DEFENDANTS MOTION TO COMPEL BETTER RESPONSES TO REQUESTS FOR ADMISSIONS AND OVERRULE OBJECTIONS April 01, 2020 (2024)

 
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 Filing # 105755370 E-Filed 04/01/2020 06:02:07 PMIN THE CIRCUIT COURT OF THESEVENTH JUDICIAL CIRCUIT IN ANDFOR FLAGLER COUNTY, FLORIDACASE NO.: 2018-CA-000671ASSET PROTECTION GROUP, LLC (DavidMartin),Plaintiff,v.SECURITY FIRST INSURANCE COMPANY,Defendant./DEFENDANT’S MOTION TO COMPEL BETTER RESPONSES TOREQUESTS FOR ADMISSIONS AND OVERRULE OBJECTIONSCOMES NOW Defendant, SECURITY FIRST INSURANCE COMPANY, by andthrough its undersigned counsel, and pursuant to the Florida Rule of Civil Procedurehereby files this Motion To Compel Better Responses To Requests For Admissions AndOverrule Objections, and as grounds states as follows:1. On or about 01/14/2020 Defendant served their First Request for Admissionsto Plaintiff. See Exhibit “A.”2. On or about 02/11/2020 Plaintiff filed its Response to Defendant's Request forAdmissions. See Exhibit “B.”3. Aparty may serve upon any other party a written request for the admission ofthe truth of any matters within the scope of rule 1.280(b) set forth in the request that relateto statements or opinions of fact or of the application of law to fact, including the genuine-ness of any documents described in the request. Copies of documents shall be servedwith the request unless they have been or are otherwise furnished or made available forinspection and copying. Fla. R. Civ. P. Section 1.370(a).COLE, SCOTT & KISSANE, P.A.COLE, SCOTT & KISSANE BUILDING - 4686 SUNBEAM ROAD - JACKSONVILLE, FLORIDA 32257 - (904) 672-4000 (904) 672-4050 FAXElectronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 04/03/2020 06:31 AMCASE NO.: 2018-CA-0006714. Parties may obtain discovery regarding any matter, not privileged, that is rele-vant to the subject matter of the pending action, whether it relates to the claim or defenseof the party seeking discovery or the claim or defense of any other party, including theexistence, description, nature, custody, condition, and location of any books, documents,or other tangible things and the identity and location of persons having knowledge of anydiscoverable matter. Fla. R. Civ. P. 1.280(b)(1).5. It is not ground for objection that the information sought will be inadmissible atthe trial if the information sought appears reasonably calculated to lead to the discoveryof admissible evidence. Id.6. An “answer shall specifically deny the matter or set forth in detail the reasonswhy the answering party cannot truthfully admit or deny the matter. A denial shall fairlymeet the substance of the requested admission, and when good faith requires that a partyqualify an answer or deny only a part of the matter of which an admission is requested,the party shall specify so much of it as is true and qualify or deny the remainder.” Fla. R.Civ. P. 1.370(a).7. Plaintiff's responses to Defendant’s Request for Admissions are invalid, eva-sive, or nonresponsive, specifically, Plaintiff objects on the grounds that the requests are“irrelevant, immaterial, and not likely to lead to admission of evidence.”8. Plaintiff further objects on the basis that the requests are “vague, overly broad,and burdensome,” in addition to stating that the request “does not allow the Plaintiff tounderstand,” as well as the request being “fundamentally unfair to the Plaintiff.”9. There is nothing about Defendant's discovery requests that is so puzzling con-voluted, or open to interpretation as to warrant such evasive or nonresponsive state-ments.10. In fact, Defendant included numerous public records as exhibits that explicitlysupport Defendant’s requests.2COLE, SCOTT & KISSANE, P.A.COLE, SCOTT & KISSANE BUILDING - 4686 SUNBEAM ROAD - JACKSONVILLE, FLORIDA 32257 - (904) 672-4000 (904) 672-4050 FAXCASE NO.: 2018-CA-00067111. Under Florida law, a defense of fraud exists where “a party has sentiently setin motion some unconscionable scheme calculated to interfere with the judicial system’sability impartially to adjudicate a matter by improperly influencing the trier of fact or unfairlyhampering the presentation of the opposing party’s claim or defense.” Cox v. Burke, 706So. 2d 43, 46 (Fla. 5th DCA 1998) (quoting Aoude v. Mobil Oil Corp., 892 F.2d 1115, 1118(1st Cir. 1989)).12. Additionally, the subject insurance policy at issue in this matter contains thefollowing policy language:2. Concealment or Fraud. The entire policy will be void if,whether before or after a loss, an “insured” has:a. intentionally concealed or misrepresented any material factor circ*mstance;b. Engaged in fraudulent conduct; orc. Made false statements;related to this insurance.13. Thus, Defendant's requests are relevant to the subject matter of the pendingaction, but more importantly, related to the defense, as required under the Florida Rulesof Civil Procedure.14. Florida Rule of Civil Procedure 1.380(a)(4) provides that “[i]f the motion isgranted and after opportunity for hearing, the court shall require the party or deponentwhose conduct necessitated the motion....to pay to the moving party the reasonable ex-penses incurred in obtaining the order that may include attorneys’ fees.....” (emphasisadded).15. As Plaintiff's failure to make discovery necessitated the instant motion, Defend-ant hereby requests the Court award Plaintiffs’ reasonable attorneys’ fees and costs, inaccordance with Florida Rule of Civil Procedure 1.380(a)(4).3COLE, SCOTT & KISSANE, P.A.COLE, SCOTT & KISSANE BUILDING - 4686 SUNBEAM ROAD - JACKSONVILLE, FLORIDA 32257 - (904) 672-4000 (904) 672-4050 FAXCASE NO.: 2018-CA-000671CERTIFICATE OF SERVICE| HEREBY CERTIFY that on this 1st day of April, 2020, a true and correct copy ofthe foregoing was filed with the Clerk of Flagler County by using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to the following partiesregistered with the e-Filing Portal system: Scott A. Mager, Esq., Mager Paruas, LLC,Service@mpjustice.com; 2719 Hollywood Blvd., Fl 1, Hollywood, FL 33020, (954) 763-2800/(954) 653-4645 (F), Attorney for Plaintiff, Asset Protection Group, LLC.0504.1753-00/17752027By:COLE, SCOTT & KISSANE, P.A.Counsel for Defendant SECURITY FIRSTINSURANCE COMPANYCole, Scott & Kissane Building4686 Sunbeam RoadJacksonville, Florida 32257Telephone (904) 672-4088Facsimile (904) 672-4050Primary e-mail: bradley. little@csklegal.comSecondary e-mail: christopher.degrottole@csklegal.comAlternate e-mail: hilary.morgan@csklegal.coms/ Christopher M. DeGrottoleBRADLEY LITTLEFlorida Bar No.: 54047CHRISTOPHER M. DEGROTTOLEFlorida Bar No.: 1114514COLE, SCOTT & KISSANE, P.A.COLE, SCOTT & KISSANE BUILDING - 4686 SUNBEAM ROAD - JACKSONVILLE, FLORIDA 32257 - (904) 672-4000 (904) 672-4050 FAXFiling # 101653591 E-Filed 01/14/2020 04:40:31 PMIN THE CIRCUIT COURT OF THESEVENTH JUDICIAL CIRCUIT IN ANDFOR FLAGLER COUNTY, FLORIDACASE NO.: 2018-CA-000671ASSET PROTECTION GROUP, LLC (DavidMartin),Plaintiff,v.SECURITY FIRST INSURANCE COMPANY,Defendant./DEFENDANT’S FIRST REQUEST FOR ADMISSIONSDefendant, SECURITY FIRST INSURANCE COMPANY, (hereinafter “Defendant”)by and through the undersigned counsel, hereby serves ASSET PROTECTIONGROUP, LLC (David Martin) (hereinafter “Plaintiff’) to respond to the followingRequest for Admissions pursuant to Florida Rule of Civil Procedure 1.370:1. Admit that Daniel Sechriest possesses a financial interest in Asset ProtectionGroup, LLC.2. Admit that Gulf Atlantic Industries of America, Inc. is not related or affiliated withGulf Atlantic Industries of America Disaster Relief, LLC. See Exhibit A.3. Admit that Gulf Atlantic Industries of America Disaster Relief, LLC utilized GulfAtlantic Industries of America, Inc.’s logo on their estimates and contracts within thepast (4) years.4. Admit that Gulf Atlantic Industries of America Disaster Relief, LLC utilized GulfAtlantic Industries of America, Inc.’s logo without Gulf Atlantic Industries of America,COLE, SCOTT & KISSANE, P.A.OLE, SCOTT 8 KISSANE BULONG- 4505 SUNBEAIMROKD-sRexsoNV, FLonA se” con oreo eonereaosores EK MIBIT ACASE NO.: 2018-CA-000671Inc.’s permission and/or consent within the past (4) years.5. Admit that Gulf Atlantic Industries of America Disaster Relief, LLC utilized GulfAtlantic Industries of America, Inc’s license without permission and/or consent within thepast four (4) years.6. Admit that Gulf Atlantic Industries of America Disaster Relief LLC displayed GulfAtlantic Industries of America, Inc.’s license on their website within the past four (4)years.7. Admit that Gulf Atlantic Industries of America Disaster Relief LLC performed aroof replacement while the company’s license was inactive within the past (4) years.See Exhibit B.8. Admit that Gulf Atlantic Industries of America Disaster Relief LLC advertised as aroofing contractor without a license within the past four (4) years. See Exhibit B.9. Admit that in 2019, Daniel Sechriest was charged with thirty-two (32) felonies, i.e.Insurance Fraud, Forgery, and Theft by Deception, as well as one (1) misdemeanor, inCumberland County, Pennsylvania (Docket No. CP-21-CR-00030001-2019). SeeExhibit C.10. Admit that in 2019, Daniel Sechriest was charged with three (3) felonies, i.e.False and Fraudulent Insurance Claims, Organized Scheme to Defraud, and UnlicensedAdjusting in Volusia County, Florida (Docket No. 2019 306126 CFDB). See Exhibit D.11. | Admit that Daniel Sechriest does not possess a public adjuster license.12. Admit that Daniel Sechriest prepared, completed, or filed an insurance claim formfor an insured or third-party within the past four (4) years.13. Admit that Daniel Sechriest acted on behalf of, or aided an insured or third-partyCOLE, SCOTT & KISSANE, P.A.COLE, SCOTT & KISSANE BUILDING - 4685 SUNBEAM ROAD - JACKSONVILLE, FLORIDA 32257 - (904) 672-4000 (904) 672-4050 FAXCASE NO.: 2018-CA-000671claimant in negotiating for or effecting the settlement of a claim or claims for loss ordamage covered by an insurance contract within the past four (4) years.14. | Admit that Daniel Sechriest prepared, completed, or filed an insurance claim formfor an insured or third-party claimant for money, commission, or any other thing of valuewithin the past four (4) years.15. Admit that Daniel Sechriest acted on behalf of, or aided an insured or third-partyclaimant in negotiating for or effecting the settlement of a claim or claims for loss ordamage covered by an insurance contract for money, commission, or any other thing ofvalue within the past four (4) years.16. Admit that in 2019, the Department of Business & Professional RegulationFlorida Construction Industry Licensing Board denied Daniel Sechriest a professionallicense. See Exhibit C.17. Admit that Daniel Sechriest falsified, altered, counterfeited, or forged adocument, including checks, contracts, invoices, and/or estimates within the past four(4) years.18. Admit that GSD Construction Services LLC performed construction and/or repairservices within the past four (4) years without a license.19. Admit that GSD Construction Services LLC performed construction and/or repairservices within the past four (4) years without a permit.20. Admit that Gulf Atlantic Industries of America Disaster Relief LLC performedconstruction and/or repair services within the past four (4) years without a license.21. Admit that Gulf Atlantic Industries of America Disaster Relief LLC performedconstruction and/or repair services within the past four (4) years without a permit.COLE, SCOTT & KISSANE, P.A.COLE, SCOTT & KISSANE BUILDING - 4685 SUNBEAM ROAD - JACKSONVILLE, FLORIDA 32257 - (904) 672-4000 (904) 672-4050 FAXCASE NO.: 2018-CA-00067122. Admit that Asset Protection Group LLC performed construction and/or repairservices within the past four (4) years without a license.23. Admit that Asset Protection Group LLC performed construction and/or repairservices within the past four (4) years without a permit.24. Admit that Daniel Sechriest and/or his representatives submitted photographs ofunrelated and/or different properties than the property at issue in an insurance claimwithin the past four (4) years.25. Admit that Daniel Sechriest, within the past four (4) years, submitted invoicesand/or repair estimates to insurance carriers for work that was not completed.26. Admit that representatives of GSD Construction Services LLC, through its agentsand/or representatives, submitted invoices and/or repair estimates to insurance carriersfor work that was not completed within the past four (4) years.27. Admit that Daniel Sechriest submitted invoices and/or repair estimates with theprices redacted to insurance carriers within the past four (4) years.28. Admit that Asset Protection Group LLC, through its agents and/orrepresentatives, submitted invoices and/or repair estimates with the prices redacted toinsurance carriers within the past four (4) years.CERTIFICATE OF SERVICE| HEREBY CERTIFY that on this 14th day of January, 2020, a true and correctcopy of the foregoing was filed with the Clerk of Flagler County by using the FloridaCourts e-Filing Portal, which will send an automatic e-mail message to the followingparties registered with the e-Filing Portal system: Matthew S. Brown, Esq., The BushLaw Group, LLC, MSBROWN@BUSHLAWGROUP.NET;krdupries@bushlawgroup.net,COLE, SCOTT & KISSANE, P.A.COLE, SCOTT & KISSANE BUILDING - 4686 SUNBEAM ROAD - JACKSONVILLE, FLORIDA 32257 - (904) 672-4000 (904) 672-4050 FAXCASE NO.: 2018-CA-0006716622 Southpoint Dr S., Suite 190, Jacksonville, FL 32216, (904) 522-1006, Attorney forPlaintiff, Asset Protection Group, LLC.COLE, SCOTT & KISSANE, P.A.Counsel for Defendant SECURITY FIRSTINSURANCE COMPANYCole, Scott & Kissane Building4686 Sunbeam RoadJacksonville, Florida 32257Telephone (904) 672-4088Facsimile (904) 672-4050Primary e-mail: bradley .litle@csklegal.comSecondary e-mail: christopher.degrottole@csklegal.comAlternate e-mail: hilary. morgan@csklegal.comBy: _s/ Christopher M. DeGrottoleBRADLEY LITTLEFlorida Bar No.: 54047CHRISTOPHER M. DEGROTTOLEFlorida Bar No.: 1114510504. 1753-00/16946672COLE, SCOTT & KISSANE, P.A.COLE, SCOTT & KISSANE BUILDING - 4686 SUNBEAM ROAD - JACKSONVILLE, FLORIDA 32257 - (904) 672-4000 (904) 672-4050 FAXGulf Atlantic Industries of America, Inc.Location of This Business18305 Biscayne Blvd Suite 214, Miami, FL 33160-2172S% Email this BusinessBBB File Opened: 2/23/2005Years in Business: 28Business Started: BI2219HiBusiness Incorporated: = 2/21/1991 in FLAccredited Since: 3/30/2017Type of Entity: CorporationBusiness ManagementMr. Marvin Lebovitz, PresidentAdditional Contact InformationFax Numbers(305) 937-6280Phone Numbers(800) 679-0369Email AddressesEmail this BusinessAdditional Business InformationPlease do not confuse this company with another of a similar name called GulfAtlantic Industries of America Disaster Relief, LLC whose President is listed as DanSechriest. These are two separate companies.Consumers are encouraged to verify all agreements and contracts to make sure theyare dealing with this business, and net one with a similar nameUcensing79-2018 The FiDaniel L Secreplacement aoride Department of Business & Requaton issued a Notke To Cease and Desist toDisaster Rete! rapa ‘amg roofS3g,e8BeSe&z5&s3company contioep R Case No. 2018-034651,68 fo acvertise a8As of 109.2018 the company does not holda license to perform work in Florida. The license that is curently being displayed on the company’sebs ngs tO another companyCOURT OF COMMON PLEAS OF CUMBERLAND COUNTYDOCKETDocket Number: CP-21-CR-0003001-2019CRIMINAL DOCKETCourt CaseCommonwealth of PennsylvaniaveDaniel Lloyd SechriestCASE INFORMATION |judge Assigned: Date Filed: 10/25/2019 initiation Date: 08/05/2019OTN: U 735428-1 LOTN: Originating Docket No: MJ-09101-CR-0000412-2019Initial Issuing Authority: Charles A. Clement Final Issuing Authority: Charles A. ClementArresting Agency: Pennsylvania Office of Attorney General Arresting Officer: Orozco, ChristopherComplainvincident #: 1F20160120Case Local Number Type(s; Case Local Number(s’Page 1 of 4STATUS INFORMATIONCase Status: Active Status Date rocessin: u Complaint Date; 08/05/201910/28/2019 Awaiting Formal Arraignment10/25/2019 Awaiting ARD Hearing10/25/2019 Awaiting Filing of InformationCALENDAR EVENTSCase Calendar Schedule Start Room Judge Name ScheduleEvent Type StartDate Time StatusFormal Arraignment 12/19/2019 9:00. am Jury Assembly ScheduledRoom‘ z f ee DEFENDANT INFORMATION.Date Of Birth: 09/30/1976 City/State/Zip: Columbus, OH 43240CASE PARTICIPANTS.Participant Type NameDefendant Sechriest, Daniel Lioyd‘ : BAIL INFORMATIONSechriest, Daniel Lloyd Nebbia Status: NoneBail Action Ball Type Percentage AmountBail Posting Status Posting Date08/08/2019 Unsecured $25,000.00CHARGESGrade Statute Statute Description Offense Dt. OTNF3 18§ 4117 §§.A2 False/Fraud/incomp Insurance Claim 03/01/2014 =U 735428-1F3 18 § 4117 §§ A2 False/Fraud/incomp Insurance Claim 03/01/2014 U 735428-1F3 48 § 4117 §§ AZ False/Fraud/Incomp Insurance Claim 09/01/2014 =U 738428-1F3 18 § 4117 §§ AZ False/Fraud/incomp Insurance Claim 03/01/2014 UU 738428-4F3 18 § 4117 §§ AZ False/Fraud/Incomp Insurance Claim 03/01/2014 U 735428-1F3 18 § 4147 §§ A2 False/Fraud/Incomp Insurance Claim 03/01/2014 U 736428-1‘CPCMS 9082 Printed: 11/42/2019Recent entries made in the court filing offices may not be immediately reflected on these docket sheets . Neither the courts of the Unified JudicialSystem of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assume any liability for inaccuratgdata, errors or omissions on these reports, Docket Sheet information should not be used in place of a criminal history background cheonly be provided by the Pennsylvania State Police. Moreover an employer who does not comply with the provisions of the Criminal HiInformation Act may be subject to civil lability as set forth in 18 Pa.C.S, Section 9183,COURT OF COMMON PLEAS OF CUMBERLAND COUNTYDOCKETDocket Number: CP-21-CR-0003001-2019CRIMINAL DOCKETCourt CaseCommonwealth of Pennsylvaniav.Daniel Lloyd SechriestCHARGESStatute Statute Description Offense Dt = OTN18 § 4117 §§ A2 False/Fraud/Incomp Insurance Claim 03/01/2014 =U 738428-1Page 2 of 418 § 4117 §§ AZ False/Fraud/Incomp Insurance Claim 03/01/2014 U735428-418 § 4117 §§ AZ False/Fraud/Incomp Insurance Claim 03/01/2014 U 735428-418 § 4117 §§ A2 False/Fraud/Incomp Insurance Claim 03/01/2014 U735428-118§ 4117 §§ A2 False/Fraud/incomp Insurance Claim 03/01/2014 U735428-118 § A117 §§ A2 False/Fraud/incomp Insurance Claim 03/01/2014 U 735428-118 § 4117 §§ A2 False/Fraud/incomp Insurance Claim 03/01/2014 U 735428-418.§ 4117 §§ A2 False/Fraud/incomp Insurance Claim 03/01/2014 U 735428-118§ 4117 §§ A2 False/Fraud/ncomp Insurance Claim 03/01/2014 U735428-118 § 4117 §§ A2 False/Fraud/Incomp Insurance Claim 03/01/2014 U736428-418 § 4101 §§ At Forgery - Alter Writing 03/01/2014 =U 735428-118 § 4101 §§A1 Forgery - Alter Writing 03/01/2014 U 735428-118 § 4101 §§ At Forgery - Alter Writing 09/01/2014 =U 735428-118 § 4101 §§ At Forgery ~ Alter Writing 03/01/2014 =U. 735428-118 § 4101 §§ A2 Forgery - Unauthorized Act In Writing 03/01/2014 U 735428-118 § 4101 §§ A2 Forgery - Unauthorized Act In Writing 03/01/2014 U 735428-118§ 4101 §§A2 Forgery - Unauthorized Act In Writing 03/01/2014 U738428-418 § 4101 §§ A2 Forgery ~ Unauthorized Act In Writing 03/01/2014 U 735428-118 § 4101 §§ A2 Forgery - Unauthorized Act in Writing 03/01/2014 «UU 735428-118 § 4101 §§ A2 Forgery - Unauthorized Act In Writing 03/01/2014 U 735428-118 § 4101 §§ A2 Forgery - Unauthorized Act In Writing 03/01/2014 =U 735428-118 § 4101 §§A2 Forgery - Unauthorized Act in Writing 03/01/2014 =U 735428-118 § 4101 §§ AZ Forgery - Unauthorized Act In Writing 03/01/2014 =U 735428-118 § 4101 §§A3 Forgery - Utters Forged Writing 03/01/2014 =U 735428-118 § 3922 §§ A1 Theft By Decep-False Impression 03/01/2014 = U735428-118 § 3922 §§ A1 Theft By Decep-False Impression 03/01/2014 U 735428-118 § 7512 §§A Criminal Use Of Communication Facility 03/01/2014 U 735428-1DISPOSITION SENTENCING/PENALTIESDispositionCase Event Disposition Date Einal DispositionSequence/Desoription Offense Disposition Grade SectionSentencing Judae Sentence Date Credit For Time ServedSentence/Diversion Program Type Incarceration/Diversionary Period Start DateSentence ConditiPOMS 9082 Printed: 11/12/2019Recent entries made in the court filing offices may not be immediately reflected on these docket sheets . Neither the courts of the Unified Judicial‘System of the Gommonweaith of Pennsylvania nor the Administrative Office of Pennsylvania Courts assume any liability tor inaccurate or delayeddala, errors or omissions on these reports. Docket Sheet information shouild not be used in place of a criminal history background check which canonly be provided by the Pennsylvania State Police. Moreover an employer who does not comply with the provisions of the Criminal History RecordInformation Act may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183.COURT OF COMMON PLEAS OF CUMBERLAND COUNTYDOCKETDocket Number: CP-21-CR-0003001-2019CRIMINAL DOCKETCourt CaseCommonweaith of Pennsylvaniav.Daniel Lloyd SechriestDISPOSITION SENTENCING/PENALTIESPage 3 of 4DispositionCase Event Disposition Date Final DispositionSequence/Description Offense Disposition Grade SectionSentencing Judge Sentence Date Credit For Time ServedSentence/Diversion Program Type Incarceration/Diversionary Period Start DateSentence ConditionsWaived for Court (Lower Court) Defendant Was PresentLower Court Disposition 10/15/2019 Not Final1 / False/Fraud/incomp Insurance Claim Waived for Court (Lower Court) F3 18 § 4117 §§A22./ False/Fraud/incomp Insurance Claim Withdrawn (Lower Court) F3 18§ 4117 §§A23/ False/Fraud/incomp Insurance Claim Withdrawn (Lower Court) F3 18 § 4117 §§ A24 | False/Fraud/incomp insurance Claim Withdrawn (Lower Court) F3 18 § 4117 §§ AZ5 | False/Fraud/Incomp Insurance Claim Withdrawn (Lower Court) F3 18 § 4117 §§ A26 / False/Fraud/incomp Insurance Claim Withdrawn (Lower Court) F3 18 § 4117 §§A27 | False/Fraud/incomp Insurance Claim Withdrawn (Lower Court) F3 18 § 4117 §§A28 / False/Fraud/Incomp Insurance Claim Withdrawn (Lower Court) F3 18 § 4117 §§A29/ False/Fraud/Incomp Insurance Claim Withdrawn (Lower Court) F3 18 § 4117 §§ A210 / False/Fraud/incomp Insurance Claim Withdrawn (Lower Court) F3 18.§ 4117 §§A241 / False/Fraud/Incomp Insurance Claim Withdrawn (Lower Court) F3 18 § 4117 §§ A212/ False/Fraud/Incomp Insurance Claim Withdrawn (Lower Court) F3 18 § 4117 §§ A243 / False/Fraud/incomp Insurance Claim Withdrawn (Lower Court) 18 § 4117 §§.A214 | False/Fraud/Incomp insurance Claim Withdrawn (Lower Court) F3 18 § 4117 §§A215 / False/Fraud/incomp Insurance Claim Withdrawn (Lower Court) F3 18 § 4117 §§A216 / False/Fraud/incomp Insurance Claim Withdrawn (Lower Court) F3 18§ 4117 §§ A217 | Forgery - Alter Writing Withdrawn (Lower Court) F3 18 § 4101 §§A148 / Forgery - Alter Writing Waived for Court (Lower Court) F3 18 § 4101 §§A119/ Forgery - Alter Writing Withdrawn (Lower Court) F3 18 § 4101 §§A120 / Forgery - Alter Writing Withdrawn (Lower Court) F3 18.§ 4101 §§A121 / Forgery ~ Unauthorized Act in Writing Waived for Court (Lower Court) F3 18. § 4101 §§A222 / Forgery ~ Unauthorized Act in Writing Withdrawn (Lower Court) F3 18 § 4101 §§ AZ23 / Forgery - Unauthorized Act In Writing Withdrawn (Lower Court) F3 18 § 4101 §§.A224 | Forgery - Unauthorized Act in Writing Withdrawn (Lower Court) F3 18 § 4101 §§A225 / Forgery - Unauthorized Act In Writing Withdrawn (Lower Court) F3 18 § 4101 §§.A226 / Forgery - Unauthorized Act In Writing Withdrawn (Lower Court) F3 18 § 4101 §§A227 | Forgery - Unauthorized Act In Writing Withdrawn (Lower Court) F3 18 § 4101 §§A228 / Forgery - Unauthorized Act In Writing Withdrawn (Lower Court) F3 18 § 4101 §§ AZ29 / Forgery - Unauthorized Act In Writing Withdrawn (Lower Court) F3 18 § 4101 §§A230 / Forgery - Utters Forged Writing Withdrawn (Lower Court) M1 18.§ 4101 §§A3‘CPCMS 9082 Printed: 11/12/2019Recent entries made in the court filing offices may not be immediately reflected on these docket sheets . Neither the courts of the Unified JudicialSystem of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assume any llablity for inaccurate or delayeddata, errors or omissions on these reports. Docket Sheet information should not be used in place of a criminal history background check which canonly be provided by the Pennsylvania State Police, Moreover an employer who does not comply with the provisions of the Criminal History RecordInformation Act may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183,COURT OF COMMON PLEAS OF CUMBERLAND COUNTY\ DOCKETDocket Number: CP-21-CR-0003001-2019CRIMINAL DOCKETCourt CaseCommonwealth of Pennsylvaniav.Daniel Lloyd SechriestDISPOSITION SENTENCING/PENALTIESPage 4 of 4Dispositio:Case Event Disposition Date Final DispositionSequence/Description Offense Disposition Grade SectionSentencing Judge Sentence Date Credit For Time ServedSentenge/Diversion Program Type Incarceration/Diverstonary Period Start Date31 / Theft By Decep-False Impression Withdrawn (Lower Court) 48 § 3922 §§A132 / Theft By Decep-False Impression Waived for Court (Lower Court) F3 18 § 3922 §§A133 / Criminal Use Of Communication Facility Waived for Court (Lower Court) F3 18 § 7512 §§ACOMMONWEALTH INFORMATION f oe ATTORNEY INFORMATIONName: Kristyne Michelle Crist Name: Casey Grey Shore *Attorney General PrivateSupreme Court No’ 313743 Supreme Court No: 085321Phone Number(s): Rep. Status: Lower Court747-787-0272 (Phone) Phone Number(s}:Address: 717-232-9900 (Phone)Ofc of Attorney General Address:Strawberry Square 16th Floor Perry Shore Weisenberger & ZemlockHarrisburg, PA 17120 2411 N Front StHarrisburg, PA 17110-1160Representing: Sechriest, Daniel Lloyd* Entry of Appearance Not FiledENTRIES.CP Filed Date Document Dateled By1 08/06/2019 Clement, Charles A.Bail Set - Sechriest, Daniel LloydSequence Number1 10/25/2019 Court of Common Pleas -Cumberland CountyOriginal Papers Received from Lower Court1 40/31/2019 Crist, Ktistyne MichellePraecipe for Appearance, filed. (Prosecution)cPCMs 9082 Printed: 11/12/2019Recent entries made in the court fling offices may not be Immediately reflected on these docket sheets . Neither the courts of the Unified Judicial‘System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assume any liability for inaccurate or delayeddala, errors or omissions on these reports, Docket Sheet information should not be used in place of a criminal history background check which canonly be provided by the Pennsylvania State Police. Moreover an employer who does not comply with the provisions of the Criminal History RecordInformation Act may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183,7th. Judicial Circuit 707ae . Arrest # Bea Pg#l of 2_Charging Affidavit - Volusia eeARREST [] NOTICE TO APPEAR C AFFIDAVIT cc ADULT & JUVENILE C] [eer e O10 2d Aloo a(ORD FL: 0 [ 3/7 in 7 [0 o | ABeney FL! Dept. of Financial Services/DIFS aera on. 1108FCIC/NCIC Check? Yes 9 No Ci OBTS# [ber Dae: Hinw of |, — ‘Arrested iDDRESS OF ARREST: _ Number:Nar p:_ Sechriest, Daniel L sex: M | Race: Wpos: 9/30/1976Driver's| Age: 42 ID No.SS7a EagerHeight: Sggr Weight: Hair: s POR. 6°00 | 200 Brown Rel (City, St, Coun _Sears, Marks, ‘Business & Citizenship:Tatonse an Occupation 9 Gulf Adame Industries of America Disaster Relief, LLC ves BY NOL]Probati Yes ONo® Sexval Predator; Yes QNo® English: Yes RNoO Deaf/Mute: Yes O No‘Adress-Malling/Permanent (STREET, APT. NUMBER) iy STATE) ZIPCODE RESIDENCE PHONE362 Crandall Drive Worthington __OH _ 43085 _|Address-Local (STREET, APT. NI ER) (CITY) (STATE) ZIPCODE RESIDENCE PHONE‘Address-Other(Employer/School) (STREET, APT, NUMBER) (CITY) (STATE) ‘ZIPCODE BUS/SCHOOL PHONEpe YESO) | Attachments: Afidavit(s) (J Statement(s) (J NTA Schedule (] Report (] Traffic tnfraction(s) (J DU! CI Cnet 3BL | Charges FEL MSD CT ORD ED | FSORD: Giation No. Bond:False and Fraudulent Insurance Claims _ 817.234(1 Ya) __ _a | Chara FEL &F MSDE ORD ET | Fsorp: Glation Now Bond:Organized Scheme to Defraud ___| 817.034(4y(0)#3 Charge: FEL MISO CT ORD CT] Fs/orD: Citation No ‘Bond:‘Unlicensed Adiustin: a 626.8738 —--Deft. Arrested? ¥ CIN Cl Fel, C] Misd, C) Trat, C7 Ord.Race: BOB: Age:“WL NAME(L,RM): Bex!| #2 NAME(LRM) Race: ‘Sex; Toe: | ‘Age:The undersigned certifies arid swears that there is probable cause to believe the above named defendant,did between December 2016 to present, at 142 Holly Hill Court, New Smyrna Beach, FL 32168, within Volusia County, violated the lawand did then and there present or cause to be presented to an insurer, with the intent to defraud, multiple written statements in support ofaclaim, knowing that such statements contained false, incomplete, or misleading information concerning a fact or material thing to suchclaim, in violation of $817.231(1)(a)1, to wit:This investigation revealed that between December 2016 and the present date, Sechriest has contracted to repair several roofs inVolusia County, under the names of Gulf Atlantic Industries of America, Inc., Gulf Atlantic Industris of America Disaster Relief, LLC,One Way Remodeling, LLC, Florida Roof Experts, LLC, US Restoration and Remodeling, Inc. and Asset Protection Group, LLC.Sechriest submitted supplemental claims to the homeowners’ insurance companies requesting significantly inflated payments for allegedcompleted work, which had not been performed, Sechriest is not licensed as a general contractor, a roofer, or a public adjuster in the |State of Florida, |1Sechriest entered into contracts with Michael Perry (DIFS 19-1108), Sandra Capps (DIFS 19-1109), Katherine Powers (DIFS 19-206), Howard Glavin (19-206) and William and Clelia Hill (DFIS 19-206) for damages suffered to their respective residences fromHurricanes Michael and/or Irma. Each property owner signed an Assignment of Insurance Claim, also known as an Assignment ofBenefits, transferring the ownership of the claim to one of Sechreist’s respective companies, All of the above mentioned homeownersindicated that the estimates for payment, which were submitted to their respective insurers, had charges in which the work was neverperformed, According to the insurers, Sechreist and his employees, sent emails stating that all work had beep completed successfully, |‘These emails also included Sworn Statements of Partial Proofs of Loss as well as Certifications of Completigh of Repas, furtherindicating that the work was performed in its entirety, when it had not been, ©BS .eg; countgring tialspre-stofl conditions evenReia ISechriest systematically handled all of these claims in the same manner for each of the listed home:insurance estimates with inflated prices claiming under false pretense the properties had been brought bathough all of the work had not been completed, thus, violating $817.034(4)(a).Sechriest’s companies submitted multiple written statements as part of, or in support of, a claim for patie nt omether bt bnesit toaninsurance policy, knowing that such statements contained false, incomplete, or misleading information condagring anyofact or thingmaterial to such claim in violation of $817.234(1)(a)1. According to Special Investigator D. Jarrett with the Divisiorof Insurance Agent& Agency Services, Sechriest nor any of his employees who submitted estimates are licensed by the department as a public adjusters,By submitting estimates and negotiating payments for alleged services rendered, Sechriest was acting in the capacity of a publicinsurance adjuster, therefore, violating $626. 112(1)(a). 3Below is an account of each investigation concerning the facts involving each of the homeowners and Sechriest’s businesses:PerryOn 08/26/2019, information was received that Daniel Sechriest, doing business as Gulf Atlantic Industries of America DisasterRelief, LLC, was fraudulently billing an insurance company requesting payments for alleged completed work that had not beenperformed,During my investigation, I determined that Daniel Sechriest is the President of Gulf Atlantic Industries of America Disaster Relief,LLC, A company by the name of U.S, Restoration & Remodeling, Inc, is also listed as the Authorized Member (AMBR). Gulf AtlanticIndustries of America Disaster Relief, LLC is a Florida Limited Liability Company registered with the Division of Corporations in theState of Florida on 11/23/2016. The United States Internal Revenue Service assigned a Federal Employer Identification Number (FEIN)of 81-4558906, (It should be noted, U.S, Restoration & Remodeling, Inc. is registered in the State of Ohio and Daniel Sechriest is listedas the President and statutory agent.)This investigation revealed that homeowner, Michael Perry, sustained roof damage to his residence located at 142 Holly HillCourt, New Smyrna Beach, FL 32168 as a result of Hurricane Matthew. Perry filed an insurance claim, #869389, with his homeowner'sinsurance carrier, Homeowners Choice Property and Casualty Insurance Company (Homeowners Choice). Perry entered into contractwith Gulf Atlantic Industries of America, Inc. on 12/17/16 to fix his roof. The contract presented lists a general contractors licenseissued to Robert Paul Ludwig, III. On this same date an Assignment of Insurance Claim with Gulf Atlantic Industries of America, Inc,was signed by Perry and Randy Park, an employee of Gulf Atlantic Industries of America, Inc.On 01/03/2017, Perry’s home was originally inspected by Beth Ofseur, Independent Adjustor with CIS Claim Services, acontracted company through Homeowners Choice, According to the inspection report, the total replacement cost value was estimated at$7,107.30, Actual Cash Value (ACV). On 04/04/2017, Perry’s home was inspected by Eddie Pinner, Independent Adjuster with CISClaim Services after Perry noticed some damages had not been included in the initial inspection by Ofseur, According to the inspectionreport, the total cost of repairs to Perry’s home was now estimated at $22,270.21 (ACV). On 01/31/2018, Homeowners Choice issuedchecks numbered 218824, 218825, 218826, 247966 and 247967 in the amounts of $1,333.95, $1,462.50, $300, $768.18 and $9,977.26.Perry confirmed that he received these checks and deposited them into his personal bank account.On 3/18/18, Dan Sechriest sent via email a ‘10 day demand to pay” to Homeowners Choice demanding payment in the amount of$25,170.74. The email reads in part, “Gulf ATLANTIC Industries of America has been hired to repair and restore the damaged insuredproperty back to its pre-storm condition using materials of like kind and quality. We are now the claim owner. The job is complete andour w9 is attached for the depreciation and future payments directly to us. We have received your most recent offer to settle the claimand there now exists a dispute between you and us regarding the scope of damage and pricing of this loss.”On 04/13/18, a second email demanding payment to Gulf Atlantic within 5 days was sent by Rick Augenstein. The correspondenceincluded an multiple attachments, to include an inspection report which appeared to have been completed on 4/12/18 by Augenstein.According to this inspection report, the total replacement cost for Perry’s damages is $50,470.89. A signed and notarized proof of losswhich is signed by “Daniel Sechriest, President for the claim owner US Restoration and Remodeling” was also attached in the email.This email also states “We completed all contracted work successfully..... This is our second bill that we have sent to HomeownersChoice Property & Causalty Insurance to finalized the claim.” It should be noted that Augenstein is not licensed in the State of Florida toconduct public adjusting or to submit estimates, |On 04/19/18, Perry authored a letter addressed to Gulf Atlantic Industries of America. The letter stated in part, “Please considerthis letter notice of cancellation of my roofing contract with your company, as no work has been performed to date and no timelyexchange of conversation or information on this matter has occurred.” This letter from the homeowner, Perry, directly contradictsSechriest’s 10 day demand for payment email sent on 3/18/18 and all subsequent emails claiming the job had been completed.On 04/27/2018, the Assignment of Insurance Claim which Perry initially signed with Gulf Atlantic Industries of America, Inc. wassubsequently signed over to Asset Protection Group, LLC. (It should be noted that Sechriest is also listed as the President of AssetProtection Group, LLC. The company was registered with the Florida Division of Corporations on 11/10/2017.)On 07/30/18, Sechriest sends a 5 day demand for payment via email. In this correspondence Sechriest advised that the ownershipof Perry’s claim has changed stating, “There is no cancellation of gulf Atlantic AOC, rather Gulf Atlantic has assigned the claim to AssetProtection Group, LLC 386-682-2212.” Again, demand for $50,470.89 was made, and he claims that “we completed all contracted worksuccessfully,”On 09/10/2019, Det. Owens and I interviewed Michael Perry in his home, located at 142 Holly Hill Court, New Smyrna Beach, FL32168. Perry indicated that he had entered into a contract with “Gulf Atlantic Industries” to have his roof replaced after HurricaneMatthew. Perry signed an Assignment of Insurance Claim with Gulf Atlantic Industries of America, Inc. on 12/17/2016. According toPerry, the paperwork was presented to him by Randy Park, an employee with Gulf Atlantic, Perry said he was contacted by Sechriestafter Hurricane Irma and was told that Perry's insurance company had issued a $50,000 check to complete the repairs. Perry said hethought this was odd because he received a few checks from Homeowners Choice which only listed Perry as the payee; a couple wereover a thousand dollars, and another check he thought was closer to ten thousand dollars. Even though a contract and AOC was signedwith Gulf Atlantic Industries, Perry said he never turned any of the money over to the roofer. Perry followed up with HomeownersChoice who informed him that they had not issued a check to Gulf Atlantic or Sechriest. According to Perry, no work has beencompleted at his residence, not even a tarp placed on his roof. Perry stated that any work that was done, was done by him to minimizeany further damage as best he could, ‘The only time anyone has been to his house was to document the damage and to takemeasurements. Perry signed an affidavit affirming the facts stated above.CappsOn 09/12/2019, information was received that Daniel Sechriest, doing business as Gulf Atlantic Industries of America DisasterRelief, LLC, was fraudulently billing an insurance company requesting payments for alleged completed work that had not beenperformed,During my investigation, I determined that Daniel Sechriest is the President of Gulf Atlantic Industries of America Disaster Relief, |LLC. A company by the name of U.S. Restoration & Remodeling, Inc. is also listed as the Authorized Member (AMBR). Gulf Atlantic |Industries of America Disaster Relief, LLC is a Florida Limited Liability Company registered with the Division of Corporations in theState of Florida on 11/23/2016. The United States Internal Revenue Service assigned a Federal Employer Identification Number (FEIN)of 81-4558906. (It should be noted, U.S. Restoration & Remodeling, Inc. is registered in the State of Ohio and Daniel Sechriest is listedas the President and statutory agent.)This investigation revealed that the homeowner, Sandra Capps, sustained damage to her residence located at 1144 MillbrookAvenue, Port Orange, FL 32127 on 10/7/16 as a result of Hurricane Matthew. Capps filed an insurance claim, #25023, with herhomeowner’s insurance carrier, Southern Oak Insurance Company (Southern Oak).On 1/9/17, Capps entered into contract with Gulf Atlantic Industries of America Disaster Relief, LLC for repairs to her home, AnAssignment of Insurance Claim to Gulf Atlantic Industries of America Disaster Relief, LLC was signed by Capps. According to theinterview West recorded with Capps, the following line items from the Gulf Atlantic Industries of America Disaster Relief, LLC estimatewere not completed:7. R&R Gutter/downspout-box- aluminum ~ 6” 30.00LF $326.868, R&R Gutter/downspout aluminum — 6” 11.00LF $114.9818, Gutter — Labor Minimum. $248.5821, Painting - Labor Minimum $201.77‘The metal roof panels from the sunroom were not repaired until after the second claim for Hurricane Irma. The plexiglass and windowscreens from the sunroom were not fixed until after the second claim as well.On 9/10/17, Capps sustained damage to her residence once again, this time as a result of Hurricane Irma. Capps filed an insuranceclaim, #28558, with her homeowner's insurance carrier, Southern Oak, At this point, no work had been completed by Gulf AtlanticIndustries of America Disaster Relief, LLC on the previous claim other than the skirting around the mobile home which was completedon 4/01/17,On 11/13/17, Capps signed an Assignment of Insurance Claim for Hurricane Irma (Claim #28558) over to Gulf Atlantic Industriesof America Disaster Relief, LLC. Jason Bassett is listed as the Assignee.On 3/28/18, Rick Augenstein sent an email requesting a supplement claim from Southern Oak on behalf of Gulf Atlantic Industriesof America stating in part that they had been “hired to restore the damaged insured property back to its pre-storm condition usingmaterial of like kind and quality, We are now the claim owner. The job is complete and our w9 is attached for the depreciation andfuture payments directly to us.” In this email, Augnestein references figures reflected from the first Gulf Atlantic Industries of Americaestimate which was entered on 12/12/17 at 9:23 AM by Scott Hoff.According to the interview West recorded with Capps, after Hurricane Irma the living room walls were not painted, no ceilingpanels were replaced, the insulation in the ceiling and the quarter round on the flooring was not completed. In the bathroom the wallswere replaced with new drywall and painted, however, no ceiling panels were replaced, She also said that no electrical work wascompleted, The following line items from this estimate were not completed or provided:6. Fall Protection Harness and Lanyard- per day 215,00DA $2,081.2013. Temporary Toilet 1.00 $144.0129. R&R Gutter/downspout-box- aluminum—-6" 30.00LF $317.4230. R&R Gutter/downspout aluminum ~ 6” 11.00LF = $111.5133. Ceiling fan- Detach & reset 2.00BA $352.5734. R&R 110 volt copper wiring run and box 3.00EA $173.3435. R&R Liquid tight flexible conduit 28,00LF___ $459.9537, R&R Mobile home metal skirt 1,167.60LF $4,638.9241, R&R Wood fence 5’-6’ high cedar or equal 110.00LF $4,285.9342, Stain-wood fence/gate 110.00LF $93.42On 5/23/18, a Certification of Completion of Repairs was signed by Scott Hoff for the Hurricane Irma claim, #28558. Thisdocument, which was submitted to Southem Oak, states in part that all necessary repairs contracted by the client have been completed ina satisfactory manmer and that no liens have been, nor will be filed against the property as a result of labor performed or material used.‘The property has now been restored to the condition existing prior to the date of damage. On 5/23/18, Sechriest signed and submitted asworn statement of Partial Proof of Loss indicating an actual cash value of loss as $36,463.74, Sechriest signed this document as the“President for the claim owner US Restoration and Remodeling.”On this same date, Rick Augenstein sent a final demand for payment email to Southern Oak, This email requests payment withinfive days and states that “We completed all contracted work successfully.”On 5/24/18, Hoff signed a Certificate of Completion of Repairs for Hurricane Mathew, claim # 25023, This document states inpart, that all necessary repairs contracted by the client have been completed in a satisfactory manner and that no liens have been, nor willbe filed against the property as a result of labor performed or material used. The property has now been restored to the condition existingprior to the date of damage, On this same date, Sechreist signed a Sworn Statement of Partial Proof of Loss for this same claimindicating the whole loss and damage totals $50,393. Sechriest signed this document as the “President for the claim owner USRestoration and Remodeling.”On 05/30/18, a Release Form was signed and submitted by Sechriest, indicating that $35,000 issued by Southern Oak should bereleased by Capps and tured over to Sechriest. It should be noted that Capps refused to sign said release. The form shows Capps’ namecrossed out multiple times and Sechriest’s name hand written in and then signed by Sechriest.It should be noted that neither Augustein nor Hoff are licensed in the State of Florida to conduct insurance adjusting even thoughthey are the ones listed as the estimators on the submitted estimates to Southern Oak,GlavinThis investigation revealed that homeowner, Howard Glavin, sustained roof damage to his residence, located at 848 Wild CurrRoad, Pierson, FL, as a result of Hurricane Irma on 09/11/17. Glavin filed an insurance claim (Claim #8712038) with his homeowner’sinsurance carrier, Homeowners Choice Property and Casualty Insurance Company. This investigation revealed that on 09/15/17, Glavinentered into a contract with Gulf Atlantic Industries of America Disaster Relief to replace his roof. The contract contains the roofinglicense for Scott D, Hoff (#CCC1331253), the roofing license holder for several of Sechriest’s roofing businesses. Additionally, Glavinsigned an Assignment of Claim Form from Gulf Atlantic Industries of America Disaster Relief on the same date. These documents werepresented to Glavin by James Quigley, an employee of Gulf Atlantic Industries of America Disaster Relief.On 09/30/17, Glavin’s home was inspected by Victoria Peltier of Burton Claim Service. This inspection was conducted on behalf ofthe insurance company. According to the inspection report, the total cost for the roof replacement was estimated (with depreciation) tobe $10,362.41. The insurance company issued a check (#0000197671/ dated 10/27/17) in the amount of $5,270.41, and payable toHoward Glavin, Wanda Nobles (spouse) and Jax Federal Credit Union (mortgage holder), Glavin reported that he and his spouseendorsed the check before providing the check to Quigley. The check was later deposited into Gulf Atlantic Industries of AmericaDisaster Relief’s bank account at Fifth-Third Bank, Investigator T, Gibson with Homeowners Choice Insurance company, receivedverification that the endorsem*nt from Jax Federal Credit Union was fraudulent.On 05/03/18, Hoff’s license was placed on inactive status by the FL Dept, of Business & Professional Regulation (DBPR). On06/30/18, another Assignment of Claim Form was signed by Daniel Sechriest, indicating that Glavin’s claim was being transferred toGSD Construction Services LLC, an Illinois-based company, This form was signed by Sechriest and Joseph Piagentini, President ofGSD Construction Services, LLC.On 05/17/19, Homeowners Choice received an email from Sechriest’s email stating that all contracted work had been completedsuccessfully and demanding that the amount of $43,707.37 be paid to avoid legal proceedings. This email also contained a SwornStatement of Partial Proof of Loss, and an estimate from Gulf Atlantic Industries of America Disaster Relief, purporting to be a generalcontractor and using the name and logo of Gulf Atlantic Industries of America, Inc., the general contracting business that is owned byLebowitz. This estimate was written after A Notice of Termination of Agreement/Material Breach Notices (dated 06/26/17) was sent toSechriest demanding that he refrain from using the Gulf of Atlantic Industries of America name and logo.On 08/27/19, Detectives M, Owens and A. Kline of the FL Dept. of Financial Services/ Bureau of Insurance Fraud interviewed KerryLeuzinger, Chief Building Official with Growth & Resource Management / Building & Code Administration. Leuzinger provided asworn affidavit attesting to the fact that there has been no roofing permit applied for or issued for Glavin’s residence.On 08/27/19, Detectives Owens and Kline interviewed Howard Glavin. Glavin provided a sworn affidavit attesting to the fact that heentered into a contract with Gulf Atlantic Industries of America Disaster Relief in 2017, and that there has been no work performed at hisresidence, Additionally, Gavin reported that on 11/11/17, when he provided the insurance check to Quigley, he gave him a personalcheck for his deductible in the amount of $5,092. Glavin stated that the funds were.deducted from his bank account and deposited intoGulf Atlantic Industries bank account at Fifth-Third Bank. Detective M, Owens subpoenaed Fifth-Third Bank for records for the account(ending in 2474) that Glavin’s check was deposited into. The records indicate that this account is a business standard checking account in| 

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