Q&A Exhibit 2.pdf

Q&A Exhibit 2

Subpoena Example

*23-000454049* *23-000454049*

DR1

cc to:

AMANDA JACOBSON

ATTORNEY

JACOBSON, CHMELIR & FERWERDA

351 E. STATE ROAD 434, SUITE A

WINTER SPRINGS, FL 32708

MAHMOOD SILIETI CASE #: 2023-DR-660-O

COURT: CIRCUIT

COUNTY: ORANGE

PLAINTIFF(S) DFS-SOP #: 23-000454049

VS.

ROSALIE SILIETI

DEFENDANT(S)

SUBPOENA

NOTICE OF SERVICE OF PROCESS

NOTICE IS HEREBY GIVEN of acceptance of Service of Process by the Chief Financial Officer of the State of Florida. Said process was received in my office by ELECTRONIC DELIVERY on Monday, September 11, 2023 and a copy was forwarded by ELECTRONIC DELIVERY on Tuesday, September 12, 2023 to the designated agent for the named entity as shown below.

STATE FARM FLORIDA INSURANCE COMPANY

LYNETTE COLEMAN

1201 HAYS STREET

TALLAHASSEE, FL 32301

*Our office will only serve the initial process (Summons and Complaint) or Subpoena and is not responsible for transmittal of any subsequent filings, pleadings, or documents unless otherwise ordered by the Court pursuant to Florida Rules of Civil Procedure, Rule 1.080.

Jimmy Patronis Chief Financial Officer

Office of the General Counsel - Service of Process Section

200 East Gaines Street - P.O. Box 6200 - Tallahassee, FL 32314-6200 - (850)413-4200

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,

IN AND FOR ORANGE COUNTY, FLORIDA

IN RE: The Marriage of: CASE NO.: 2023-DR-660-O

MAHMOOD SILIETI

Petitioner, and

ROSALIE SILIETI

Respondent.

SUBPOENA DUCES TECUM WITHOUT DEPOSITION

THE STATE OF FLORIDA

TO: State Farm Florida Insurance Co.

c/o Chief Financial Officer 200 E. Gaines Street Tallahassee, FL 32399

YOU ARE COMMANDED to deliver or mail to the attorney whose name appears below, within twenty (20) days of your receipt hereof, the items on the attached Exhibit "A".

You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena by mail or delivery. You may condition the preparation of the copies upon payment, in advance, of the reasonable cost of preparing the copies. You have the right to object to the production pursuant to this subpoena at any time before production, by giving written notice to the attorney whose name appears on this subpoena.

If you fail to furnish the records as provided above or timely object to this subpoena you may be in contempt of court. You are subpoenaed by the attorney whose name appears below and unless excused from the subpoena by the attorney or by the Court, you must respond to the subpoena as directed.

THIS IS FOR RECORDS PICK-UP ONLY. NO TESTIMONY WILL BE TAKEN.

Dated:_________ ______________________________

AMANDA R. JACOBSON, ESQUIRE

Jacobson, Chmelir & Ferwerda Florida Bar Number: 0089631 351 E. State Road 434, Suite A Winter Springs, FL 32708 Tel. (407)327-8899 Fax. (407)327-3019 Email 1: arjlawfirm@hotmail.com Email 2: michelle@jmcflaw.com Attorney for the Wife

8/16/23

Exhibit "A"

16619 Tudor Grove Dr.

Orlando, FL 32828

Policy #59-CY-:037-1

1. Any and all insurance policies issued by State Farm Florida to Mahmood Silieti, Rosalie Silieti and Carol Whitaker regarding the property listed above.

2. Any and all correspondence regarding the property listed above.

3. Any and all claims made regarding the property listed above.

4. Any and all photographs, reports and appraisals regarding the property listed above.

5. Any and all policy cancellations, modifications, renewals, and non-renewals regarding any insurance policy related to the property listed above.

6. Any and all payment records, receipts, and transactions related to the property listed above held by State Farm Florida.

7. Any and all other records related to the property listed above.

Q&A Exhibit 2

Summons and Complaint Example

*23-000453980* *23-000453980*

DR1

cc to:

JUAN CAMILO VELASQUEZ

PRESIDENT

VELASQUEZ & ASSOCIATES, P.A.

16201 SW 95 AVENUE

SUITE 100A

MIAMI, FL 33157

JOSE AGUILAR AND KATERINE ARMIJO CASE #: 23001410CCAXMX

COURT: 19TH JUDICIAL CIRCUIT

COUNTY: MARTIN

PLAINTIFF(S) DFS-SOP #: 23-000453980

VS.

CASTLE KEY INDEMNITY COMPANY

DEFENDANT(S)

SUMMONS, COMPLAINT, DISCOVERY

NOTICE OF SERVICE OF PROCESS

NOTICE IS HEREBY GIVEN of acceptance of Service of Process by the Chief Financial Officer of the State of Florida. Said process was received in my office by ELECTRONIC DELIVERY on Monday, September 11, 2023 and a copy was forwarded by ELECTRONIC DELIVERY on Tuesday, September 12, 2023 to the designated agent for the named entity as shown below.

CASTLE KEY INDEMNITY COMPANY

DONNA MOCH

1200 SOUTH PINE ISLAND ROAD

PLANTATION, FL 33324

*Our office will only serve the initial process (Summons and Complaint) or Subpoena and is not responsible for transmittal of any subsequent filings, pleadings, or documents unless otherwise ordered by the Court pursuant to Florida Rules of Civil Procedure, Rule 1.080.

Jimmy Patronis Chief Financial Officer

Office of the General Counsel - Service of Process Section

200 East Gaines Street - P.O. Box 6200 - Tallahassee, FL 32314-6200 - (850)413-4200

Filing # 181507847 E-Filed 09/11/2023 12:05:04 PM

330 SW 27th Avenue Suite 601 Miami, Florida 33135 | T: (786) 776-0130 | F: (305) 230-4190

IN THE COUNTY COURT FOR THE 19TH

JUDICIAL CIRCUIT IN AND FOR

MARTIN COUNTY, FLORIDA

JOSE AGUILAR AND KATERINE ARMIJO,

Plaintiff, CASE NO.:

v.

CASTLE KEY INDEMNITY COMPANY,

Defendant.

COMPLAINT

Plaintiff, JOSE AGUILAR AND KATERINE ARMIJO (the “Plaintiff”), hereby sues

Defendant, CASTLE KEY INDEMNITY COMPANY (hereinafter “Defendant”), and alleges as follows:

PARTIES, JURISDICTION AND VENUE

1. This is an action for damages that does not exceed $50,000.00 exclusive of interest, costs, and attorney’s fees.

2. At all times material hereto, Plaintiff, JOSE AGUILAR AND KATERINE

ARMIJO, was and is a resident of MARTIN County, Florida, and the homeowner’s policy of insurance involved herein was issued by Defendant, CASTLE KEY INDEMNITY COMPANY, to Plaintiff, JOSE AGUILAR AND KATERINE ARMIJO, of MARTIN County, Florida.

3. At all times material hereto, Defendant, CASTLE KEY INDEMNITY

COMPANY, was and is a corporation duly licensed to transact insurance business in the State of

Florida and maintained agents for the transaction of its customary business in MARTIN County, Florida.

Jurisdiction and Venue

4. This Court has subject matter jurisdiction over the claims asserted herein because the total amount does not exceed $50,000.00, exclusive of interest and costs.

5. Venue is proper in MARTIN County, Florida because the cause of action accrued in MARTIN County, Florida.

GENERAL ALLEGATIONS

6. Plaintiff purchased and paid the premium for a policy of homeowner’s insurance from Defendant, Policy Number 988-870-728 (the “Policy’), for the property located at 395 Galley

St SE Palm Bay, FL 32909 (the “Insured Property.”)

7. The Policy was in full force and effect at all relevant times to this lawsuit.

8. That the damage to Plaintiff’s home, and any and all claims and losses of JOSE

AGUILAR AND KATERINE ARMIJO for the loss on or about September 28, 2022, fall within coverage afforded pursuant to the policy of insurance issued by the Defendant, CASTLE KEY

INDEMNITY COMPANY, No.: 988-870-728.

9. A true and correct copy of the Policy is attached hereto and incorporated herein as composite Exhibit “A”.

10. The Plaintiffs’ representative prepared an estimate of damages incurred by the

Plaintiff as a result of the loss. A true and correct copy of the Estimate is attached hereto and incorporated herein as composite Exhibit “B”.

11. The Insurance Company assigned claim number 0689052108 to the Loss.

12. The loss to the insured’s Property was a direct physical loss to the property and, therefore, is a covered peril under the policy.

13. Accordingly, Plaintiff immediately made application to Defendant for insurance benefits under the Policy.

14. The CASTLE KEY INDEMNITY COMPANY has failed to pay all benefits to which Plaintiff is entitled under the Policy.

15. All conditions precedent to obtaining payment of insurance benefits under the

Policy, and to the filing of this action have been fulfilled, satisfied, waived, or excused.

COUNT I – BREACH OF CONTRACT

16. The Plaintiff reallege paragraphs 1 through 15 as if fully set forth herein and further allege the following:

17. The Defendant’s denial of coverage and/or refusal to pay the full amount of the claim was contrary to the terms of the Policy and/or Florida law and was a breach of said contract of insurance.

18. As a direct and proximate cause of the Defendant’s acts and/or omissions, Plaintiff has been damaged in an amount to be determined at trial.

19. That as a direct and proximate cause of the Defendant’s breach in refusal to pay the full amount of the Plaintiff’s claim, the Plaintiff has been required to retain the legal services of

Velasquez & Associates, P.A. for the purposes of prosecuting the instant matter and such attorneys are entitled to reasonable attorney’s fees pursuant to Section 627.428, Florida Statutes.

WHEREFORE, the Plaintiff, JOSE AGUILAR AND KATERINE ARMIJO demands judgment against the Defendant CASTLE KEY INDEMNITY COMPANY for damages, including, but not limited to, damage to the premises, its contents, loss of use, costs, interest as allowed by law, reasonable attorney’s fees pursuant to Section 627.428, Florida Statutes, and such other relief as this Court deems just and proper.

DEMAND FOR JURY TRIAL

The Plaintiff hereby demands a trial by jury on all issues so triable. Dated this September

7, 2023

Respectfully Submitted, Velasquez & Associates, P.A.

330 SW 27th Avenue, Suite 601 Miami, FL 33135 T: (786) 776-0130 F: (305) 230-4190 Juan@jvelasquezlaw.com www.jvelasquezlaw.com

Juan C. Velasquez, Esq.

Florida Bar No. 84767

Confidential Information

Claim#__________________________

To Whom It May Concern:

I, ________________, employee of Allstate Insurance Company, do certify that the enclosed is a Copy of Castle Key policy and or declaration page for the above claim number, showing the coverages that were on the policy at the time of loss of

Claim Support

State of Texas, County of Dallas

____ _____On this __ ______ day of ____ __________________, 2022 before me personally appeared ___________________ to me known to be the person who executed the foregoing instrument and acknowledged that she/he executed the same as a free act and deed.

Vishwas Malshikare

26th October

Vishwas Malshikare

09/29/2022

0689052108

EXHIBIT A

Ted Todd Insurance

23190 Fshn Dr # P216

Estero FL 33928-2561

Information as of October 6, 2022

Policyholder(s)

Jose I Aguilar, Katerine O Armijo

Policy number

988 870 728

Your Castle Key agency is

Ted Todd Insurance

(239) 948-1234

TedTodd@allstate.com

TFADDAADFDFTTFATAFTDFTTFAFDTDFATFADAFTDDATADADADDAFDFADAATDTFADTD

JOSE I AGUILAR

KATERINE O ARMIJO

395 GALLEY ST SE

PALM BAY FL 32909-4302

Here’s a Copy of Your Current Policy Declarations

This package contains your Castle Key* Broad Policy Declarations—which lists your coverages, coverage limits, premiums and any discounts you’re receiving.

Please give me a call at (239) 948-1234 if you have any questions.

* Please note that, while the assets and liabilities of the Castle Key companies are separate and distinct from other companies within the Allstate group, Allstate Insurance Company provides some customer services for the Castle Key companies.

NP190-1

Page 2 of 2Policy number: 988 870 728

Policy effective date: July 23, 2022

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Your Insurance Coverage Checklist

We’re happy to have you as an Castle Key customer! This checklist outlines what’s in this package and provides answers to some basic questions, as well as any “next steps” you may need to take.

A guide to your welcome package

£ What’s in this package?

See the guide below for the documents that are included.

Next steps: review your Policy Declarations to confirm you have the coverages, coverage limits, premiums and savings that you requested and expected. Read any

Endorsements or Important Notices to learn about new policy changes, topics of special interest, as well as required communications. Keep all of these documents with your other important insurance papers.

£ Am I getting all the discounts I should?

Confirm with your Castle Key Agent that you’re benefiting from all the discounts you’re eligible to receive.

Policy

Declarations*

The Policy

Declarations lists policy details, such as your property details and coverages.

Policy

Your policy is your insurance contract; it lists all of the terms and conditions of your coverage.

Policy

Endorsements

If changes are made to your policy, these documents will include your new contract language.

Important

Notices

We use these notices to call attention to particularly important coverages, policy changes and discounts.

£ What about my bill?

Unless you’ve already paid your premium in full, we’ll send your bill separately. Next steps: please pay the minimum amount by the due date listed on it.

You can also pay your bill online at Allstate.com/support or through the Allstate mobile app. If you’re enrolled in the

Allstate® Easy Pay Plan, we’ll send you a statement detailing your payment withdrawal schedule. Para español, Ilamar al 1-800-979-4285.

£ What if I have questions?

Visit Allstate.com/support to browse our list of frequently asked questions and find information regarding billing or policy documents. You can also create an online account to access and manage your policies. Para español, Ilamar al 1-800-979-4285.

* To make it easier to see where you may have gaps in your protection, we’ve highlighted any coverages you do not have in the

Coverage Detail section in the enclosed Policy Declarations.

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Homeowners Policy Broad Declarations

Your policy effective date is July 23, 2022

Information as of October 6, 2022

Summary

Named Insured(s)

Jose I Aguilar, Katerine O Armijo

Mailing address

395 Galley St SE

Palm Bay FL 32909-4302

Policy number

988 870 728

Your policy provided by

Castle Key Indemnity Company

Policy period

Begins on July 23, 2022 at 12:01 A.M.

standard time, with no fixed date of expiration

Premium period

Beginning July 23, 2022 through July 23, 2023 at 12:01 A.M. standard time

Your Castle Key agency is

Ted Todd Insurance

23190 Fshn Dr # P216

Estero FL 33928-2561

(239) 948-1234

TedTodd@allstate.com

Some or all of the information on your

Policy Declarations is used in the rating of your policy or it could affect your eligibility for certain coverages. Please notify us immediately if you believe that any information on your Policy

Declarations is incorrect. We will make corrections once you have notified us, and any resulting rate adjustments, will be made only for the current policy period or for future policy periods.

Please also notify us immediately if you believe any coverages are not listed or are inaccurately listed.

THIS POLICY CONTAINS A SEPARATE DEDUCTIBLE

FOR HURRICANE LOSSES, WHICH MAY RESULT IN

HIGH OUT-OF-POCKET EXPENSES TO YOU.

LAW AND ORDINANCE: LAW AND ORDINANCE

COVERAGE IS AN IMPORTANT COVERAGE THAT YOU

MAY WISH TO PURCHASE. PLEASE DISCUSS WITH

YOUR INSURANCE AGENT.

FLOOD INSURANCE: YOU MAY ALSO NEED TO

CONSIDER THE PURCHASE OF FLOOD INSURANCE.

YOUR HOMEOWNER'S INSURANCE POLICY DOES NOT

INCLUDE COVERAGE FOR DAMAGE RESULTING FROM

FLOOD EVEN IF HURRICANE WINDS AND RAIN

CAUSED THE FLOOD TO OCCUR. WITHOUT SEPARATE

FLOOD INSURANCE COVERAGE, YOU MAY HAVE

UNCOVERED LOSSES CAUSED BY FLOOD. PLEASE

DISCUSS THE NEED TO PURCHASE SEPARATE FLOOD

INSURANCE COVERAGE WITH YOUR INSURANCE

AGENT.

YOUR POLICY PROVIDES COVERAGE FOR A

CATASTROPHIC GROUND COVER COLLAPSE THAT

RESULTS IN THE PROPERTY BEING CONDEMNED AND

UNINHABITABLE. OTHERWISE, YOUR POLICY DOES

NOT PROVIDE COVERAGE FOR SINKHOLE LOSSES.

YOU MAY PURCHASE ADDITIONAL COVERAGE FOR

SINKHOLE LOSSES FOR AN ADDITIONAL PREMIUM.

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Homeowners Policy Broad Declarations

Policy number: 988 870 728

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Total Premium for the Premium Period (Your bill will be mailed separately)

Premium for property insured $2,120.00

01/2007 Florida Hurricane Catastrophe Fund Emergency

Assessment

$0.00

Total $2,122.00

Your bill will be mailed separately. Before making a payment, please refer to your latest bill, which includes payment options and installment fee information. If you do not pay in full, you will be charged an installment fee(s). If you do not pay your bill by the due date shown on your billing statement, you may be charged a late fee.

The total premium includes a $619.00 hurricane premium.

The total premium includes a $1,501.00 non-hurricane premium.

The total premium includes a $2.00 EMPA trust fund surcharge.

The total premium includes a windstorm loss mitigation discount.

Discount (included in your total premium)

Windstorm Mitigation 68%

Location of property insured

395 Galley St SE, Palm Bay, FL 32909-4302

Rating Information*

Please review and verify the information regarding your insured property. Please refer to the Important Notice (X72800-1) for additional coverage information.

Contact us if you have any changes.

The dwelling is of brick construction and is occupied by 1 family

Your dwelling is 2 miles to the fire department

Hurricane Premium adjusted 28% and Non-Hurricane Premium adjusted 0% for

Building Code Effectiveness Grading Adjustments range from 1% surcharge to 11% discount.

Dwelling Style:

Built in 2006; 1 family; 1808 sq. ft.; 1 story

Foundation:

Slab at grade, 100%

Attached structure:

Attached garage, 420 sq. ft.

Interior details:

One builders grade kitchen Two builders grade full baths

Exterior wall type:

100% stucco on masonry

(continued)

Policy effective date: July 23, 2022

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Rating Information* (continued)

Interior wall partition:

100% drywall

Heating and cooling:

Gas hot air heating , 100% Central air - same ducts, 100%

Additional details:

Vinyl sash with glass, 100%

Two exterior wood doors

Interior wall height - 8 ft, 100%

Fire protection details:

Fire department subscription - no 2 miles to fire department

Roof surface material type:

Composition

• 100% asphalt / fiberglass shingle

*This is a partial list of property details. If the interior of your property includes custom construction, finishes, buildup, specialties or systems, please contact your Castle Key representative for a complete description of additional property details.

Mortgagee

FREEDOM MORTGAGE CORPORATION ITS SCRS &/OR ASSIGNS ATIMA

P O Box 5050, Troy, MI 48007-5050

Loan number: 0145767620

Additional Interested Party

None

Coverage detail for the property insured

Coverage Limits of Liability Applicable Deductible(s)

Dwelling Protection - with Building

Structure Replacement Cost Method

Extended Limits

$278,000 • Other Peril Deductible Applies**

• Deductible for Hurricane Applies***

Other Structures Protection $5,560 • Other Peril Deductible Applies**

• Deductible for Hurricane Applies***

Personal Property Protection -

Actual Cash Value

$139,000 • Other Peril Deductible Applies**

• Deductible for Hurricane Applies***

Additional Living Expense Lesser of $27,800 or 12 months

Family Liability Protection $300,000 each occurrence

Guest Medical Protection $5,000 each person

Building Codes (Law and Ordinance

Coverage)

25% of the Limit of Liability of Dwelling

Protection

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Homeowners Policy Broad Declarations

Policy number: 988 870 728

Policy effective date: July 23, 2022

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Other Coverages Not Purchased:

• Business Property Protection*

• Business Pursuits*

• Cellular Communication System*

• Electronic Data Processing

Equipment*

• Extended Coverage on Cameras*

• Extended Coverage on Jewelry, Watches and Furs*

• Extended Coverage on Musical

Instruments*

• Extended Coverage on Sports

Equipment*

• Fire Department Charges*

• Golf Cart*

• Home Day Care*

• Incidental Office, Private

School Or Studio*

• Increased Coverage on Money*

• Increased Coverage on Securities*

• Increased Silverware Theft Limit*

• Lock Replacement*

• Loss Assessments*

• Optional Protection for Mold*

• Satellite Dish Antennas*

• Sinkhole Activity*

* This coverage can provide you with valuable protection. To help you stay current with your insurance needs, contact your agent to discuss available coverage options and other products and services that can help protect you.

** $2,500 is your Other Peril Deductible, which applies to the total of all losses under the coverages indicated above.

***$5,560 (calculated by applying 2% to your Dwelling Protection limit) is your Deductible for Hurricanes, which applies to the total of all property losses under the coverages indicated above. Please read your Hurricane

Deductible Endorsement carefully.

Scheduled Personal Property Coverage

Your policy does not include Scheduled Personal Property Coverage. This coverage can provide you with valuable protection. To help you stay current with your insurance needs, contact your agent to discuss available coverage options and other products and services that can help protect you.

Your policy documents

Your Homeowners policy consists of the Policy Declarations and the following documents. Please keep them together.

• Homeowners Policy Broad – AP4688 • Depreciation Amendatory Endorsement – AP4981

• Florida Hurricane Deductible Endorsement – AP865-1 • Florida Homeowners Policy Broad Amendatory Endorsement –

AP4763-1

• Lender's Loss Payable Endorsement – AP875 • Amendatory Endorsement – AP4963

• Amendatory Endorsement – AP4590

Important payment and coverage information

Here is some additional, helpful information related to your coverage and paying your bill:

„ A $10.00 late fee may be assessed if payment is received after the due date.

„ The Property Insurance Adjustment condition applies using the Marshall Swift Boeckh Publications building cost index.

„ Do not pay. Mortgagee has been billed.

(continued)

Policy effective date: July 23, 2022

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Important payment and coverage information (continued)

If You Have a Question About Your Insurance...

If you wish to present an inquiry or obtain information about coverage, or if you need assistance in resolving a complaint, please call (239) 948-1234.

Allison Moe

President

Susan L. Lees

Secretary

IN WITNESS WHEREOF,Castle Key Indemnity Company has caused this policy to be signed by two of its officers at Northbrook, Illinois, and if required by state law, this policy shall not be binding unless countersigned on the Policy Declarations by an authorized agent of Castle Key Indemnity Company.

Policy countersigned by Ted Todd Insurance

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CASTLE KEY INDEMNITY COMPANY

Homeowners

Policy Broad

FLORIDA AP4688

Policy number

988 870 728

Policy effective

July 23, 2022

Your Castle Key agency is

Ted Todd Insurance

23190 Fshn Dr # P216

Estero FL 33928-2561

Policyholders

Jose I Aguilar, Katerine O Armijo

395 Galley St SE

Palm Bay FL 32909-4302

Castle Key Indemnity Company

A Stock Company---Home Office: St. Petersburg, Florida 33716

Table of Contents General Definitions Used In This Policy Insuring Agreement Agreements We Make With You Conformity To State Statutes Coverage Changes Policy Transfer Continued Coverage After Your Death Renewal Cancellation Concealment Or Fraud What Law Will Apply Where Lawsuits May Be Brought

Section I—Your Property Dwelling Protection–Coverage A Property We Cover Under Coverage A Property We Do Not Cover Under Coverage A Other Structures Protection–Coverage B Property We Cover Under Coverage B Property We Do Not Cover Under Coverage B Losses We Cover Under Coverages A and B Losses We Do Not Cover Under Coverages A and B Personal Property Protection–Coverage C Property We Cover Under Coverage C Limitations On Certain Personal Property Property We Do Not Cover Under Coverage C Losses We Cover Under Coverage C Losses We Do Not Cover Under Coverage C Additional Protection Additional Living Expense Credit Card, Bank Fund Transfer Card, Check Forgery And Counterfeit Money Debris Removal Emergency Removal Of Property Fire Department Charges Temporary Repairs After A Loss Trees, Shrubs, Plants And Lawns Temperature Change Power Interruption Building Codes Arson Reward Collapse Section I Conditions Deductible Insurable Interest And Our Liability What You Must Do After A Loss How We Pay For A Loss Our Settlement Of Loss Appraisal

Abandoned Property Permission Granted To You Our Rights To Recover Payment Our Rights To Obtain Salvage Suit Against Us Glass Replacement No Benefit To Bailee Other Insurance Property Insurance Adjustment Mortgagee Mold, Fungus, Wet Rot And Dry Rot Remediation As A Direct Result Of A

Covered Water Loss Neutral Evaluation For Resolution Of Sinkhole Activity Losses

Section II—Family Liability And Guest Medical Protection Family Liability Protection–Coverage X Losses We Cover Under Coverage X Losses We Do Not Cover Under Coverage X Guest Medical Protection–Coverage Y Losses We Cover Under Coverage Y Losses We Do Not Cover Under Coverage Y Additional Protection Claim Expenses Emergency First Aid Damage To Property Of Others Section II Conditions What You Must Do After An Accidental Loss What An Injured Person Must Do—Guest Medical Protection–Coverage Y Our Payment Of Loss—Guest Medical Protection–Coverage Y Our Limits Of Liability Bankruptcy Our Rights To Recover Payment—Family Liability Protection–Coverage X Suit Against Us Other Insurance—Family Liability Protection–Coverage X

Section III—Optional Protection Optional Coverages You May Buy Increased Coverage On Business Property– Coverage BP Increased Coverage On Electronic Data Processing Equipment– Coverage DP Fire Department Charges–Coverage F Loss Assessments–Coverage G Extended Coverage On Jewelry, Watches And Furs–Coverage J Incidental Office, Private School Or Studio–Coverage K Lock Replacement–Coverage LR Increased Coverage On Money–Coverage M Business Pursuits–Coverage P Increased Coverage On Securities–Coverage S Satellite Dish Antennas–Coverage SD Portable Cellular Communication Systems–Coverage SE Increased Coverage On Theft Of Silverware–Coverage ST

Homeowners Policy Broad

Policy number: 988 870 728

General

Definitions Used In This Policy

1. You or your means the person named on the Policy Declarations as the insured and that person’s resident spouse.

2. We, us or our means the company named on the Policy Declarations.

3. Insured person(s) means you and, if a resident of your household:

a) any relative; and

b) any dependent person in your care.

Under Family Liability Protection–Coverage X and Guest Medical Protection–Coverage Y, insured person also means:

a) any person or organization legally responsible for loss caused by animals or watercraft covered by this policy which are owned by an insured person. We do not cover any person or organization using or having custody of animals or watercraft in any business, or without permission of the owner.

b) with respect to the use of any vehicle covered by this policy, any person while engaged in the employment of an insured person.

4. Bodily injury means physical harm to the body, including sickness or disease, and resulting death, or any resulting symptom, effect, condition, disease or illness. Bodily injury does not include any of the following which are communicable: disease, bacteria, parasite, virus or other organism, any of which are transmitted by any insured person to any other person. It also does not include the exposure to any such disease, bacteria, parasite, virus or other organism by any insured person to any other person.

Under Guest Medical Protection–Coverage Y, bodily injury means physical harm to the body, including sickness or disease. Bodily injury does not include any of the following which are communicable: disease, bacteria, parasite, virus or other organism, any of which are transmitted by any insured person to any other person. It also does not include the exposure to any such disease, bacteria, parasite, virus or other organism by any insured person to any other person.

5. Building structure means a structure with walls and a roof.

6. Business means:

a) any full- or part-time activity of any kind engaged in for economic gain and the use of any part of any premises for such purposes. The providing of home day care services to other than an insured person or relative of an insured person for economic gain is also a business.

However, the mutual exchange of home day care services is not considered a business;

b) any property rented or held for rental by an insured person. Rental of your residence premises is not considered a business when:

1) it is rented occasionally for residential purposes;

2) a portion is rented to not more than two roomers or boarders;

or

3) a portion is rented as a private garage.

7. Residence premises means the dwelling, other structures and land located at the address stated on the Policy Declarations.

8. Insured premises means:

a) the residence premises; and

b) under Section II only:

1) the part of any other premises, other structures and grounds used by you as a residence. This includes premises, structures and grounds you acquire for your use as a private residence while this policy is in effect;

2) any part of a premises not owned by an insured person but where an insured person is temporarily living;

3) cemetery plots or burial vaults owned by an insured person;

4) vacant land, other than farmland, owned by or rented to an insured person;

5) land owned by or rented to an insured person where a one-, two-, three-, or four-family dwelling is being built as that person’s residence;

6) any premises used by an insured person in connection with the residence premises;

7) any part of a premises occasionally rented to an insured person for other than business purposes.

9. Occurrence means an accident, including continuous or repeated exposure to substantially the same general harmful conditions during the policy period, resulting in bodily injury or property damage.

10. Property damage means physical injury to or destruction of tangible property, including loss of its use resulting from such physical injury or destruction.

11. Residence employee means an employee of an insured person while performing duties arising out of and in the course of employment in connection with the maintenance or use of your residence premises.

This includes similar duties performed elsewhere for an insured person, not in connection with the business of an insured person.

12. Dwelling means a one-, two-, three-, or four-family building structure, identified as the insured property on the Policy Declarations, where you reside and which is principally used as a private residence.

13. Sinkhole activity means the settlement or systematic weakening of the earth supporting the dwelling or a covered building structure, but only when such settlement or systematic weakening results from movement or raveling of soils, sediments or rock materials into subterranean voids created by the effect of water on a limestone or similar rock formation.

We do not cover catastrophic ground cover collapse under Sinkhole Activity Coverage.

14. Catastrophic ground cover collapse means geological activity that results in all the following:

a) the abrupt collapse of the ground cover;

b) a depression in the ground cover clearly visible to the naked eye;

Homeowners Policy Broad

Policy number: 988 870 728

Policy effective date: July 23, 2022

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c) structural damage to a building structure, including the foundation, that we cover under Dwelling Protection–Coverage A or Other Structures Protection–Coverage B; and

d) that building structure being condemned and ordered to be vacated by the governmental agency authorized by law to issue such an order for that building structure.

Catastrophic ground cover collapse does not include structural damage consisting merely of settling or cracking of a foundation, structure or building structure.

Insuring Agreement In reliance on the information you have given us, we agree to provide the coverages indicated on the Policy Declarations. In return, you must pay the premium when due and comply with the policy terms and conditions, and inform us of any change in title, use or occupancy of the residence premises.

Subject to the terms of this policy, the Policy Declarations shows the location of the residence premises, applicable coverages, limits of liability and premiums. The policy applies only to losses or occurrences that take place during the policy period. The policy period is shown on the Policy Declarations. This policy is not complete without the Policy Declarations.

The terms of this policy impose joint obligations on the person named on the Policy Declarations as the insured and on that person’s resident spouse. These persons are defined as you or your. This means that the responsibilities, acts and omissions of a person defined as you or your will be binding upon any other person defined as you or your.

The terms of this policy impose joint obligations on persons defined as an insured person. This means that the responsibilities, acts and failures to act of a person defined as an insured person will be binding upon another person defined as an insured person.

Agreements We Make With You We make the following agreements with you:

Conformity To State Statutes When the policy provisions conflict with the statutes of the state in which the residence premises is located, the provisions are amended to conform to such statutes.

Coverage Changes When we broaden coverage during the premium period without charge, you have the new features if you have the coverage to which they apply.

Otherwise, the policy can be changed only by endorsement.

The coverage provided and the premium for the policy is based on information you have given us. You agree to cooperate with us in determining if this information is correct and complete. You agree that if this information changes, is incorrect or incomplete, we may adjust your coverage and premium accordingly during the policy period.

Any calculation of your premium or changes in your coverage will be made using the rules, rates and forms on file, if required, for our use in your state.

The rates in effect at the beginning of your current premium period will be used to calculate any change in your premium.

Policy Transfer You may not transfer this policy to another person without our written consent.

Continued Coverage After Your Death If you die, coverage will continue until the end of the premium period for:

1. Your legal representative while acting as such, but only with respect to the residence premises and property covered under this policy on the date of your death;

2. An insured person, and any person having proper temporary custody of your property until a legal representative is appointed and qualified.

Renewal If we intend to renew your policy, we will mail you an offer to renew your policy at least 45 days before the end of the policy period.

Cancellation Your Right to Cancel:

You may cancel this policy by notifying us of the future date you wish to stop coverage.

Our Right to Cancel:

We may cancel this policy by mailing notice to you at the mailing address shown on the Policy Declarations. When this policy has been in effect for less than 90 days, and it is not a renewal with us, we may cancel this policy for any reason. If the cancellation is for non-payment of premium, we will give you at least 10 days’ notice. If the cancellation is for any other reason, we will give you at least 20 days’ notice. If you have had a policy with us or an affiliate company that insured the same residence premises as this policy for a period of at least five years prior to the date of cancellation, we will give you at least 180 days’ notice, unless the cancellation is for non-payment of premium. If the cancellation is for non-payment of premium, we will give you at least 10 days’ notice.

When this policy has been in effect for 90 days or less, we may cancel for any reason, except we may not cancel:

1. on the basis of property insurance claims that are the result of an Act of

God, unless we can demonstrate, by claims frequency or otherwise, that you have failed to take action reasonably necessary as requested by us to prevent recurrences of damage to the insured property.

2. on the basis of filing claims for partial loss caused by sinkhole damage or clay shrinkage, regardless of whether this policy has been the subject of a sinkhole damage or clay shrinkage claim, or on the basis of the risk associated with the occurrence of such claim. However, we may cancel this policy if:

a) the total of such property claim payments for this policy exceeds the current policy limits of coverage for property damage; or

b) you have failed to repair the structure in accordance with the engineering recommendations upon which any loss payment or policy proceeds were based.

Homeowners Policy Broad

Policy number: 988 870 728

3. on the basis of a single claim on a property insurance policy which is the result of water damage unless we can demonstrate you have failed to take action reasonably requested by us to prevent a future similar occurrence of damage to the insured property.

When this policy has been in effect for 90 days or more, or if it is a renewal with us, we may cancel this policy for one or more of the following reasons:

1. non-payment of premium;

2. the policy was obtained by misrepresentation, fraud or concealment of material facts;

3. there has been substantial change or increase in hazard in the risk we originally accepted;

4. material misstatement; or

5. we have mailed notice within the first 90 days that we do not intend to continue the policy.

If the cancellation is for non-payment of premium, we will give you at least 10 days’ notice. If the cancellation is for any other reason, we will give you at least 180 days’ notice or if the cancellation would be effective between June 1 and November 30, we will give you at least 180 days’ notice or notice by June 1, whichever is earlier.

If the cancellation is for non-payment of premium by your mortgage lender and the premium payment made is not more than 90 days overdue, we shall reinstate the insurance policy, retroactive to the date of cancellation.

Our mailing the notice of cancellation to you will be deemed proof of notice.

Coverage under this policy will terminate on the effective date and time stated on the cancellation notice. Your return premium, if any, will be calculated on a pro rata basis and refunded at the time of cancellation or within 15 working days after the effective date of cancellation. Any unearned premium amounts under $5.00 will be refunded only upon your request. However, refund of unearned premium is not a condition of cancellation.

Our Right Not to Renew or Continue:

We have the right not to renew or continue this policy beyond the current premium period. If we do not intend to continue or renew the policy, we will give you notice at least 180 days before the end of the premium period or, for any non-renewal that would be effective between June 1 and November 30, we will give you notice at least 180 days before the end of the premium period or notice by June 1, whichever is earlier. Our mailing the notice of non-renewal to you will be deemed proof of notice.

We may non-renew or discontinue this policy for any reason, except:

1. on the basis of property insurance claims that are the result of an Act of

God, unless we can demonstrate, by claims frequency or otherwise, that you have failed to take action reasonably necessary as requested by us to prevent recurrences of damage to the insured property.

2. on the basis of filing claims for partial loss caused by sinkhole damage or clay shrinkage, regardless of whether this policy has been the subject of a sinkhole damage or clay shrinkage claim, or on the basis of the risk associated with the occurrence of such claim. However, we may non-renew or discontinue this policy if:

a) the total of such property claim payments for this policy exceeds the current policy limits of coverage for property damage; or

b) you have failed to repair the structure in accordance with the engineering recommendations upon which any loss payment or policy proceeds were based.

3. on the basis of a single claim on a property insurance policy which is the result of water damage unless we can demonstrate you have failed to take action reasonably requested by us to prevent a future similar occurrence of damage to the insured property.

Concealment Or Fraud This policy is void if it was obtained by misrepresentation, fraud or concealment of material facts. If it is determined that this policy is void, all premiums paid will be returned to you since there has been no coverage under this policy.

We do not cover any loss or occurrence in which any insured person has concealed or misrepresented any material fact or circumstance.

What Law Will Apply This policy is issued in accordance with the laws of Florida and covers property or risks principally located in Florida. Subject to the following paragraph, the laws of Florida shall govern any and all claims or disputes in any way related to this policy.

If a covered loss to property, or any other occurrence for which coverage applies under this policy happens outside Florida, claims or disputes regarding that covered loss to property, or any other covered occurrence may be governed by the laws of the jurisdiction in which that covered loss to property, or other covered occurrence happened, only if the laws of that jurisdiction would apply in the absence of a contractual choice of law provision such as this.

Where Lawsuits May Be Brought Subject to the following two paragraphs, any and all lawsuits in any way related to this policy, shall be brought, heard and decided only in a state or federal court located in Florida. Any and all lawsuits against persons not parties to this policy but involved in the sale, administration, performance, or alleged breach of this policy, or otherwise related to this policy, shall be brought, heard and decided only in a state or federal court located in Florida, provided that such persons are subject to or consent to suit in the courts specified in this paragraph.

If a covered loss to property, or any other occurrence for which coverage applies under this policy happens outside Florida, lawsuits regarding that covered loss to property, or any other covered occurrence may also be brought in the judicial district where that covered loss to property, or any other covered occurrence happened.

Nothing in this provision, Where Lawsuits May Be Brought, shall impair any party’s right to remove a state court lawsuit to a federal court.

Homeowners Policy Broad

Policy number: 988 870 728

Policy effective date: July 23, 2022

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Section I—Your Property

Dwelling Protection–Coverage A

Property We Cover Under Coverage A:

1. Your dwelling including attached structures. Structures connected to your dwelling by only a fence, utility line or similar connection are not considered attached structures.

2. Construction materials and supplies at the residence premises for use in connection with your dwelling.

3. Wall-to-wall carpeting fastened to your dwelling.

Property We Do Not Cover Under Coverage A:

1. Any structure including fences or other property covered under Other

Structures Protection–Coverage B.

2. Land.

3. Satellite dish antennas and their systems, whether or not attached to your dwelling.

Other Structures Protection–Coverage B

Property We Cover Under Coverage B:

1. Structures at the address shown on the Policy Declarations separated from your dwelling by clear space.

2. Structures attached to your dwelling by only a fence, utility line or similar connection.

3. Construction materials and supplies at the address of the residence premises for use in connection with structures other than your dwelling.

4. Wall-to-wall carpeting fastened to other building structures.

Property We Do Not Cover Under Coverage B:

1. Structures used in whole or in part for business purposes.

2. Any structure or other property covered under Dwelling Protection– Coverage A.

3. Construction materials and supplies at the address of the residence premises for use in connection with the dwelling.

4. Land.

5. Satellite dish antennas and their systems, whether or not attached to building structures.

Losses We Cover Under Coverages A and B:

We will cover sudden and accidental direct physical loss to property described in Dwelling Protection–Coverage A and Other Structures Protection–Coverage B except as limited or excluded in this policy.

Losses We Do Not Cover Under Coverages A and B:

We do not cover loss to the property described in Dwelling Protection– Coverage A or Other Structures Protection–Coverage B consisting of or caused by:

1. Flood, including, but not limited to, surface water, waves, tidal water or overflow of any body of water, or spray from any of these, whether or not driven by wind.

2. Water or any other substance that backs up through sewers or drains.

3. Water or any other substance that overflows from a sump pump, sump pump well or other system designed for the removal of subsurface water which is drained from a foundation area of a structure.

4. Water or any other substance on or below the surface of the ground, regardless of its source. This includes water or any other substance which exerts pressure on, or flows, seeps or leaks through any part of the residence premises.

We do cover sudden and accidental direct physical loss caused by fire, explosion or theft resulting from items 1. through 4. listed above.

5. Earth movement of any type, including, but not limited to, earthquake, volcanic eruption, lava flow, landslide, subsidence, mudflow, pressure, sinkhole, erosion or the sinking, rising, shifting, creeping, expanding, bulging, cracking, settling or contracting of the earth. This exclusion applies whether or not the earth movement is combined with water.

Earth movement does not include catastrophic ground cover collapse.

We do cover sinkhole activity when Sinkhole Activity Coverage is shown on the Policy Declarations.

We do cover sudden and accidental direct physical loss caused by fire, explosion, theft or breakage of glass or safety glazing materials resulting from earth movement.

6. Enforcement of any building codes, ordinances or laws regulating the construction, reconstruction, maintenance, repair, placement or demolition of any building structure, other structure or land at the residence premises, except as specifically provided in Section I, Additional Protection under item 10., Building Codes.

We do cover sudden and accidental direct physical loss caused by actions of civil authority to prevent the spread of fire.

7. The failure by any insured person to take all reasonable steps to save and preserve property when the property is endangered by a cause of loss we cover.

8. Any substantial change or increase in hazard, if changed or increased by any means within the control or knowledge of an insured person.

9. Intentional or criminal acts of, or at the direction of, any insured person, if the loss that occurs:

a) may be reasonably expected to result from such acts; or

b) is the intended result of such acts.

Homeowners Policy Broad

Policy number: 988 870 728

This exclusion applies regardless of whether or not the insured person is actually charged with, or convicted of a crime.

10. Nuclear action, meaning nuclear reaction, discharge, radiation or radioactive contamination, or any consequence of any of these.

Loss caused by nuclear action is not considered loss by fire, explosion or smoke.

We do cover sudden and accidental direct physical loss by fire resulting from nuclear action.

11. War or warlike acts, including, but not limited to, insurrection, rebellion or revolution.

12. Collapse, except as specifically provided in Section I, Additional Protection under item 12., Collapse.

13. Soil conditions, including, but not limited to, corrosive action, chemicals, compounds, elements, suspensions, crystal formations or gels in the soil.

14. Vapors, fumes, acids, toxic chemicals, toxic gasses, toxic liquids, toxic solids, waste materials or other irritants, contaminants or pollutants.

In addition, we do not cover loss consisting of or caused by any of the following:

15. a) wear and tear, aging, marring, scratching, deterioration, inherent vice, or latent defect;

b) mechanical breakdown;

c) growth of trees, shrubs, plants or lawns whether or not such growth is above or below the surface of the ground;

d) rust or other corrosion;

e) contamination, including, but not limited to, the presence of toxic, noxious or hazardous gasses, chemicals, liquids, solids or other substances at the residence premises or in the air, land or water serving the residence premises;

f) smog, smoke from the manufacturing of any controlled substance, agricultural smudging and industrial operations;

g) settling, cracking, shrinking, bulging or expansion of pavements, patios, foundations, walls, floors, roofs or ceilings;

h) insects, rodents, birds or domestic animals. We do cover the breakage of glass or safety glazing materials caused by birds; or

i) seizure of covered property by government authority.

If any of a) through h) cause the sudden and accidental escape of water or steam from a plumbing, heating or air conditioning system, household appliance or fire protective sprinkler system within your dwelling, we cover the direct physical damage caused by the water or steam. If loss to covered property is caused by water or steam not otherwise excluded, we will cover the cost of tearing out and replacing any part of your dwelling necessary to repair the system or appliance. This does not include damage to the defective system or appliance from which the water escaped.

16. Freezing of plumbing, fire protective sprinkler systems, heating or air conditioning systems or household appliances, or discharge, leakage or overflow from within the systems or appliances caused by freezing, while the building structure is vacant, unoccupied or being constructed unless you have used reasonable care to:

a) maintain heat in the building structure; or

b) shut off the water supply and drain the system and appliances.

17. Freezing, thawing, pressure or weight of water or ice, whether driven by wind or not. This exclusion applies only to fences, pavements, patios, swimming pools, foundations, retaining walls, bulkheads, piers, wharves or docks.

18. Seepage, meaning continuous or repeated seepage or leakage over a period of weeks, months or years, of water, steam or fuel:

a) from a plumbing, heating, air conditioning or automatic fire protection system…