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Filing # 101917079 E-Filed 01/20/2020 05:18:08 PM
IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT
IN AND FOR BAY COUNTY, FLORIDA
PATSY J. ODOM,
Plaintiff,
v. Case No.: 19-004405 CA
TOWER HILL SIGNATURE INSURANCE
COMPANY, a Florida insurance corporation,
Defendant.
/
TOWER HILL SIGNATURE INSURANCE COMPANY’S
MOTION TO DISMISS
Defendant, TOWER HILL SIGNATURE INSURANCE COMPANY (“Tower Hill”), by
and through its attorneys, pursuant to Fla. R. Civ. P. 1.140, hereby moves to dismiss the
Complaint filed by Plaintiff, PATSY J. ODOM (“Plaintiff”). In support hereof, Tower Hill
would show:
Introduction
Plaintiff filed a Complaint alleging causes of action for (1) breach of contract arising out
of insurance policy No. PIH0384517 and (2) declaratory relief. Plaintiff fails to state a cause of
action for Count I and Count II of his Complaint. Therefore, Plaintiffs Complaint should be
dismissed.
Memorandum of Law
I. Count I for Breach of Contract is Predicated on Improper allegations and
Fails to State a Cause of Action.
Plaintiff's Complaint includes improper allegations that have no place in the instant
litigation, as there has been no determination of liability or measure of damages in this case. For
example, Plaintiff alleges that Tower Hill breached its contract with Plaintiff by failing “to pay
Page 1 of 6Plaintiff that which she is owed under the terms of her policy”, withholding “excessive amounts
for depreciation”, and “grossly underestimated the cost to repair Plaintiff's damages.” (Ex. A at §
14). The allegations in paragraphs 7 through 10 and paragraph 14 not only misstate the coverages
available under the Policy but in addition, allegations of “excessive” and “grossly
underestimated” are inappropriate given there has been no determination of liability or measure
of damages in this case. See Liberty Mutual Ins. Co. v. The Farm, Inc., 754 So. 2d 865, 866 (Fla.
3d DCA 2000) (holding that because damages had not yet been determined in the underlying
first-party action against the insurer, the insured’s claim for extra-contractual damages must be
dismissed) Vest v. Travelers Ins. Co., 753 So. 2d 1270, 1276 (Fla. 2000).
Plaintiff's the allegations can only be seen as an attempt to circumvent established
Florida law protections on the claims file, claim investigation, and claims handling when there
has been no determination of liability and damages. See State Farm Fla. Ins. Co. v. Gallmon, 835
So. 2d 389, 390 (Fla. 2d DCA 2003) (finding claim file materials were either irrelevant to the
dispute or were privileged work product); see also State Farm Fire & Cas. Co. v. Valido, 662 So.
2d 1012, 1013 (Fla. Dist. Ct. App. 1995) (recognizing an insurer’s claim files, manuals,
guidelines, and claim handling procedures were irrelevant to the first party breach of contract
case); see also Allstate Indem. Co. v. Ruiz, 899 So. 2d 1121 (Fla. 2005); State Farm Mut. Auto.
Ins. Co. v. Tranchese, 49 So. 3d 809, 810 (Fla. 4th DCA 2010); Nationwide Ins. Co. of Fla. v.
Demmo, 57 So. 3d 982 (Fla. 2d DCA 2011); GEICO v. Rodriguez, 960 So. 2d 794, 795-96 (Fla.
3d DCA 2007). Allowing the Complaint to stand as it is written would irreparably harm Tower
Hill, lead to irrelevant and objectionable attempted discovery and unfairly influence a jury on
issues that have no bearing on the case at hand. Therefore, Plaintiff's Complaint should be
dismissed.
Page 2 of 6I. Count II for Declaratory Judgment Fails to State a Cause of Action.
Plaintiff's Count II asking for Declaratory Relief fails to state a cause of action. In
Florida, the right to a declaratory judgment for a party in doubt of his contractual rights was
created by Section 86.021, Florida Statutes, which states in pertinent part:
Any person claiming to be interested or who may be in doubt about his or
her rights under a deed, will, contract, or other article, memorandum, or
instrument in writing or whose rights, status, or other equitable or legal relations
are affected by a statute, or any regulation made under statutory authority, or by
municipal ordinance, contract, deed, will, franchise, or other article,
memorandum, or instrument in writing may have determined any question of
construction or validity arising under such statute, regulation, municipal
ordinance, contract, deed, will, franchise, or other article, memorandum, or
instrument in writing, or any part thereof, and obtain a declaration of rights,
status, or other equitable or legal relations thereunder.
Fla. Stat. § 86.021 (emphasis added).
To state a cause of action for declaratory relief in a first-party insurance action, Plaintiff
must allege a question of construction or validity of a specific policy provision to specific facts
that would require judicial interpretation. See State Farm Mut. Auto. Ins. Co. v. Wallace, 209 So.
2d 719, 721 (Fla. 2d DCA 1968)(emphasis added); Heritage Prop. And Cas. Ins. Co. v.
Romanach, Case No. 3D16-995 (Fla. 3d DCA 2017) (finding a cause of action for declaratory
judgment when the Court could determine from the allegations, and specific facts pled, what
ruling of law the party was seeking). Here, Plaintiff generally asks the Court for “relief” in her
Wherefore Clause and asks that the Court “determine and declare that Florida Statute 627.7011
and the subject policy of insurance provide the appropriate and controlling protocol for recovery
of withheld depreciation”, “determining that Defendant’s procedure as outlined in its letters of
November 14, 2018 and January 29, 2019 is inconsistent with, contrary to, and violative [sic] of
the subject policy of insurance and further ordering Defendant to refrain from imposing an extra-
contractual and illegal protocol and obligation for the recovery of withheld depreciation”, but
Page 3 of 6Plaintiff fails to state what facts or specific policy language they seek declaration of by the
Court. (See Complaint, attached as Exhibit “A”) In fact, Plaintiff admits in the Complaint
allegations to not knowing whether the language of Florida Statute 627.7011 appears in
Plaintiffs’ policy of insurance yet is somehow seeking declaration of rights under such unknown
provisions. Additionally, the requests for relief are improper, inappropriate, and given they are
simply encompassed in the Wherefore clause of Plaintiffs complaint, have no bearing on the
actual allegations which make up Plaintiff's alleged cause of action. Wherefore clause aside,
Plaintiff raises no question of construction, validity, nor does she state a need for the relief
requested from this Court.
Furthermore, as stated above, Plaintiff again is attempting to make extra-contractual
allegations, particularly given Plaintiff reference to the “extra-contractual” nature of the request,
and even so far as requesting this Court to prohibit action, which is wholly inappropriate when
there has been no determination of liability and damages and Plaintiff request appears to seek an
improper injunction, not declaration from this Court. Plaintiff Wherefore Clause goes on to
request discovery of a procedure, again an attempt to circumvent established case law preventing
discovery of policies and procedures of insurance companies, as cited above, when there has
been no determination of liability and damages. Plaintiff Count goes further than merely a
dispute regarding the actual cash value of the loss and asks this Court to make a ruling regarding
the internal policies and procedures of Tower Hill, which is wholly inappropriate and not ripe for
declaration under Florida law, as no breach of contract has been found on the part of the carrier.
Lastly, nowhere in Florida Statute 627.7011 does the Legislature provide a right of cause
of action for any alleged “violation” of the statutory provision parsed out by Plaintiff nor is there
any reference to any limitation of timeframe or requirement that an insurance carrier provide
unlimited time to an Insured to perform repairs. Therefore, Plaintiffs’ action must fail, as
Page 4 of 6Plaintiffs have no right to seek declaration under Florida law nor any specific policy language or
statutory language upon which this Court can make a declaration over. Accordingly, Count II
fails to state a cause of action for declaratory judgment and should be dismissed.
WHEREFORE, Defendant, TOWER HILL SIGNATURE INSURANCE COMPANY,
requests this Honorable Court dismiss Plaintiff's action. Defendant further requests all other
relief this Court deems just and proper as a matter of law.
[o] Nicole M. Fluet
NICOLE M. FLUET, Fla. Bar No. 91077
nfluct@gallowaylawfirm.com
SARAH K. CULLETON, Fla. Bar No. 1015231
sculleton@gallowaylawfirm.com
Galloway, Johnson, Tompkins, Burr & Smith, PLC
400 N. Ashley Drive, Suite 1000
Tampa, Florida 33602
(813) 977-1200
(813) 977-1288 (facsimile)
tampaservice@gallowaylawfirm.com
Counsel for Defendant, Tower Hill Signature
Insurance Company
Page 5 of 6CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
the following via the Florida Courts E-Filing Portal and/or electronic mail delivery this 20" day
of January, 2020:
Clark Hamilton, Jr., Esq.
Tyler & Hamilton, P.A.
Midtown Centre, Building 4000
4811 Beach Boulevard, Suite 200
Jacksonville, Florida 32207
Phone: 904-398-9999
Fax: 904-398-0806
courtdocs@floridainsurancelawyers.com
tandhpa@bellsouth.net
Counsel for Plaintiff
Jay Manuel, Esq.
Manuel & Thompson, P.A.
120 Richard Jackson Boulevard, Suite 200
Panama City, Florida 325407
Phone: 850-785-5555
Fax: 850-785-0133
jay@manuelthompson.com
velinda@manuelthompson.com
tim@manuelthompson.com
Counsel for Plaintiff
[| Nicale M. Fluet
NICOLE M. FLUET
SARAH K. CULLETON
Page 6 of 6Filing # 99781984 E-Filed 12/04/2019 01:27:04 PM
Exhibit A
IN THE CIRCUIT COURT, 14TH
JUDICIAL CIRCUIT, IN AND FOR
BAY COUNTY, FLORIDA
CASENO.: 19 004405 CA
PATSY J. ODOM,
Plaintiff,
ve
TOWER HILL SIGNATURE INSURANCE
COMPANY, a Florida insurance corporation,
Defendant.
SS
COMPLAINT
The Plaintiff, PATSY J. ODOM, by and through her undersigned attorneys, sues Defendant,
TOWER HILL SIGNATURE INSURANCE COMPANY, a Florida insurance corporation, and says:
GENERAL ALLEGATIONS
1, This is an action arising out of a dispute over an insurance contract, with the amount
in controversy in excess of $15,000.00, exclusive of interest, costs, and attorneys’ fees.
2. Atall times material hereto, Plaintiff was and is the owner of residential real property
located at 7601 Kingswood Road, Southport, Bay County, Florida.
3. Atall times material hereto, Defendant was a Florida insurance corporation organized
and existing under the laws of the State of Florida and authorized to engage in and was engaged in
the insurance business in Florida, including Bay County.
4, Prior to October 10, 2018, Defendant issued to Plaintiff a policy of homeowners
insurance insuring her home identified above, policy number PIH0384517. Plaintiff does not have
acopy of that policy in her possession, and although a request to Defendant for a copy of the policy
was made on behalf of Plaintiff by letter dated September 5, 2019 and by letter of October 14, 2019,Defendant has refused to provide Plaintiff with a copy of the policy. Defendant has the policy in its
possession. Plaintiff has requested a copy of the policy in discovery served with this Complaint.
5. On or about October 10, 2018, while the subject policy of insurance was in full force
and effect, the Plaintiffs home and contents therein were damaged by the storm forces of Hurricane
Michael, a covered cause of loss under the subject policy of insurance.
6. Following the loss, Plaintiff promptly notified Defendant of the loss and damage and
otherwise cooperated with Defendant in its investigation and adjustment of the loss.
7. Defendant thereafter inspected the loss and determined the loss was covered under
the policy and so notified the Plaintiff by letter to her dated November 14, 2018. A copy of that
letter is attached hereto as Exhibit “A”. In that letter, Defendant provided Plaintiff its estimate of
the damage which reflected the cost to repair Plaintiff's home was $37,808.80, from which
Defendant subtracted what Defendant determined to be “recoverable depreciation” in the amount of
$10,685.30, leaving a net ACV payable to the Plaintiff in the amount of $25,430.66.
8. By that correspondence, Defendant also determined the cost to repair Plaintiff's
detached structure under Coverage B of the policy was $3,644.61, From that number Defendant
subtracted $1,745.25 in “recoverable depreciation”, making anet ACV payable amount of $1,899.36.
9. Thereafter, by letter to the Plaintiff dated January 29, 2019, Defendant revised its
determination as to the amount of Plaintiff's covered loss, and determined the total damage to her
home was $55,208.12. From that number Defendant subtracted $22,227.90 in “recoverable
depreciation”, leaving a net amount payable under Coverage A of $28,355.22, subject to prior
payments.
10. With that correspondence, Defendant also recalculated the loss under Coverage B,
and determined the repair costs for that structure were $5,729.58, from which Defendant subtracted
“recoverable depreciation” of $3,791.76, leaving a net payment to the insured under that coverage
of $1,937.82, also subject to prior payments.
COUNT I (Breach of Contract)
11. The allegations contained in paragraphs | through 10 above are restated as if each
were set forth herein verbatim.
Page -2-12. This is an action for breach of an insurance contract.
13. Plaintiff's insured damages far exceed the amounts paid by Defendant to Plaintiff.
14. By paying only the amounts outlined above, Defendant has breached the insurance
contract with Plaintiff in that it has failed to pay Plaintiff that which she is owed under the terms of
her policy. Defendant has withheld excessive amounts for depreciation and has grossly
underestimated the cost to repair Plaintiff's damages, Defendant has also failed to pay Plaintiff in
full for her contents loss.
15. Plaintiff has been damaged by Defendant’s breach in that she has not received
insurance benefits to which she is entitled, including benefits for her home and contents.
16. Plaintiff has hired and retained the undersigned attorneys to represent her in
connection with this action and has agreed to pay a reasonable fee for their services. Pursuant to
Florida Statute §627.428, Plaintiff is entitled to an award of a reasonable attorney fee in the event
she prevails in this action.
WHEREFORE, Plaintiff demands judgment for damages against Defendant, together with
interest, costs, and attorneys’ fees, and DEMANDS TRIAL BY JURY.
COUNT Tl Declaratory Relief)
17. The allegations contained in paragraphs 1 through 10 above are restated as if each
were set forth herein verbatim.
18. This is an action for declaratory relief brought pursuant to Chapter 86, Florida
Statutes.
19. The subject policy of insurance is a homeowners policy as that term is used in Florida
Statute §627.7011.
20. Pursuant to Florida Statute §627.7011, and to the best of Plaintiff's knowledge and
belief pursuant to her policy with Defendant, Defendant is entitled to withhold a reasonable amount
of recoverable depreciation from claims payments made on structure losses insured under
homeowners insurance policies.
Page -3-21, Pursuant to Florida Statute §627.7011, and, on Plaintiff’s information and belief,
pursuant to the terms of the subject policy of insurance, the depreciation which has been withheld
may be recovered by Plaintiff pursuant to the policy and statute.
22. Florida Statute §627.7011(3)(a) provides:
“For a dwelling, the insurer must initially pay at least the actual cash
value of the insured loss, less any applicable deductible. The insurer
shall pay any remaining amounts necessary to perform such repairs
as work is performed and expenses are incurred.”
23. Upon information and belief, Plaintiffalleges her contract with Defendant has similar,
if not identical, language.
24. — In connection with the subject claim, Defendant has ignored both its policy of
insurance and Florida law when outlining to Plaintiff how she might recover that depreciation.
25, Specifically, in its letter to Plaintiff of November 14, 2018, attached as Exhibit A,
Defendant stated as follows:
“Because your claim is paid at actual cash value (ACV), you may make a claim for
up to $12,430.55, (the amount of recoverable depreciation) within 180 days,
providing us with receipts, photos, estimates, and/or other documentation supporting
that repairs have been completed and costs incurred, as well as the possibility of a re-
inspection to verify repairs.”
26. By its letter to Plaintiff of January 29, 2019, marked as Exhibit B, Defendant
substantively made the same statement to Plaintiff as follows:
“Recoverable Depreciation
‘
Your claim is paid at actual cash value (ACV), which is the valuation of your
property less any depreciation. You may make a claim for the recoverable
depreciation, up to $22,227.90, within 180 days by providing us with receipts,
photos, estimates, and/or any other documentation supporting that repairs have been
completed and costs incurred, as well as the possibility of a reinspection to verify
repairs.”
27. The procedure outlined by Defendant in the correspondence attached as Exhibit A
and Exhibit B materially differs from and is significantly financially more burdensome than the
procedure outlined in Florida Statute §627.701 1, and, Plaintiff'alleges, as outlined under the subject
policy ofinsurance. Neither the policy nor the statute impose a 180 day deadline and neither requires
that all repairs be completed prior to the recovery of withheld depreciation.
Page -4-28. __ Plaintiffhas doubts as to the parties’ rights and responsibilities under the terms of the
policy as it relates to how Plaintiff is entitled to recover depreciation, and whether she is obligated
to do so within a specific period of time.
29. Plaintiff is in need of a declaration by this Court as to the proper protocol and
procedure to be followed by Plaintiff for the recovery of withheld depreciation.
30. Plaintiff has no adequate remedy at law.
31. Plaintiff was required to retain the services of the undersigned attomeys in order to
bring this action and has agreed to pay a reasonable fee for those services. Pursuant to Florida
Statute §627.428, in the event Plaintiff prevails she is entitled to recover the reasonable fees from
Defendant,
WHEREFORE, Plaintiff requests the Court to take jurisdiction of this matter and issue an
order and judgment as follows:
1. Determine and declare that Florida Statute §627.7011 and the subject policy of
insurance provide the appropriate and controlling protocol for recovery of withheld depreciation;
2. Determining that Defendant’s procedure as outlined in its letters of November 14,
2018 and January 29, 2019 is inconsistent with, contrary to, and violative of the subject policy of
insurance and further ordering Defendant to refrain from imposing an extra-contractual and illegal
protocol and obligation for the recovery of withheld depreciation;
3. Awarding Plaintiff her reasonable attorneys fees and costs; and
4, Any and such further relief as the Court deems reasonable and necessary.
DEMAND FOR JURY TRIAL
Plaintiff hereby demands trial by jury on all issues so triable.
Page -5-TYLER & HAMILTON, P.A.
/s/Clark Hamilton, Jr.
CLARK HAMILTON, JR.
Florida Bar No.: 311731
Midtown Centre, Building 4000
4811 Beach Boulevard, Suite 200
Jacksonville, Florida 32207
(904) 398-9999 Telephone
(904) 398-0806 Facsimile
courtdocs@floridainsurancelawyers.com
tandhpa@bellsouth.net
and
MANUEL & THOMPSON, P.A.
Jay Manuel, Esq.
Florida Bar No.: 651052
120 Richard Jackson Boulevard, Suite 200
Panama City, FL 325407
(850) 785-5555 Telephone
(850) 785-0133 Facsimile
jay@manuelthompson.com
velinda@manuelthompson.com
tim@manuelthompson.com
Attorneys for Plaintiff, PATSY J. ODOM
Page -6-00200900000 15009668_0 140444 MLDP
November 14, 2018
PATSY J ODOM
7601 KINGSWOOD RD
SOUTHPORT, FL 32409
RE: Company: Tower Hill Signature Insurance Company
Insured: PATSY JODOM
Claim Number: 3300294952
Policy Number: PIH0384517
Date of Loss: 10/08/2018
Dear PATSY JODOM:
Below is the estimated payment for damages from your Windstorm claim based on our current
information. You should be receiving your check in the amount of $29,842.86 in 5-7 days. The
amount of your claim settlement is computed as follows:
Dwelling / Structure $ 37,808.80
"Other" Structure(s) $ 3,644.61
Personal Effects (Contents) § 6,300.00
Gross Lass $ 47,753.41
ee
es
Please do not hesitate to contact myself or our office should you have questions regarding the
amounts listed above.
Because your claim is paid at actual cash value (ACV), you may make a claim for up to
$12,430.55, (the amount of recoverable depreciation) within 180 days, by providing us with
receipts, photos, estimates, and/or any other documentation supporting that repairs have been
completed and costs incurred as well as the possibility of a re-inspection to verify repairs.
We also want to bring to your attention that the amount of $29,842.86 does not necessarily
constitute a full and final settlement of your claim for damages associated with your claimed
loss. You may submit supplemental claims for any damages discovered in the covered
PO Box 142230 @ Gainesville, FL 32614 ©@ Telephone (800) 342-3407 @ Fax (352) 332-7999
CoML 16
EXHIBIT Areconstruction and repair of the above mentioned property.
As mentioned above, if you believe you may have any supplemental damage, please contact me
to discuss the matter or send in any information that would help substantiate the claimed
damages, We encourage you to have any estimates we supplied you as well as those prepared by
other vendors available during our discussion to help pinpoint any area(s) of concern,
Our records currently indicate you have a mortgage on the home insured through our company.
Your policy contains contractual language to ensure your mortgagee’s financial interests are
protected when payment is issued for damages from a covered peril to your home or other
structures. We include the name of your mortgage company and/or companies when the amount
exceeds $1,500.00. Please contact your mortgage company to inquire on how to proceed to have
them endorse the check.
We appreciate the trust you placed in Tower Hill Signature Insurance Company and thank you
for allowing us to serve you in your time of need. If you should have any questions, feel free to
contact me at 888-563-4691 extension 154.
Sincerely,
Shaquille Cherry
Claims Representative
claims@thig.com
Enclosures:
cc:
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January 29, 2019
PATSY J ODOM
7601 KINGSWOOD RD
SOUTHPORT, FL 32409
RE: Company: Tower Hill Signature Insurance Company
Insured: PATSY J ODOM
Claim Number: 3300294952
Policy Number: PIHO384517
Date of Loss: 10/08/2018
Dear PATSY J ODOM:
Below we have included a summary of your claim settlement. Please be aware that the
amount outlined below does not necessarily constitute a full and final settlement of your
claim for damages associated with your claimed loss. We will continue to work with you
fo ensure you have appropriate funds to complete your repairs. If you need advice,
assistance finding a contractor, or have another estimate we should review, please call
me at 888-563-4691 extension 154 or Tower Hill Customer Service at (800) 342-3407
for assistance,
Below is the estimated payment for damages from your Windstorm claim based on our
current information. You should be receiving your chéck in the amount of $5,275.38 in
5-7 days. The amount of your claim settlement is calculated as follows:
Dwelling / Structure $ 55,208.12
"Other" Structure(s) $ 5,729.58
Ordinance or Law $ 463.02
$
Gross Loss
PO Box 142230 © Gainesville, FL 32614 @ Telephone (800) 342-3407 © Fax (352) 332-7999
(CPLHO., DPI83 120 WEP NLIEN WSL 1918
EXHIBIT BRecoverable Depreciation
Your claim is paid at actual cash value (ACV), which is the valuation of your property
less any depreciation. You may make a claim for the tecoverable depreciation, up to
$22,227.90, within 180 days by providing us with receipts, photos, estimates, and/or any
other documentation supporting that repairs have been completed and costs incurred,
as well as the possibility of a re-inspection to verify repairs.
Please do not hesitate to contact myself or our office should you have questions
regarding the amounts listed above.
Supplemental Payments/Damages
As stated earlier, the amount of $5,275.38 does not necessarily constitute a full and
final settlement of your claim for damages associated with your claimed loss. You may
submit supplemental claims for any damages discovered in the covered reconstruction
and repair of the insured property.
If you believe you may have any supplemental damage, please contact me to discuss
the matter or send in any information that would help substantiate the claimed
damages. We encourage you to have any estimates we supplied to you as well as
those prepared by other vendors available during our discussion to help pinpoint any
area(s)'of concem.
Ordinance or Law
Please be aware that your policy entitles you to further coverage for work that may be
required due to ordinance or law on a limited basis as incurred. Based on the estimate
provided, you may claim up to $0.00. In order to claim the additional amount(s), please
provide us with the following information for review:
1. Final invoice from your contractor showing the total cost, work completed, and
type of material installed.
2. A copy of the building permit, or like, pulled for your local building enforcement
agency that shows the permit number clearly.
Submitting Information
Unless otherwise instructed, you may provide documentation via your Customer Portal,
email, fax, or mail. Below are instructions to assist you when submitting information to
Tower Hill.
Customer Portal: You can upload files to your Customer Portal account using
your personal computer or mobile device at T HIG.com/Portal.
“Email: To submit information via email, please send it to claims@thig.com and
make sure to include your claim number, 3300294952, in the subject line
of your email.
2of 306300900000 16009725_0 623562 MLDP
*Email attachments are limited to 25 MB.
Fax: (352) 332-7999: As with email, please make sure to include your claim
number, 3300294952, on the cover sheet.
Mail: When mailing us information, please include your claim number,
3300294952, on your documentation.
Our mailing address is: Tower Hill Claims
P.O. Box 142230
Gainesville, FL 32614
We appreciate the trust you have placed in Tower Hill Signature Insurance Company
and thank you for allowing us to serve you in your time of need. If you should have any
questions, feel free to contact me at 888-563-4691 extension 154.
Sincerely,
Shaquille Cherry
Claims Representative
claims@thig.com
Enclosures:
cc:
Pursuant to Fla. Statute 817.234, we are required to provide the fallowing statement:
“Any person who knowingly and with intent fo injure, defraud, or deceive any insurer
files a statement of claim or an application containing any false, incomplete, or
misleading information is guilty of a felony of the third degree,”
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