UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO: 20-21707-CV-MARTINEZ/BECERRA

RAYMOND JAMES FINANCIAL, INC.,

Plaintiff,

vs.

FEDERAL INSURANCE COMPANY; 

TRAVELERS CASUALTY AND SURETY 

COMPANY OF AMERICA; GREAT 

AMERICAN INSURANCE COMPANY; 

BEAZLEY INSURANCE COMPANY, INC.; 

and ST. PAUL MERCURY INSURANCE 

COMPANY,

Defendants.

PLAINTIFF RAYMOND JAMES FINANCIAL, INC.’S 

MOTION FOR PARTIAL SUMMARY JUDGMENT AGAINST DEFENDANT

FEDERAL INSURANCE COMPANY AND SUPPORTING MEMORANDUM OF LAW

Plaintiff, Raymond James Financial, Inc. (“Raymond James”), by and through undersigned 

counsel and pursuant to Fed. R. Civ. P. 56, moves for partial summary judgment against Defendant 

Federal Insurance Company (“Federal”) on Federal’s Seventh, Eighth, Ninth, Twenty-Second and 

Twenty-Eighth Affirmative Defenses [ECF No. 46]. In support thereof, Raymond James submits 

the following memorandum of law.

I. INTRODUCTION

This is an insurance coverage dispute arising from Federal and the other defendant-insurers 

failure to indemnify Raymond James for covered losses under a series of Financial Institution 

Bonds (the “Bonds”) that Raymond James purchased from the Defendants providing a total of $60 

million in “single loss” employee fidelity coverage. Raymond James was insured by Federal under 

the Primary Bond, the Second Excess Bond and the Third Excess Bond (as defined in the First 

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Amended Complaint). Raymond James suffered a covered loss under the Bonds resulting directly 

from dishonest and fraudulent acts committed by a Raymond James employee, Joel Burstein

(“Burstein”), while acting in collusion with his former father-in-law Ariel Quiros (“Quiros”), in 

connection with the purchase, improvement and expansion of the Jay Peak Resort in Jay Peak, 

Vermont by Quiros. As part of their dishonest and fraudulent scheme, Burstein and Quiros, with 

the intent to financially benefit themselves and entities operated and controlled by Quiros and 

others, misappropriated over $60 million in limited partnership funds for purposes unrelated to 

any of the Jay Peak limited partnerships and for Quiros’ personal benefit. 

Upon discovery of the fraud, the SEC initiated litigation against Quiros on April 12, 2016, 

which resulted in the appointment of Michael Goldberg as the Receiver for the Jay Peak limited 

partnerships and related entities (the “SEC Receiver”). See (Plaintiff Raymond James Financial, 

Inc.’s Local Rule 56.1 Statement of Material Facts in Support of Motions for Partial Summary 

Judgment (“Stmt. Mat. Facts”) at ¶ 6).0F

1

 Soon thereafter, numerous lawsuits were filed against 

Raymond James and Burstein, including an action filed by the SEC Receiver on May 20, 2016, 

and a consolidated class action lawsuit filed on May 3, 2016 by individual EB-5 investors who 

were seeking to recover, among other damages, the limited partnership funds that had been 

misappropriated by Burstein and Quiros using accounts at Raymond James. (Id. at ¶ 7). After 

months of confidential negotiations, Raymond James agreed to settle with the SEC Receiver and 

class counsel. (Id. at ¶ 8). The Settlement Agreement, which was subsequently approved by the 

Court in the receivership action, provided for the dismissal of all Jay Peak related civil litigation 

against Raymond James and a bar of future litigation (other than actions brought directly by 

 1 Pursuant to S.D. Fla. L.R. 56.1, Raymond James’ Local Rule 56.1 Statement of Material Facts is 

being filed contemporaneously with this Motion. Pursuant to this Court’s Order [ECF No. 96], 

Raymond James further refers the Court to the parties’ Joint Statement of Undisputed Facts.

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government entities) in exchange for payment of $150 million from Raymond James. (Id. at ¶¶ 8, 

9).

On or about May 4, 2016, Raymond James’ Legal Department received notice that the 

Daccache class action lawsuit had been filed against Raymond James and Burstein. (Id. at ¶ 10). 

At that time, Raymond James received notice of an actual claim in which it was alleged that 

Raymond James was liable to a third party under circumstances which, if true, would constitute a 

loss under the Bonds. (Id.). Raymond James then reported to the Defendants a claim under the 

Bonds on May 16, 2016. (Id. at ¶ 11). Raymond James, as requested by the Defendants and 

pursuant to agreed-upon extensions, submitted a narrative proof of loss to the Defendants on 

February 27, 2018. (Id. at ¶ 12). Over two years later, on April 20, 2020, Federal, as the primary 

insurer in a follow form tower, denied coverage under the Bonds. (Id. at ¶ 13). 

Raymond James then filed this lawsuit on April 23, 2020. (Id. at ¶ 14). Raymond James 

filed a First Amended Complaint for Damages on July 8, 2020. (Id.). The lawsuit asserts claims 

for breach of contract and declaratory relief, and seeks to recover the $60 million in insurance 

coverage that Raymond James purchased from the Defendants under the Bonds at issue. (Id.). In 

response to the First Amended Complaint, Federal filed its Answer and Affirmative Defenses 

[ECF No. 46], and asserted numerous affirmative defenses, certain of which, as addressed herein, 

are not supported by any record evidence in this case or otherwise are legally inapplicable to 

Raymond James’ claims in this lawsuit. Accordingly, and for the reasons discussed herein, 

Raymond James is entitled to partial summary judgment on Federal’s Seventh, Eighth, Ninth, 

Twenty-Second and Twenty-Eighth Affirmative Defenses.

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II. ARGUMENT

A. Summary Judgment Standard

“Rule 56(c) mandates the entry of summary judgment . . . against a party who fails to make 

a showing sufficient to establish the existence of an element essential to that party’s case, and on 

which that party will bear the burden of proof at trial.” Celotex Corp. v. Catrett, 477 U.S. 317, 

322 (1986). “When the non-moving party bears the burden of proof on an issue at trial, the moving 

party need not ‘support its motion with affidavits or other similar material negating the opponent’s 

claim” to meet its initial burden on summary judgment. Rice-Lamar v. City of Fort Lauderdale, 

232 F.3d 836, 840 (11th Cir. 2000) (quoting Celotex Corp., 477 U.S. at 323) (emphasis in original). 

Instead, the moving party simply may “point out to the district court” . . . “that there is an absence 

of evidence to support the nonmoving party’s case.” Id.; Young v. City of Augusta ex rel. DeVaney, 

59 F.3d 1160, 1170 (11th Cir. 1995) (to prevail, moving party may “may show that the non-moving 

party has no evidence to support [an essential element] of its case”). Once the moving party makes 

this showing, “the burden shift[s] to the nonmoving party to designate, through affidavits or 

otherwise . . . , specific facts showing that there is a genuine issue for trial.” Young, 59 F.3d at

1170. “The existence of a mere scintilla of evidence in support of the non-movant’s position is 

insufficient; there must be evidence on the basis of which a jury could reasonably find for the 

nonmovant.” Yacht Club on the Intracoastal Condo. Ass’n v. Lexington Ins. Co., 944 F. Supp. 2d 

1258, 1261 (S.D. Fla. 2013).

B. Principles of Insurance Policy Interpretation

Florida law is well-settled that insuring or coverage clauses must be read in the broadest 

possible manner to afford the greatest extent of coverage. Hudson v. Prudential Prop. & Cas. Ins. 

Co., 450 So. 2d 565, 568 (Fla. Dist. Ct. App. 1984). Exclusionary clauses, in contrast, are always 

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strictly construed. Westmoreland v. Lumbermens Mut. Cas. Co., 704 So. 2d 176, 179 (Fla. Dist. 

Ct. App. 1997). Because exclusions are fundamentally contrary to the purpose of insurance, 

Florida courts hold insurers “responsible for clearly setting forth what [is] excluded from coverage 

under the terms of the policy.” Fayad v. Clarendon Nat’l Ins. Co., 899 So. 2d 1082, 1086 (Fla. 

2005). Accordingly, if an insurer intends to exclude or limit coverage, it must do so 

unambiguously. Anderson, 756 So. 2d at 34. Where policy language is susceptible to more than 

one reasonable interpretation, it is considered to be ambiguous. Washington Nat’l Ins. Corp. v. 

Ruderman, 117 So. 3d 943, 948 (Fla. 2013). Any ambiguity must be liberally construed in favor 

of coverage and strictly against the insurer. Id. at 949-50. In other words, where “one reasonable 

interpretation of the policy provisions would provide coverage, that is the construction which must 

be adopted.” Id. at 950.

C. Raymond James is Entitled to Partial Summary Judgment on Federal’s Seventh, 

Eighth, Ninth, Twenty-Second and Twenty-Eighth Affirmative Defenses

The “burden of proving each element of an affirmative defense rests on the party that 

asserts the defense.” Paladin Shipping Co. v. Star Capital Fund, Ltd. Liab. Co., 491 F. App’x 42, 

44 (11th Cir. 2012) (quoting Custer Med. Ctr. v. United Auto. Ins. Co., 62 So. 3d 1086, 1097 (Fla. 

2010)). Accordingly, Federal bears the burden of establishing the elements of each asserted 

affirmative defense. Regions Bank v. Old Jupiter, LLC, No. 10-80188-CIV, 2010 WL 5148467, 

at *2 (S.D. Fla. Dec. 13, 2010). Because Federal cannot meet that burden with respect to its 

Seventh, Eighth, Ninth, Twenty-Second and Twenty-Eighth Affirmative Defenses, Raymond 

James is entitled to summary judgment on those defenses.

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i. Seventh, Eighth and Ninth Affirmative Defense – Aggregate Limits of Liability

are Inapplicable

Federal asserted for its Seventh, Eighth and Ninth Affirmative Defenses that Raymond 

James’ cannot recover in excess of the Aggregate Limit of Liability under the Primary Bond ($20 

million), the Second Excess Bond ($20 million excess of $40 million) and the Third Excess Bond 

($40 million in excess $60 million), respectively. [ECF No. 46 at pp. 43-44]. Raymond James is 

entitled to summary judgment on these defenses, because the aggregate limits of liability in these 

Bonds is completely inapplicable. As the First Amended Complaint makes clear, Raymond James 

is only seeking to recover the $60 million in “single loss” employee fidelity coverage under the 

Bonds resulting from Burstein’s dishonesty. [ECF No. 39 at ¶¶ 1, 74]. And, indeed, the Primary 

Bond expressly provides that “[s]ingle loss” means “all acts or omissions . . . caused by any person 

(whether an Employee or not) or in which such person is implicated.” [ECF No. 39 at Ex. A, 

Primary Bond, Limit of Liability, p. 13]. There is no record evidence to even suggest that the 

aggregate limits of liability under the Bonds are applicable in this case. 

Therefore, Raymond James is entitled to partial summary judgment on Federal’s Seventh, 

Eighth and Ninth Affirmative Defenses.

ii. Twenty-Second Affirmative Defense – Raymond James is Entitled to Recover its 

Attorneys’ Fees and Costs Pursuant to Fla. Stat. § 627.428 if it Prevails

Federal asserted for its Twenty-Second Affirmative Defense that Raymond James seeks to 

recover fees and costs not covered under the Primary Bond, relying on Exclusion (u) (as amended 

by Endorsement No. 5) of the Primary Bond. That exclusion provides that there is no coverage 

for “all fees, costs, and expenses incurred by the Insured (1) in establishing the existence or amount 

of loss covered under this bond, except to the extent covered under the portion of Insuring 

Agreement (a) entitled Audit Expense; or (2) as a party to legal proceeding whether or not such 

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legal proceeding exposes the Insured to loss covered by this bond.” [ECF No. 46 at p. 49]. Federal 

appears to be suggesting that Raymond James is not entitled to recover its attorneys’ fees and costs 

in this litigation.

But, if Raymond James prevails in this action against Federal, the Court is required to 

award Raymond James its attorneys’ fees and costs pursuant to Florida Statutes Section 627.428. 

See Fla. Stat. § 627.428(1) (“Upon the rendition of a judgment or decree by any of the courts of 

this state against an insurer and in favor of any named or omnibus insured or the named beneficiary 

under a policy or contract executed by the insurer, the trial court or, in the event of an appeal in 

which the insured or beneficiary prevails, the appellate court shall adjudge or decree against the 

insurer and in favor of the insured or beneficiary a reasonable sum as fees or compensation for the 

insured’s or beneficiary’s attorney prosecuting the suit in which the recovery is had”) (emphasis 

added). Indeed, an award of fees under Fla. Stat. § 627.428 “is a mandatory, non-discretionary 

requirement of law.” Sanchez v. AN Luxury Imports of Pembroke Pines, Inc., 216 So. 3d 723, 730 

(Fla. Dist. Ct. App. 2017).

Therefore, if successful against Federal in this litigation, Raymond James is, as a matter of 

law, entitled to recover its attorneys’ fees and costs from Federal. Accordingly, Raymond James 

is entitled to summary judgment on Federal’s Twenty-Second Affirmative Defense.

iii. Twenty-Eighth Affirmative Defense – Raymond James Timely Filed this Action

Federal asserted for its Twenty-Eighth Affirmative Defense that “Raymond James claim is 

barred by the applicable statute of limitations and/or contractual limitations period as outlined in 

the Primary Bond.” [ECF No. 46 at p. 51]. This defense fails as a matter of law and undisputed 

fact.

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Under Florida law, the statute of limitations for an action for breach of a written instrument 

is five (5) years. Fla. Stat. § 95.11(2)(b). A cause of action accrues when the last element 

constituting the cause of action occurs. Fla. Stat. § 95.031(1). “Florida case law consistently holds 

that a cause of action for breach of contract accrues and the limitations period commences at the 

time of the breach.” Clark v. Estate of Elrod, 61 So. 3d 416, 418 (Fla. Dist. Ct. App. 2011) (internal 

quotation marks omitted). As such, “a breach of contract action on an insurance contract accrues 

on the date the contract is breached.” Dinerstein v. Paul Revere Life Ins. Co., 173 F.3d 826, 828 

(11th Cir. 1999) (citing State Farm Mut. Auto. Ins. Co. v. Lee, 678 So. 2d 818, 821 (Fla. 1996)); 

Saenz v. State Farm Fire & Cas. Co., 861 So. 2d 64 (Fla. Dist. Ct. App. 2003) (statute of limitations

period in breach of insurance contract actions begins running from the date of the alleged breach). 

To that end, “a specific refusal to pay a claim is the breach which triggers the cause of action and 

begins the statute of limitations running” in actions predicated upon insurance contracts. Donovan 

v. State Farm Fire & Cas. Co., 574 So. 2d 285, 286 (Fla. Dist. Ct. App. 1991) (citations omitted); 

Roth v. State Farm Mut. Auto. Ins. Co., 581 So. 2d 981, 983 (Fla. Dist. Ct. App. 1991) (insurer’s 

notification to insureds that claim was denied triggered the running of the statute of limitations).

Federal, as the primary insurer in a follow form tower, denied coverage on April 20, 2020. 

(Stmt. Mat. Facts at ¶ 13). This denial of coverage triggered the running of the statute of limitations 

under Florida law. Donovan, 574 So. 2d at 286; Roth, 581 So. 2d at 983. Raymond James filed 

this action on April 23, 2020 – within days of Federal’s denial of coverage. (Stmt. Mat. Facts at ¶ 

14). Raymond James timely brought this action within the five-year statute of limitations.

In response to an interrogatory asking for the factual basis for its defense, Federal asserted 

that Raymond James’ claim under the Bonds was barred either by the statute of limitations in Fla. 

Stat. 95.11 or the two-year suit limitation imposed by the Bonds. See [Federal Insurance 

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Company’s Objections and Responses to Raymond James Financial, Inc.’s First Set of 

Interrogatories at No. 4, a copy of which is attached hereto as Exhibit “1”].

As to the former, Federal contended that Raymond James’ claim is untimely because Fla. 

Stat. 95.11(2)(e) provides that in an “action for breach of a property insurance contract,” the period 

runs from the date of loss. But this is not a property insurance claim governed by Fla. Stat. § 

95.11(2)(e); it is an action for indemnification under a tower of fidelity bonds. To be sure, the 

published decisions that have referenced Fla. Stat. § 95.11(2)(e) all involved lawsuits for damage 

to real property, typically in the context of hurricane damage.1F

2

 Fla. Stat. § 95.11(2)(e) simply has 

 2 See McMillan v. Cincinnati Ins. Co., No. 5:20-cv-72-Oc-30PRL, 2020 WL 5947656 (M.D. Fla. 

June 12, 2020) (breach of contract action based on failure to pay insurance proceeds for damage 

to plaintiff’s home); The Jacqueline Norris Huggett v. Ironshore Specialty Ins. Co., No. 18-21467-

CIV-ALTONAGA/Goodman, 2018 WL 8359643, at *1 (S.D. Fla. July 18, 2018) (damage to 

plaintiff’s home from Hurricane Irma); Siegel v. Tower Hill Signature Ins. Co., 225 So. 3d 974 

(Fla. Dist. Ct. App. 2017) (claim under homeowners’ insurance policy arising from drain line 

collapse under foundation of home); Harco Co. of Jacksonville, LLC v. Chubb Custom Ins. Co., 

No. 3:15-CV-818-J-39MCR, 2016 WL 7206177 (M.D. Fla. Mar. 18, 2016) (breach of contract for 

failing to pay for structural damages to apartment); N.P.V. Realty Corp. v. Nationwide Mut. Assur. 

Co., No. 8:14–CV–03235–T–17MAP, 2015 WL 3494127 (M.D. Fla. June 3, 2015) (action for 

damage to real property); Luciano v. United Prop. & Cas. Ins. Co., 156 So. 2d 1108 (Fla. Dist. Ct. 

App. 2015) (action for breach of homeowner’s insurance based on denial of claim for hurricane 

damage to home); Donovan v. Fla. Peninsula Ins. Co., 147 So. 3d 566 (Fla. Dist. Ct. App. 2014) 

(action against property insurer for failing to pay costs to comply with building codes in the repair 

of hurricane damage to insured’s property); Linares v. Universal Prop. & Cas. Ins. Co., 141 So. 

3d 719 (Fla. Dist. Ct. App. 2014) (breach of contract arising from denial of insureds’ claim for 

hurricane damage to home); Rizo v. State Farm Florida Ins. Co., 133 So.3d 1114 (Fla. Dist. Ct. 

App. 2014) (action arising from damages caused by Hurricane Wilma); Cypress Chase Condo. 

Ass’n A v. QBE Ins. Corp., No. 10–61987–CIV, 2013 WL 1191413 (S.D. Fla. Mar. 22, 2013) 

(property damage arising from Hurricane Wilma); Regency 288, LLC v. Glencoe Ins. Ltd., No. 12-

62461-Civ-SCOLA, 2013 WL 12092098 (S.D. Fla. Aug. 16, 2013) (damage to property resulting 

from Hurricane Wilma); Olear Org. v. North Pointe Ins. Co., No. 6:12–cv–850–Orl–28KRS, 2012 

WL 5471789 (M.D. Fla. Nov. 9, 2012) (plaintiff’s property was damaged by Hurricane Charley); 

Garden-Aire South Condo. Ass’n Inc. v. QBE Ins. Corp., 10-61985-CIVDIMITROULEAS/SNOW, 2012 WL 12861091 (S.D. Fla. Nov. 20, 2012) (property damage from 

Hurricane Wilma); West Palm Gardens Villas Condo. Ass’n, Inc. v. Aspen Specialty Ins. Co., No. 

11-23912-Civ, 2012 WL 3017083 (S.D. Fla. June 25, 2012) (homeowner’s insurance dispute 

involving loss from Hurricane Wilma); Kelly v. Balboa Ins. Co., 897 F. Supp. 2d 1262 (M.D. Fla. 

2012) (dispute involving loss to real property); Allstate Ins. Co. v. Country Club Apartments, NO. 

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no applicability here. The five-year statute of limitations began to run on the date of Federal’s 

breach, not the date of Raymond James’ loss. Raymond James plainly brought this action within 

the five years of Federal’s breach of the Bonds.

Alternatively, Federal contended that Raymond James’ claim is barred by the two-year suit 

limitation imposed by the Bonds. Florida law is clear, however, that any contract provision that 

seeks to reduce the limitations period is void. See Fla. Stat. 95.03 (“Any provision in a contract 

fixing the period of time within which an action arising out of the contract may be begun at a time 

less than that provided by the applicable statute of limitations is void”); Montroy v. State Farm. 

Mut. Auto. Ins. Co., No. 8:12-CV-1871-T-24EAJ, 2012 WL 4746407, at *4 (M.D. Fla. Oct. 4, 

2012) (limitations period in insurance policy reducing statute of limitations to two years was void 

under Florida law); N.P.V. Realty Corp. v. Nationwide Mut. Assur. Co., No. 8:14–CV–03235–T–

17MAP, 2015 WL 3494127, at * 4 (M.D. Fla. June 3, 2015) (provision in policy requiring legal 

action within five years of when loss occurred is void). 

Simply put, an insurance policy that is subject to Florida law cannot reduce the statute of 

limitations to file an insurance coverage lawsuit to less than five years. “Therefore, the Florida 

rule governing the statute of limitations for claims made under an insurance policy applies, and 

[Raymond James] ha[d] five years to bring suit.” Montroy, 2012 WL 4746407. Because Raymond 

James brought this action within five years of Federal’s breach, Raymond James’ claims are not 

barred by the applicable statute of limitations or the void contractual limitations period in the 

 

11-61907-CIV-SEITZ/SIMONTON, 2012 WL 13008297 (S.D. Fla. Jan. 13, 2012) (claim for 

damages to property as a result of Hurricane Wilma).

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Bonds. Raymond James thus is entitled to summary judgment on Federal’s Twenty-Eighth 

Affirmative Defense.

III. CONCLUSION

For all the foregoing reasons, the Court should grant the Motion and enter a partial 

summary judgment in favor of Raymond James and against Federal on Federal’s Seventh, Eighth, 

Ninth, Twenty-Second and Twenty-Eighth Affirmative Defenses.

Dated: July 30, 2021. Respectfully submitted,

/s/ Jason S. Mazer

Jason S. Mazer, Esq. 

Florida Bar No. 0149871 

Joshua R. Alhalel, Esq. 

Florida Bar No. 0016320

CIMO MAZER MARK PLLC

100 Southeast Second Street, Suite 3650

Miami, Florida 33131

Telephone: (305) 374-6481; Fax: (305) 374-6488

jmazer@cmmlawgroup.com

jalhalel@cmmlawgroup.com

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CERTIFICATE OF SERVICE

I hereby certify that on July 30, 2021, I electronically filed this Motion for Partial Summary 

Judgment Against Federal Insurance Company and Supporting Memorandum of Law with the 

Clerk of Court using CM/ECF. I also certify that the foregoing document is being served this day 

on parties listed in the below Service List via transmission of Notices of Electronic Filing 

generated by CM/ECF or in some other manner.

/s/ Jason S. Mazer

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SERVICE LIST

Kristina L. Marsh, Esq. 

Florida Bar No. 0311080

GORDON REES SCULLY MANSUKHANI

601 S. Harbor Island Blvd., Suite 109

Tampa, FL 33602

Telephone (Main): 813-444-9700

Telephone (Direct) 813-523-4937

Facsimile: 813-377-3505

kmarsh@grsm.com

and

Scott L. Schmookler, Esq.

Sarah Riedl Clark, Esq.

GORDON REES SCULLY MANSUKHANI

One North Franklin, Suite 800

Chicago, IL 60606

Telephone: 312-980-6779

sschmookler@grsm.com

srclark@grsm.com

Counsel for Federal Insurance Company

James M. Kaplan, Esq. 

Florida Bar No. 921040

KAPLAN ZEENA LLP

2 South Biscayne Boulevard, Suite 3050

Miami, Florida 33131

Telephone: (305) 530-0800

Facsimile: (305) 530-0801

James.kaplan@kaplanzeena.com

Elizabeth.salom@kaplanzeena.com

service@kaplanzeena.com

and

Michael Keeley, Esq.

John R. Riddle, Esq.

C. Adam Brinkley

Clark Hill Strasburger

901 Main Street, Suite 6000

Dallas, Texas 75202-3794

Telelphone: (214) 651-4718

Facsimile: (214) 659-4121

mkeeley@clarkhill.com

jriddle@clarkhill.com

abrinkley@clarkhill.com

Counsel for Beazley Insurance Company, Inc.

E.A. “Seth” Mills, Jr., Esq. 

Florida Bar No. 339652 

Ryan J. Weeks, Esq.

Florida Bar No. 57897

MILLS PASKERT DIVERS

100 N. Tampa Street, Suite 3700

Telephone: (813) 229-3500

Facsimile: (813) 229-3502

smills@mpdlegal.com

rweeks@mpdlegal.com

csoltis@mpdlegal.com

Counsel for Travelers Casualty and Surety 

Company of America

Dustin C. Blumenthal

Florida Bar No. 0149871 

Goldberg Segalla

222 Lakeview Avenue, Suite 800

West Palm Beach, FL 33401

Telephone: (561) 618-4485

Facsimile: (561) 618-4549

dblumenthal@goldbergsegalla.com

lparker@goldbergsegalla.com

and

Stephen N. Dratch, Esq.

Franzblau Dratch, P.C.

354 Eisenhower Parkway

Livingston, New Jersey 07039

Telephone: (973) 992-3700

Counsel for Great American Insurance Company

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