Monday, May 16, 2022

4 + 2 ≠ "Residence Premises"

Last week I received a favorable decision and order for one of my insurer clients from the United States District Court for the Southern District of New York in a number-of-families homeowners policy application misrepresentation case. My client had denied coverage for the Brooklyn, NY fire loss based, in part, on the application misrepresentation but did not rescind the homeowners policy (that's a thing). I conducted the policyholder's EUO and defended the policyholder's subsequent breach of contract action.

The Decision & Order begins:
The material facts, which cannot be disputed, are simple: In his insurance application, plaintiff stated that his property had three units, with three families living in them. The policy that Nationwide issued to him covered "one, two, three or four-family" dwellings. In fact, plaintiff's building had at least six units, rented to unrelated tenants. After the fire, Nationwide discovered the additional units and denied coverage. As explained below, Nationwide was entitled to do so and consequently will be granted summary judgment.
And adds:
Plaintiff contends that the language of the Policy is ambiguous, preventing the Court from granting summary judgment. * * * He argues that because the Policy uses the term “one, two, three, or four family dwelling” rather than “one, two, three, or four unit building,” it is irrelevant that there were at least six separate residential units in the Subject Premises. ***

Neither logic nor precedent supports plaintiff's hair-splitting argument. To the contrary: the New York courts have repeatedly explained that terms like “four family dwelling” are unambiguous. 
The Court granted summary judgment to Nationwide based solely on the uncontroverted fact that at the time of the fire, the dwelling did not meet the policy's definition of a "residence premises" (because it was MORE than a four-family dwelling).

The Court also rejected plaintiff's negligence argument (viz, that Nationwide could've and should've discovered the extra, illegal apartments before the fire) and, given its ruling on the residence premises issue, did not reach Nationwide's alternative argument that the Policy was void because plaintiff intentionally misrepresented the material fact or circumstance of how many families lived within and how many units comprised the Subject Premises at the time he filled out his application.

You can read the decision by clicking the image below:



Monday, May 9, 2022

Scope of Appraisal vs. Appraisal of Scope -- New York

There has been a good deal of conflicting case law over the years over what kinds of property loss disputes are and are not amenable to the appraisal process. This post discusses four of those court decisions and concludes with what I think is the current state of the law in New York on the proper scope of property loss appraisals.

425 West Main Associates LP v. Selective Insurance Company of South Carolina 
(Supreme Court, Genesee Co., 2018)

The policyholder, 425 West Main Associates LP commenced this special proceeding to compel an appraisal of its reported roof damage/loss claim.  The policyholder claimed that on March 8, 2017, the roof of its commercial premises was damaged as a result of wind and weight of ice and snow, which resulted in further damage to the interior of the premises. 

425 West Main hired National Fire Adjustment Company, Inc. (NFA) to assist in determining the damage and submitting claims to its insurer, Selective Insurance Company, for replacement of the roof and repair for the interior of the building. After NFA's analysis, 425 West Main claimed damages of more than $530,000.00.

425 West Main's wind damage claim was tendered to Selective on March 22, 2017. Before Selective's inspection of the property, a roofer had already removed the allegedly wind-damaged roofing and made temporary repairs. Selective inspected the roof on March 28, 2017.  Selective's general adjuster indicated that tenants of the property had advised him that they were experiencing leaking and staining of ceiling tiles before the date of loss. Furthermore, a forensic engineer concluded the defects in the roofing system were caused by long-term deterioration as opposed to a wind event.

On April 12, 2017, Selective sent 425 West Main a detailed letter and the engineering report advising 425 West Main of the basis for covering only a portion of the roof. Selective denied coverage for the full replacement of the roof on the ground that the damage was not caused by wind, but rather wear and tear or deterioration. Selective would only cover the cost to tarp and patch one section of the roof, and replace only the membrane of that section.

On October 24, 2017, 425 West Main demanded an appraisal pursuant to the policy. The policy provided:
If we and you disagree on the value of the property, the extent of the loss or damage or the amount of the loss or damage, either may make a written demand for an appraisal of the loss. In this event, each party will select a competent and impartial appraiser and notify the other of the appraiser selected within twenty days of such demand.
After 425 West Main demanded the appraisal on October 24, 2017, Selective advised 425 West Main in a November 6, 2017 letter that it would not proceed with appraisal. Selective claimed that the dispute was not subject to the appraisal condition in the policy because it did not involve the value of the property or the extent or amount of the loss or damage. Instead, Selective claimed, the dispute centered on the cause of the loss or damage and whether it is covered under the policy.

In DENYING the policyholder's petition to compel appraisal and dismissing the special proceeding, Supreme Court Justice Henry Nowak ruled:
    425 West Main claims that Selective's refusal is a mere pretext to refuse to engage in the appraisal pursuant to the policy and unnecessarily delay providing 425 West Main the insurance proceeds to which it is entitled. Selective contends that the property is not an appropriate candidate for appraisal because the very legitimacy of 425 West Main's claim remains in dispute. Insurance Law § 3408(c) provides that the appraisal provision in a policy triggers only where there is a "covered loss," and specifically prohibits appraisal to "determine whether the policy actually provides coverage for any portion of the claimed loss or damage" (see also Pilkenton v New York Cent. Mut. Fire Ins. Co., 112 AD3d 1327 [4th Dept 2013]). 425 West Main claims that because Selective agreed to cover a portion of the roof, it constitutes a "covered loss" thereby subjecting Selective to the appraisal provision.

    In Louati v State Farm Fire & Cas. Co., 161 AD3d 701, 702 (1st Dept 2018), the parties disputed whether water damage on the floor of a bathroom at the petitioner's premises "was caused by a burst pipe (a covered cause of loss) or by another, excluded cause." The parties also disputed whether it was necessary to retile the entire first floor when the covered loss directly affected only the bathroom (id.). The petitioner sought to conduct an appraisal for the property, all while respondent opposed the appraisal until the cause of the damage could be resolved (id.). The trial court denied the motion to compel the appraisal in order to await resolution of the coverage issues in a plenary action, and the Appellate Division unanimously affirmed (id.).

    Similarly, in this action, significant coverage issues exist as to the cause of the loss in this case — whether it was damage created as a result of the windstorm or long-term water infiltration. As in Louati, this court denies the petition to compel the appraisal and dismisses the proceeding without prejudice after resolution of the coverage issues in a plenary action.
On January 31, 20202, the Fourth Department unanimously affirmed Justice Nowak’s order “for reasons stated in the decision at Supreme Court.” On March 11, 2020, the policyholder plaintiff moved the Fourth Department for leave to appeal to the New York Court of Appeals. On July 17, 2020, the Fourth Department denied that motion and, as far as I can tell, the policyholder did not move the Court of Appeals for leave to appeal, ending that action.

Phillips v. New York Central Mut. Fire Ins. Co. 
(Index. No. 811860/2021 [Sup. Ct., Erie Co., 2021])

In this case, which involved a reported hail damage/roof claim, Erie County Supreme Court Justice Donna Siwek DENIED the policyholder's motion for an order under Insurance Law § 3408 compelling appraisal, reasoning:
    We have considered all the papers submitted in this matter, including the affidavits and a Memoranda of Law and find that the issue between Petitioner and Respondent involves a question of coverage, and as a result, the Petition to compel appraisal is denied without prejudice until the coverage issues are resolved. It is not disputed that an appraisal may only be invoked to examine and or consider "the extent of the loss or damage and the amount of the loss" when there are no coverage issues involved. If any portion of the claimed loss or damage involves a coverage issue, that issue may not be determined through the appraisal process. Insurance Law §3408 is clear that the appraisal process cannot be utilized to determine a coverage issue. We agree with Respondent that the question of whether there is coverage for replacing the three sides of the house that were not damaged as a result of the hailstorm is a coverage issue. The New York Central policy language requires the carrier to pay Petitioner for the replacement cost "of that part of the building damaged with material of like kind and quality and for like use". (See Respondent's Exhibit '"A", Section I - CONDITIONS, C. Loss Settlement 2. a. (2)., NYSCEF Document # 15)

    In the absence of any damage to the other three sides of the homes' siding, we agree with the carrier that there is a question as to whether or not the coverage requires New York Central to pay to replace the undamaged portions of the siding because it will no longer match the north side of the home that was actually damaged and for which New York Central will pay to replace with siding of "like kind and quality and for like use". Respondent takes the position that providing matching siding for purposes of aesthetics is not covered under the policy. We agree that this issue requires a coverage determination. The language the policy provision's need to be interpreted by a court in order to resolve the parties' dispute. The coverage questions to be answered include:
  • What constitutes a "direct physical loss" under the policy?
  • Does the policy require New York Central to replace the undamaged siding because it will no longer match the new siding?
  • Does the coverage preclude payment for the non-damaged siding due to policy exclusions for "wear and tear", .., deterioration and the "'inherent vice" existent in the building materials?
  • Does the policy language which requires New York Central to replace the siding with "material of like kind and quality and for like use" require New York Central to pay for the three undamaged sides because they can not match up the old siding with "material of like kind and quality"?
    Where a parties' dispute is essentially a difference regarding coverage, the request for appraisal should be denied. See, Kawa v. Nationwide, l 74 Misc.2d 407 (S. Ct. Erie Co. 1997); Duane Reade, Inc. v. St. Paul Fire & Marine Ins. Co., 411 F.3d 384 (2d Cir. 2005); Indian Chef Inc. v. Fire & Cas. Ins. Co. of Connecticut, 2003 WL 329054 (SDNY Feb. 13, 2003).
The policyholder in Phillips did not appeal Justice Siwek’s corresponding order.

(Supreme Court, Tompkins Co., 2017)

Policyholder counsel and public adjusters are fond of citing this decision, thinking it provides more than, in my opinion, it actually does.  In GRANTING the policyholder’s petition to compel and ordering Dryden Mutual to proceed with an appraisal of the homeowner insureds’ vandalism claim, Justice Rumsey held:
    Notably, respondent has not denied liability for damages sustained in the vandalism incident and it does not identify any policy provisions that need to be interpreted by the court to resolve the parties' dispute. Rather, it is clear from the parties' respective submissions that the basis for respondent's objections to an appraisal is limited to the extent of work required to repair the damage caused by the vandalism incident. Such disputes "are factual questions that fall squarely within the scope of the policy's appraisal clause" (Quick Response Commercial Div., LLC v Cincinnati Ins. Co., 2015 WL 5306093, *3, 2015 US Dist LEXIS 120415, *8 [ND NY, Sept. 10, 2015, No. 1:14-cv-779 (GLS/DEP)] [citations omitted] [applying New York law]; see also Hyman, 2016 NY Slip Op 32700[U], *2, quoting Quick Response). Respondent cites Kawa v Nationwide Mut. Fire Ins. Co. (174 Misc 2d 407 [1997]) for the proposition that a dispute over whether it was necessary to repair or replace the house siding is one involving the scope of coverage. However, in Kawa, the fundamental dispute was not the extent of necessary repairs; rather, it was one of causation, namely, whether the condition of the aluminum siding on the home was a result of improper maintenance that had been performed prior to the windstorm incident, or whether it resulted from the insured's efforts to secure the siding during the windstorm, and the court held that the issue of causation was incidental to an underlying legal controversy regarding the meaning of the policy and its application to the facts (see Kawa, 174 Misc 2d at 408-409).

    In sum, issues of causation relate to the scope of coverage, which is not a proper subject for an appraisal, and issues regarding the extent of necessary repairs involve valuation of damages, which are properly submitted for an appraisal. This conclusion is supported by the persuasive and extensive analysis set forth in Lee v California Capital Ins. Co. (237 Cal App 4th 1154, 1170-1173, 188 Cal Rptr 3d 753, 764-767 [2015]), in which the court held, like the court in Kawa, that issues of causation are not properly submitted to appraisal because they involve the scope of coverage, while the issue of whether property was damaged at all is properly determined by the appraisers, because the scope of repairs made necessary by a covered loss, and the cost of any such repairs, directly bear upon the valuation of the loss.[2]
Kawa v. Nationwide was my case, by the way. I’ve been litigating issues relating to property insurance policies appraisal clause since 1995.

Dryden Mutual appealed Pottenburgh to the Third Department, and in October 2017, the Third Department affirmed the trial court’s decision. I can’t give you a Google Scholar address for that decision, because the very next month, Dryden moved to vacate that appellate decision, which the Third Department granted, leaving Supreme Court’s decision in place.

Whatever you think of the trial-level Pottenburgh decision, note that it does explicitly state that “issues of causation relate to the scope of coverage, which is not a proper subject for an appraisal[.]”

(161 AD3d 701, 702 (1st Dept 2018)

In this case, the parties disputed whether water damage on the floor of a bathroom at the policyholder's premises "was caused by a burst pipe (a covered cause of loss) or by another, excluded cause." The parties also disputed whether it was necessary to retile the entire first floor when the covered loss directly affected only the bathroom.  The policyholder sought to conduct an appraisal for the property, and State Farm opposed the appraisal until the cause of the damage could be resolved. The trial court DENIED the motion to compel the appraisal in order to await resolution of the coverage issues in a plenary action, and the Appellate Division unanimously AFFIRMED, holding: 
    The court correctly found that policy coverage issues exist that must be resolved before an appraisal can proceed (see Insurance Law § 3408 [c]).

    An issue exists as to whether the water damage on the floor of the first-floor bathroom was caused by a burst pipe (a covered cause of loss) or by another, excluded cause (see Matter of Pottenburgh v Dryden Mut. Ins. Co., 55 Misc 3d 775, 778 [Sup Ct, Tompkins County 2017], citing Kawa v Nationwide Mut. Fire Ins. Co., 174 Misc 2d 407, 408-409 [Sup Ct, Erie County 1997]). An issue also exists as to whether petitioner's failure to retain the floor tiles for inspection is a basis to deny coverage (see Fuchs v Sun Ins. Off., Ltd., 149 Misc 600, 600-601 [Mun Ct, NY County 1933], citing Johnson v Hartford Fire Ins. Co., 94 Misc 163, 167 [App Term, 1st Dept 1916]).

    However, to the extent the parties dispute whether it was necessary to re-tile the entire first floor when the covered loss directly affected the bathroom only, or whether it was necessary to replace any floor tiles given respondent's failure, upon inspection, to observe any damage to the floor, these disputes present factual questions that are properly decided in an appraisal (see Pottenburgh, 55 Misc 3d at 777-778; Quick Response Commercial Div., LLC v Cincinnati Ins. Co., 2015 WL 5306093, *3-4, 2015 US Dist LEXIS 120415, *6-9 [ND NY, Sept. 10, 2015, No. 1:14-cv-779 (GLS/DEP)]).

* * * CONCLUSION* * *

In my opinion (which you should not necessarily rely on because this blog DOES NOT GIVE OR REPRESENT LEGAL ADVICE [see the footer of this page]), the current state of the case law in New York on the proper scope of appraisal is:
  • coverage questions or issues—including questions of covered versus non-covered or excluded causes of loss (i.e., causation issues)—are not amenable to the appraisal process; but
  • disputes over the extent of a covered loss, or whether damaged property can be repaired or must be replaced (which the Pottenburgh court called the “scope of repairs”), appear to be amenable to the appraisal process.
So, if your loss involves causation and/or exclusion-based disputed coverage issues and defenses, it falls squarely in the not-amenable-to-appraisal category. So say all four of the above-discussed decisions.  

Monday, May 2, 2022

Discord and Discourse With a Florida Public Adjuster About His "5 Ways to Trick an Insurance Claims Adjuster"

 


Florida public adjuster Mike Keeler believes his own messaging.  At least he seems to do so.

I was looking for content for my "So, You're About to Be Deposed (Or Violently Overthrown): How Should You Prepare and What Should You Expect" presentation tomorrow at NEIASIU's 15th Annual Joint Training Seminar in Massachusetts, when I came YouTube returned this video (click the image above to view) in my "depositions of insurance adjuster" search results.  

Those of you who know me know I couldn't resist--both watching the video and dropping a comment onto it.

"Trick No. 4", according to Mike is:

If they ask you for a recorded statement, all right, when you're going through a recorded statement they usually try to pin you down as to what happened. You play dumb. When did this happen? Um, and let's say the claim was two months ago. Well, I don't remember. I just know I have a leak. And why did you wait two weeks to report it? Well I was trying to attend to the leak. You keep everything simple. Keep everything very simple. Brief. Use I don't remember exactly. When they ask for a time, I don't remember exactly, maybe sometime in the afternoon. I, I really don't know. All right so you use that quite a bit because you want to preserve your rights to pursue the claim. You don't want to get boxed in. You don't want to say something that you might regret. Something that may hurt your claim. So use I don't know exactly as one of your main phrases to answer when a recorded statement, okay?  When did you roof get damaged? I don't know exactly. When did you notice the first ceiling? You know, I don't know exactly. I can't give you a date cause I give you a date it may be off. Those are examples.

Mike also seems to be a "last word" kinda guy, but it's his YouTube channel so I have no complaint with that.  For your entertainment, my initial comment to Mike's video and the discourse that followed are as follows: 

Roy A. Mura
Saying "I don't know exactly when the [loss] occurred" when an insured, in fact, knows exactly when the loss occurred IS a misrepresentation and possible fraudulent statement, voiding insurance coverage, if the loss date/time is relevant (material) to the insurance company's investigation and determination of coverage. Same goes for how a loss occurred. I understand you're trying to sell your public adjusting services by scaring people into thinking their insurance companies are out to screw them, but telling (and trying to teach) them to "trick" their insurance adjusters does a disservice to yourself, your profession, the industry in general, and your prospective customers. Be careful, people.
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The Claim Squad Public Adjusters
Can you please point to any statute in any state that clearly reads someone can't say the exact date of loss in an insurance claim? Please point to any insurance policy that states the same. I love how you insurance company people get all upset when someone is actually helping and protecting people from insurance companies because of how they treat people. You insurance company people always say if you say that or don't say that it's Fraud , a misrepresentation, LOL No it's not. You should be paying people's claims and stop screwing people rather than watching my videos.
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Roy A. Mura
 @The Claim Squad Public Adjusters  Why don't you ask your regulator, the FL DFS, what it thinks of telling insureds never to tell the truth even if they know the truth about an exact date or cause of loss. But since you asked, FL Statutes § 817.234 states: (1)(a) A person commits insurance fraud punishable as provided in subsection (11) if that person, with the intent to injure, defraud, or deceive any insurer: 1. Presents or causes to be presented any written or oral statement as part of, or in support of, a claim for payment or other benefit pursuant to an insurance policy or a health maintenance organization subscriber or provider contract, knowing that such statement contains any false, incomplete, or misleading information concerning any fact or thing material to such claim; 2. Prepares or makes any written or oral statement that is intended to be presented to any insurer in connection with, or in support of, any claim for payment or other benefit pursuant to an insurance policy or a health maintenance organization subscriber or provider contract, knowing that such statement contains any false, incomplete, or misleading information concerning any fact or thing material to such claim[.] Saying one doesn't know exactly when or how a loss occurred is a "false, incomplete, or misleading" statement if the insured knows exactly the date or loss, right? There's the statute for you. Surprised you don't know the insurance fraud law that exists in the state in which you are licensed, Mike. You should be telling your clients to tell the truth and cooperate with their insurers' loss/claim investigations rather than telling them how to "trick" their insurers' adjusters.
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The Claim Squad Public Adjusters
 @Roy A. Mura  Boy you insurance company adjusters love to fabricate stories Saying "I don't know" on a date of loss is NOT fraud Just like when my partnering attorneys take depositions of insurance company adjusters like you and during the deposition it is asked " What is your reserve on the claim" answer from guys like you "I don't know I don't remember" Or how about this classic last week my attorneys took deposition of State Farm adjuster for cast iron pipe "did you tell the insured that cast iron pipes are not covered because they sent you an email explaining their confusion" Ron C the adjuster from State Farm stated under oath in deposition "I don't recall" Now again Mr Insurance Adjuster guy you barking up the wrong tree because all you guys should be in jail for what you do to people. But I do thank you because if it wasn't for guys like you and the insurance companies you work for I wouldn't have a job. Seriously, I thank you from bottom of my heart. Keep treating people like crap so I can have continued job security.
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Roy A. Mura
 @The Claim Squad Public Adjusters  Typical public adjuster (policyholder and personal injury attorney) messaging. Gotta maintain the bogeyman myth.
Roy A. Mura
Mike, I presume you know that a lie, as opposed to a mistake, is a knowing misrepresentation with an intent to deceive, right? Big difference. Everyone makes mistakes. Lying to one's insurer can void coverage (and result in criminal charges in some states, like FL apparently). That's all I'm saying. Honest people don't need to be shown a statute to know this. By the way, I did watch your video. You said at 5:02: "The public adjuster's fees are irrelevant because if you have a good public adjuster, they're going to be able to get a larger settlement to cover his fees, your damages and then some." Wait. You mean that PAs exaggerate or inflate insureds' damages so that insurers pay more than the insureds' damages "to cover [your] fees, [the insureds'] damages and then some"? That's legal in Florida? Yowza.
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The Claim Squad Public Adjusters
 @Roy A. Mura  Mr Insurance Company Adjuster Claims 101 Settlements by way of lawsuit and/or pre-lawsuit by a good PA and/or attorney will get people plenty to fix things , cover attorney and/or PA fees, and many times they do have money left over. Here's the great part, this has been going on for over 100 years in FL since 1893 when the law changed in FL forcing insurance companies to pay legal fees Lol Boy you insurance company adjusters don't really know the law do you? Lol See PAs need to know case law and how to get around policy language. Anything else I can teach you today? I know it's confusing for insurance adjusters like you but try to stay with me. Btw, did you also know FL has a great bad faith statute that protects people? We settled one end of March $38,000 Guess what? The client gets 100% of that less my fees. So yes they do get more than their damages...it's a great thing when we can nail guys like you and the insurance company you work for. We got another dandy Bad Faith Lawsuit coming up against the carrier but we also naming the adjuster and umpire personally from the appraisal in the lawsuit. It's a beautiful thing :)
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The Claim Squad Public Adjusters
Here's another great video "3 people you should never trust in the claim process"...Hint:. You Mr Insurance Adjuster are one of them ;) https://youtu.be/UrfZ3jiQRVU
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Roy A. Mura
Mike, just stop. You're embarrassing yourself now. And btw, you may be getting some more views (and comments) on this video. I posted it to my LinkedIn page. You're welcome.
The Claim Squad Public Adjusters
 @Roy A. Mura  great looking forward to interacting with more "fraud" attorneys like you lol NY with those arbitration clauses Lol What a joke Great to see how you try screwing people
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Roy A. Mura
Be careful what you wish for, Mike. Given your views and how-to tips on "tricking" claim adjusters, any interaction with insurance fraud attorneys like me might not turn out well for you or your clients. Thank you for your revealing content, though. I'll make good use of it.
The Claim Squad Public Adjusters
 @Roy A. Mura  ooookkk lol Interesting "threat" documented. Make sure you don't advise your clients to say "i don't know" "i don't remember" when they actually do. Not sure it's best for an insurance company attorney to be conversing with a public adjuster but keep on screwing people up in NY and I'll keep on fighting people in FL. Cheers
Roy A. Mura
Funny you should mention the "I don't know" and "I don't recall" deposition responses. I'm speaking to a bunch of insurance fraud investigators and claims professionals tomorrow in Massachusetts on the subject of deposition preparation. The IDK and IDR responses are the middle and ring finger responses and are appropriate responses when true. Have you ever been deposed? If so, have you never said "I don't know" or "I don't recall" while under oath? I converse with PAs all the time, but none quite as interesting, sophomoric and polar as you, Mike.
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The Claim Squad Public Adjusters
 @Roy A. Mura  Thanks for the compliment. Ahh the ole tailor the excuse based on environment lol. Yes, IDK & IDR very appropriate for insurance adjusters but not homeowners lol I get it. Nah, unlike most PAs I have a little bit of a legal backgrround...I get on record do my 5 min spiel on I get paid an expert fee, I am an expert, etc...then I leave the depo. Attorneys list me as expert. In times, prior to trial IF def attorneys like you try to argue differently that I'm fact witness based on my statement at depo we win every time. Although only been a few times we had to carry out and def attny file motion. Anyhow, you have yourself a wonderful day protecting insurance companies and hurting homeowners. I'll continue to fight for people.
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Roy A. Mura
I wasn't complimenting you, Mike, and you continue to miss the point. But I understand why. Your distorted view of insurance companies won't allow you to see and understand why saying something that's not true, such as "I don't know exactly", could void coverage and constitute insurance fraud under FL law. Do you (or the attorneys you say hire you as an "expert") not realize that videos like this one provide rich material for cross examination? But keep on creating content. The industry appreciates it.
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The Claim Squad Public Adjusters
 @Roy A. Mura  Roy you continue to view things from the very perspective that pays all your hefty bills ie insurance companies I don't hire attorneys as experts Never said I do I'm the expert. Attorneys in Florida are referred cases from public adjusters. How can you CE someone when they not deposed? Lol Trial? Been tried before ...didn't work Trust me I would never want an insurance paid biased attorney to compliment me...that's when I know it's time to quit the industry. And don't worry I don't compliment guys like you who intentionally try to hurt people. "Don't hate the player, hate the game"
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The Claim Squad Public Adjusters
 @Roy A. Mura  btw I've received 3 emails from people today who have some choice words for you...people watching you lol

Mike doth protest too much, methinks. I've never liked the "you need to hire me because the insurance company is going to screw you" sales pitch, and thought most public adjusters had abandoned it years ago.  Most but not all, I see.  

And I hope the three people who emailed Mike with "choice words" for me chose their words more carefully than Mike does.  Encouraging insureds to "trick" their insurance companies' adjusters sounds to me an awful lot like promoting insurance fraud at worst, or coverage-voiding conduct at best.