Disaster Recovery and Planning

by Gary A. Poliakoff, J.D.

www.hurricane-recovery.com
Disaster Planning and Recovery
by Gary A. Poliakoff, J.D.*
2
*Gary A. Poliakoff, J.D., is a founding principal of Becker & Poliakoff, P.A., a law rm which for over 35 years,
has provided legal counsel to more than 7,000 Condominium, Cooperative and Homeowners Associations.
He is an adjunct professor at the Shepard Broad School of Law, Nova Southeastern University and the author
of a national treatise, The Law of Condominium Operations, published by West Group, 1988.
Photograph by: Gary A. Poliakoff, J.D.
H
urricane Andrew, which devastated South Miami-Dade on August 24,
1992, opened our eyes to the vulnerability of common interest owner-
ship housing communities (i.e., condominiums, cooperatives, and deed
restricted communities governed by a mandatory membership homeowners
association) to catastrophic events. The lessons learned from Andrews 145
mph winds were accentuated by Hurricane Opal, which struck the Florida
Panhandle with 20 foot storm surges. These lessons were reinforced by the
storms of 2005 when seven major hurricanes crossed the state of Florida
leaving devastation in their paths.
In the aftermath of the storms, the importance of developing and imple-
menting a disaster plan became self-evident. This article is based upon rst
hand experience gained in assisting the victims of Hurricanes Andrew, Opal
and the hurricanes of 2004 and 2005 which devastated the state of Florida.
IDENTIFYING THE POTENTIAL
CONSEQUENCES OF A DISASTER
Prior to September 11, 2001, the term
disaster was generally associated with
naturally occurring events such as fire,
hurricane, earthquake, mudslides or floods.
Now, acts of terrorism need to be factored into
the equation. The first step toward developing
and implementing a disaster plan is identifying
the potential consequences of a disaster. They
include:

Destruction of Property
Improvements to Realty
Buildings
Landscaping
Roads and Pathways
Personalty
At risk are the furniture, fixtures and per-
sonalty of the association and the unit owners.
Those items of most concern to the association
include:
Furniture
Fixtures
Equipment, computers
Historical records
Data bases
Accounting records
Unit and personnel files
Loss of Life
In addition to the potential for permanent
injury, all disasters bring with them the risk of
loss of life. In addition to key members of
the board and committee chairs, this potentially
impacts management and staff, as well.
Relocation Caused by the Total or
Partial Destruction of the Premises
A properly prepared disaster plan will antic-
ipate and plan not only for the possibility of a
total casualty loss, but also the need to relocate,
temporarily or permanently, due to the loss of
both ones residence and, potentially, ones place
of work. While many individuals are able to
clean up their storm debris within a relatively
short period of time and return to their normal
3
routines, for tens of thousands of others, life
will remain in turmoil for years after being
impacted by a Hurricane. Opals devastation
caused a slightly different impact on the resi-
dents of Floridas Panhandle. Many residents
owned condominium units, which were placed
in rental pools and provided a source of revenue
for them, which was temporarily disrupted.
Emotional Impact
The psychological impact of disasters, even
those on a much smaller scale than a category
four hurricane or the events of 9/11, will linger
for years. In the case of Hurricane Andrew, the
fear of reliving another storm of similar magni-
tude caused some to move from Florida or to
vow never again to remain in their homes when
facing a similar threat. The events at the World
Trade Center have caused some to rethink liv-
ing or working in high rise structures.
Economic Impact
The economic impact of a disaster is felt on
many fronts. Unit owners displaced from work
may be unable to meet their nancial
obligations to the association. Uninsured,
underinsured or non-covered losses will neces-
sitate special assessments, which could further
stress the already overtaxed unit owners. The
higher cost of goods and services resulting from
shortages further compounds the problem.
Rippling Repercussions
No doubt all of us had empathy for the fami-
lies who lost loved ones at the World Trade
Center. But, as we watched the collapse of the
Twin Towers in dismay, how many said, I feel
terrible for all those families whose livelihoods
are dependent upon the ongoing viability of the
World Trade Center. Community associations
are no different. Surrounding every community
are hundreds of businesses which are depend-
ent upon the association and its residents for
their livelihood. Included are:
restaurants
hair salons
dry cleaners
daycare centers

messenger services
retail stores
doctors
attorneys
Then, of course, there are those who
directly service the community association
such as:
management
staff
pool maintenance
elevator maintenance
lawn maintenance
roofers
painters
air conditioning and heating contractors
security services
banks
accountants
attorneys
roong contractors
pavement contractors

bureaucrats
courts
process servers
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Designation of a
Disaster Coordinator
The ability of the commu-
nity association to react
quickly with a clear and
decisive plan, thereby mini-
mizing damages and speed-
ing up recovery, to a large
extent, will be dependent
upon the associations ability
to react quickly and deci-
sively when a disaster
strikes. The ability to do so is
dependent upon having a
person or committee in place prior to the disas-
ter with full power and authority to implement
the Disaster Plan.
Designation of an
Information Facilitator
In times of crisis, people want to know they
need to know! A major hurdle to recovery is
rumor and misinformation. Left unchecked,
both can hamper the recovery efforts. This can
be short-circuited through the use of an
Information Facilitator. Todays computer tech-
nology provides the ideal vehicle for this pur-
pose. Every association should have its own
website. During normal times, it is the ideal
resource for disseminating information and
staying in touch with the unit owners. At times
of a disaster, it is the vital link. The Information
Facilitator works in concert with the Disaster
Coordinator as a type of Press Secretary.
Disaster Preparedness
Protecting the Premises
Hurricane Shutters / Impact Glass

Central re alarm and smoke detection

system
Walled Community
Relocation: Where will I go?
A properly prepared plan will include plans
for temporary relocation of the residents in sit-
uations where the community must be evacu-
ated during the crisis. This can include Red
Cross or other emergency shelters, hotels,
schools, or staying with family in other cities.
Said relocation may require more extensive
stays during periods of reconstruction or sub-
stantial emergency periods. The residents of
Naranja Lakes and other communities devas-
tated by hurricanes were never able to return
to their homes and, today, are dispersed
throughout the world.
DEVELOPING A DISASTER PLAN
5
Photographic Imaging of
Premises and Records
Regardless of how
sharp ones memory might
be, there are few with a
photographic memory suf-
cient to withstand the
challenge of cross exami-
nation as to ones proof of
loss in any insurance dis-
pute. A necessary prereq-
uisite to disaster planning
is video documentation of
each unit owners home,
and the associations office
and property. Keep in
mind the old clich: a picture is worth a thou-
sand words. With todays digital technology,
photographic records can be conveniently and
safely stored off premises and easily retrieved,
if needed. In addition to photographic records
or videotaping of the community, it is also rec-
ommended that the records reect the date,
place and cost of each item of personalty. What
should be photographed? [For purposes of this
article, the term photograph and all deriva-
tives therefrom, includes all imaging, including
scanning of documents onto disc.]
Specically, include:
Inside and outside of buildings
and premises;
furniture;
xtures;
art work;
equipment/computers;
books;
accounting records;
les;
insurance policies;
bank accounts;
personnel records;

records of units/unit owners;

as-built plans and specications.

Quick Reference List
In addition to photographic records,
quick reference lists might contain:

Record Title Owners

names
unit numbers
other residences
next of kin/emergency contacts
identifying features
social security numbers
medications
cell phone numbers
e-mail addresses (maintained in groups)
Association Employees
names
addresses
phone numbers
cell phone numbers
e-mail addresses
social security numbers
next of kin/emergency contacts
medications
Bank Account(s)
bank/location address
account numbers authorized signatures
certicates of deposits and/or other
investment documents
6
Insurance Policies
nature and extent of coverage carrier
policy number
agents with pertinent information
Vendor List listed by service provided;
e.g., pool maintenance, security, landscape
maintenance, etc.
Professionals
CPA
insurance agent
attorney
management

Inventory of Furniture and Equipment

Storage of Emergency Supplies. Most casu-
alties, such as re, generally affect only the
immediate residents, who can be evacuated to
nearby hospitals, hotels or emergency facilities.
Finding food, shelter and clothing is not an
issue. However, in the case of a widespread dis-
aster, such as a major hurricane, residents
might be forced to stay in their damaged homes
and neighborhoods for extended periods of
time. A disaster plan should consider the need
for emergency medical supplies, food, water,
waterproof matches, a debrillator, and an
emergency generator; and an ample supply of
fuel to power the generator for an extended
period of time. In addition, tools, which might
be required to excavate someone from a col-
lapsed structure, such as shovels, crowbars and
a power saw, might be considered.
Building Plans. A set of as-built plans and
specications is essential to both the immedi-
ate response and long term recovery. Knowing
the whereabouts of shut-off valves and struc-
tural components can be the difference
between life and death. The as-built drawing
will greatly facilitate the reconstruction effort.
Along with the building plans, should be the
names, addresses, telephone numbers and
e-mail addresses of the architects, engineers,
contractors and sub-contractors who designed
and built the structures. They can be an invalu-
able resource in disaster recovery.
Emergency Planning
Evacuation Route. Every high rise structure
should have emergency evacuation routes
visibly posted.
Fire and Emergency Evacuation Drills. It is not
childish to take a lesson from our youth and, on
a periodic basis, rehearse evacuation of the
building.
Buddy System. This is another positive lesson
from our childhoods. Valuable time can be
saved if your neighbors know your whereabouts
at the time of an emergency. For example, if the
Fire Department is informed that the Smiths
are in Europe, by their neighbors, emergency
response teams can focus their efforts on known
victims. It is particularly important to be aware
of special needs residents who might require
medications or special assistance.
Data Inventory
Separate and apart from the inventory of the
physical resources of the association is the
need to maintain a record of information main-
tained in data processing and information
systems. Where appropriate, a list of source
codes and/or vendor sources should be
maintained.
7
RISK MANAGEMENT
8
A well-designed disaster plan will include
hedges against risk which are designed to mini-
mize economic and property loss, as well as the
loss of human life. Options include:
Maintenance of Adequate Insurance
Maintaining adequate insurance is easier
said than done. Both the high cost of insurance
and the unavailability of carriers willing to pro-
vide coverage often force Associations to
acquire coverage from non-admitted carriers,
or to maintain deductibles at levels higher than
desirable.
When acquiring Condominium Insurance
one must be conversant with the statutory man-
dated guidelines which impose upon the Board
the duty to maintain adequate insurance,
which coverage may include reasonable
deductibles as determined by the Board. And,
one must review statutory mandates along with
provisions of the governing documents to deter-
mine whether the Association or the unit
owner(s) is responsible for providing cover for
unit improvements.
In addition to basic coverage, experience has
taught us that some major sources of economic
loss, such as landscaping, exterior building
paint, building foundations, walkways, pools,
tennis courts, and satellite dishes, are not nor-
mally covered by insurance. While excluded
from basic coverage, some areas of potential
loss can be covered for a small additional pre-
mium. None are as important as ordinance or
law exclusion.
Ordinance or law exclusion states that the
insurer will not pay for loss or damage caused
directly or indirectly by the enforcement of
any ordinance or law: (1) regulating the con-
struction, use or repair of the property; or (2)
requiring the tearing down of any property,
including the cost of removing its debris. This
exclusion is aimed at the application of build-
ing codes that may require more expensive
reconstruction material, installation, design
or methods than those used in the existing
building. It may also apply to environmental
laws that require elaborate and expensive
decontamination processes, or upgraded con-
struction practices in hurricane and ood
zones.
For example, following Hurricane Andrew,
a Miami-Dade County Ordinance required
that a number of partially damaged buildings
[considered to be damaged by 50% or more]
could be restored only if they were elevated to
a specic height above sea level. Under such
circumstances, the cost of elevation plus
repair of the damage, generally would exceed
the limit of building insurance, unless there
was coverage afforded under the rider to the
base policy.
Many communities were left waterlogged
by Hurricanes Andrew and Opal, only to nd
that their basic policies did not cover water
damage from ooding. Effective October 1,
1994, all condominiums in ood zones are
required to purchase ood insurance equal to
eighty (80%) percent of the value of the build-
ing, not to exceed a total limit of $250,000 per
unit. New ood policies include coverage for
foundations. The entire building is covered
under one policy, including both the common
elements and the individual units.
For many owners and managers in the
Florida Panhandle, the greatest loss wasnt
property but, rather income from lost rentals.
Business interruption insurance is essential
for owners or managers who rely upon vaca-
tion rentals for their livelihood. Managers,
particularly, need to ensure that their busi-
ness interruption coverage is not just for the
premises where they maintain their offices,
but also for the communities where they
manage rental units.
Many homeowners failed to maintain cov-
erage for their personal effects and building
upgrades within their homes. It is recom-
mended that homeowners residing in common
interest ownership housing communities
maintain homeowner coverage with at least
the following endorsements:
Loss Assessment Coverage. Protects
against special assessments levied by boards
to cover losses from covered peril, when the
primary coverage is inadequate.
Water Seepage Coverage. Covers water
damage from wind-driven rain or water enter-
ing from a source other than an opening in the
building (e.g., through stucco or around win-
dow frames).
Additions, Alterations, Improvements and
Betterments Coverage. Covers upgrades, as
well as real property added by the unit owner.
This endorsement is often available with all
risk coverage, without a water seepage exclu-
sion.
Even assuming that one maintains ade-
quate coverage, there is a risk that not every
insurer will survive extraordinary claims.
Andrew brought many insurance companies
to their knees. Careful consideration must be
given to the nancial strength of the insurer.
Keep in mind that the lowest quote is not
always the most secure coverage.
It is imperative that a reserve fund be
maintained for contingencies and to cover
deductibles.
Specialty Services
These are pre-negotiated contracts
specically designed and written with disas-
ter in mind. The services included are:
Drying In or Shoring up the premises.
Drying Out
Debris removal
Security. Although the National Guard was
ultimately mobilized to prevent looting in the
aftermath of Andrew, initially, many property
owners had to resort to their own means to
protect their property and their families.
9
Reconstruction
State laws and document restrictions
designed to insure owner access to information
and input in the decision-making process often
impede disaster recovery. For example, the use
of reserve funds in an emergency is hampered
by laws requiring prior approval by a majority
of the voting interests present, in person or by
proxy, at a meeting. If necessary, documents
should be reviewed and amended to remove
barriers to recovery and provide boards with
emergency powers. Areas of concern include:
Insurance Trustee Provisions. Generally
found within the insurance section of the docu-
ments, these provisions require that the pro-
ceeds of insurance settlements be paid to a
third party for disbursement at the instruction
of the associations engineer. When such a pro-
vision exists, insurers will not pay proceeds to
the association until a trustee is designated.
This can critically delay the receipt of funds
necessary for disaster response. It is preferable
for the board to act as a trustee with dis-
bursements being authorized only when
approved in advance by an independent engi-
neer or construction manager employed by the
association.
Access to Units. While the Condominium and
Cooperative Acts grant associations an irrevoca-
ble right of access when necessary for the main-
tenance, repair or replacement of the common
elements or of any portion of a unit to be main-
tained by the association or as necessary to pre-
vent damage to the common elements or to a
REMOVE THE BARRIERS TO RECOVERY
10
unit or units, a gray area exists in relation to the
repair or reconstruction of portions of the units
maintained by the unit owners. To avoid con-
icts, all common interest ownership housing
documents should be amended to provide:
Right of access to the units to repair or
replace any portion of the property insured by
the association.
Association as agent: The association should
be irrevocably appointed as agent for each unit
owner, each owner of a mortgage or other lien
upon a unit and each owner of any other inter-
est in the property, in order to adjust all claims
arising under insurance policies purchased by
the association and to execute and deliver
releases upon the payment of claims.
It is of interest to note that in the aftermath
of Hurricane Opal, Floridas Division of Florida
Land Sales, Condominiums and Mobile Homes
affirmed the right of an association to enter the
unit to remove the carpet, cabinets, hot water
heater, and other appliances damaged by the
storm. [See In Re Petition for Arbitration
Higdin v. Seaspray Condominium Association,
Inc. Case No. 96-0430].
Powers of Board or Disaster Coordinator
to Act in an Emergency
Members of the board (though less than a
quorum) and/or a designated disaster coordina-
tor, who act in good faith without pecuniary
gain, should be indemnied from actions by
members of the association and should have
emergency powers, including, but not limited
to, the power to contract for: (1) emergency
services; (2) security from vandalism; (3)
removal of debris; and (4) engineering and
other professional services to assist in disaster
recovery.
Reconstruction vs. Termination
The unit owners at one South Miami-Dade
County condominium destroyed by Hurricane
Andrew were shocked to learn of a provision in
their declaration of condominium which pro-
vided for automatic termination when damage
exceeded fty (50%) percent or more of the
condominium, unless a majority of the total vot-
ing interests voted within sixty days to rebuild.
Since the unit owners had scattered all across
the country, the association had to seek court
relief to prevent the activation of the provision.
It is preferable for the documents to require a
vote of the owners to terminate the condo-
minium, not to rebuild it. That said, The
Condominium Act was amended subsequent to
the hurricanes of 2004 and 2005 to provide a
method for terminating condominiums in the
event of economic waste, disrepair of the prop-
erty and when continued operation of the con-
dominium is made impossible by law or
regulation. In the event of economic waste, the
percentage needed to terminate the lesser of
the lowest percentage of voting interests
needed to amend the declaration for termina-
tion of the condominium.
The 50% Rule
Even if your condominium does not contain
an automatic termination provision, a regula-
tion of the National Flood Insurance Program,
as adopted by most counties and cities, will sig-
nicantly impact an associations ability to
reconstruct based upon the adequacy of insur-
ance proceeds and other funds. The 50% Rule
provides that if the condominium/home is
below the 100-year ood elevation, and if the
condominium is substantially damaged
or substantially improved, the condo-
minium/home will be required to be rebuilt
based upon current building codes, which
11
might necessitate tearing it down, raising the
elevation, and then reconstructing it.
A quick response in accordance with precon-
ceived plan will minimize damage and promote
a speedy recovery. After the disaster, associa-
tions should take steps to:
Account For Residents. Knowing the where-
abouts of all residents greatly enhances emer-
gency response time following a disaster. In a
situation such as a hurricane, in which there is
advance warning, a committee should ascertain
which residents are remaining in the commu-
nity and which are evacuating. A temporary
destination address and phone number should
be obtained from those who are evacuating.
Once disaster strikes, the boards rst action
should be to direct emergency medical assis-
tance to any residents in need.
Attending to the injured.
Securing the community from acts of
vandalism and looting.
Removal of storm debris
Drying In/Shoring Up the building
structures in order to mitigate against
further damage.
Drying Out. This is the removal, where
necessary, of wet carpet, wall board,
cabinets, etc. when necessary to prevent
the growth of mold.
Survey the Property and Identify Areas
Needing Priority Attention. Depending upon
the nature and extent of the damage, it may be
necessary to evacuate the premises or shore-up
the structure. In some cases, it may be neces-
sary to hire security personnel to protect
against vandalism, theft and other criminal
activities. In the case of widespread disaster,
unit owners will not be able to depend upon
local law enforcement agencies whose attention
might be diverted to higher priority matters.
Arrangements for security, debris cleanup and
emergency repairs should be made as part of a
disaster plan, not after the fact, when it will be
difficult, if not impossible, to nd help.
Activate the Plan. Following a disaster, the
disaster coordinator and information facilitator
move into action. The information facilitator
opens lines of communications with the unit
owners. The disaster coordinator contacts emer-
gency services and noties the contractors and
employees, advising of their duties and needs.
In some cases, it may be necessary to suspend
or cancel on-going contracts such as lawn and
pool maintenance. Hopefully, provision was
made in the contract for such right of suspen-
sion without penalty in situations such as a dis-
aster when the contracted services are no
longer needed.
ACTIVATING THE DISASTER PLAN
12
Within hours of any disaster, the affected
community will be besieged by companies and
individuals looking for work and/or offering dis-
aster recovery services. This group will consist
of qualied professionals, ranging from public
adjusters to companies specializing in disaster
recovery. The larger of these companies will
arrive decked out in color-coordinated uni-
forms, large debris removing equipment and
even helicopters. Interspersed among the new
arrivals will be the con men and proteers who
prey upon the misfortune of others. While it is
very tempting to sign the rst contract stuck in
your face, when confronted with what initially
will appear to be an insurmountable task of
reconstruction, experience has shown that
these quick solutions are formulas for disasters
of greater magnitude than those already suf-
fered. No greater application exists for the old
adage that haste makes waste than in these
situations. The best advice is to just say no and
stick to your disaster plan which, hopefully, will
include a plan that anticipates the ve (5)
phases of reconstruction:
Project planning/scheduling;
Construction bidding;
Contract negotiations;
Construction/rehabilitation; and
Project completion/close out.
There are intervening steps you should take
which may require contracts of short duration
and for specic purposes. Even these contracts
should be reviewed to insure that proper pre-
cautions are taken.
AVOIDING THE PITFALLS OF DISASTER
RECOVERY
Disputes between insurance carriers (ood,
windstorm, hazard) and the Association over
the nature and extent of damage, cost of repair
or replacement, and/or whether appropriate
mitigation was effectuated.
Claims made by unit owners against their
Boards over the mismanagement of insurance
proceeds.
The Association owes a duty to the
owners and their mortgages to exercise
reasonable care in the management of the
insurance proceeds and to hold the proceeds for
the benet of the owners and mortgages.
Claims of contractors, sub-contractors, mate-
rial men and suppliers, who were not paid by
the general contractor, resulting in the
Associations having to pay double because of
its failure to comply with Floridas Construction
Lien Law.
Suits against contractors and subcontractors
over poor quality repairs.
HASTE MAKES WASTE IN RECONSTRUCTION
13
RESTORATION OF THE PROPERTY
Once conditions stabilize, the disaster recov-
ery team will be in a position to meet with pro-
fessionals trained in disaster recovery, such as:
Architect/Engineer Responsible for assess-
ing the damage, preparing plans and specica-
tions in accordance with new building codes,
assisting in selection of construction manager
and dening other reconstruction require-
ments.
Construction Manager Oversees selection
of general contractor, competitive bidding and
administrators; directs and coordinates pay req-
uisitions, change orders and all other activities
of the parties; and resolves disputes.
General Contractor Employs and super-
vises laborers, supplies materials and builds
project in accordance with architects/engi-
neers plans and specications, under the direc-
tion of the construction manager.
Attorney Reviews construction contracts
to insure adequate assurance of job perform-
ance and warranties, and compliance with
applicable lien laws.

Public Adjuster In some instances, the

assistance of an independent public adjuster
may be benecial when dealing with the nui-
sances of an ambiguous insurance policy. While
most adjusters will work for a fee based upon a
percentage of the insurance proceeds, when the
scope of assistance required is limited to spe-
cic items, the fee should be adjusted
accordingly.
Review your governing documents; particu-
larly, the repair after casualty section of the
insurance provision. It is common to nd lan-
guage such as the following:
Estimates of Costs Immediately after
deciding to rebuild or repair damage to prop-
erty for which the association is responsible, the
association shall obtain reliable and detailed
estimates of the cost to rebuild or repair.
Construction Fund The construction fund
shall be disbursed in payment of such costs in
the manner required by the board of directors
of the association upon approval by an archi-
tect qualied to practice in Florida and
employed by the association to supervise the
work.
When the aforesaid provisions exist in your
documents, contracting for reconstruction prior
to obtaining a scope of work will be contrary to
both the associations best interest, and the
obligations set forth in the documents.
In order to respond to an emergency, the
association may need to obtain a short-term
14
loan. Without a restriction in the documents,
not-for-prot community associations can bor-
row; however, they generally cannot pledge the
condominium property as security. Most banks
with which the association does business will
approve a commercial line of credit secured by
the associations accounts and/or assessment
and lien rights. The association also may obtain
a small business administration loan that is
available to victims of disaster, generally, at
lower interest rates. Of course, reserve funds
can also be utilized if approved by a majority of
the total voting interests.
On television, within minutes of a disaster,
an insurance adjuster appears on the scene
with checkbook in hand. In the space of a thirty
second commercial, all claims are resolved, and
the victims shower praise on the companys
quick response and positive attitude. While it
does occasionally happen, it is an unlikely sce-
nario. In a major disaster, it is rare, if not
impossible, to fully assess the damages within
such a short timeframe. In fact, the association
should not seriously entertain a settlement
until the full scope of work is known and costs
ascertained.
Immediately following the disaster, it will be
necessary for the association to secure the
property to mitigate against further damage
and clean-up debris. Most insurers will offer
advances for this purpose. As long as the asso-
ciation doesnt sign any releases or settlements,
there is nothing wrong with accepting such
advances.
Insurance policies need to be examined to
ensure that proof of loss forms are led
within the time limit required under the
policies. As a general rule, ood policies
require that proof of loss be led within sixty
days of the ood.
CONCLUSION
Disasters do not respect geographic location
or economic status and can occur at any time.
Their effects can last for years; however, predis-
aster readiness coupled with a well-orches-
trated and executed disaster plan will minimize
damages and promote a speedy recovery.
SETTLING THE INSURANCE CLAIMS
15

Administrative Offlce
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3111 Stirling Road
Ft. Lauderdale, FL 33312-6S2S
9S+.987.7SS0
800.+32.7712


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