILLIAMS, demand judgment against Defendant, TOWER HILL SIGNATURE INSURANCE COMPANY, for damages, interest, attorney fees, costs, and any other such relief that this Honorable Court deems just and proper. DEMAND is hereby made for trial by jury of all issues so triable as a matter of right. DATED this 23 day of June 2022. MORGAN LAW GROUP, P.A. 55 Merrick Way, Suite 404 Coral Gables, Florida 33134 Phone: (305) 569-9900 Fax: (305)443-6828 e-Service: mlg.eservice@morganlawegroup.net By: _/s/Philip Rhodes Thomas J. Morgan, Jr., Esq. Florida Bar No. 127612 Phillip Rhodes, Esq. Florida Bar No.: 118395 prhodes@morganlawgroup.net /m]