CERT RESTORATION, LLC
v.
CITIZENS PROPERTY INSURANCE CORPORATION

Fla. 4th DCA | 2022-02-16
No. 2021-1473
324 So. 3d 5 Florida District Court of Appeal, Fourth District (2022) Positive Treatment
Cited by 1 case
Opinion of the Court

PER CURIAM.

Affirmed. See First Call 24/7, Inc. v. Citizens Prop. Ins. Corp., 46 Fla. L. Weekly D2419 (Fla. 4th DCA Nov. 10, 2021).

CIKLIN, GERBER and FORST, JJ., concur.

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  • Dri Force Restoration, Inc. v. Citizens Prop. Ins. Corp. (Fla. 3d DCA 2026)
    …olicy. Florida courts, however, have held that debris removal services performed in conjunction with reasonable emergency measures services do not qualify as a separate charge. In Certified Priority Restoration v. Citizens Property Insurance Corp., 324 So. 3d 5 (Fla. 4th DCA 2021), for example, the Fourth District addressed the exact situation presented in this case. There, an insured hired a company to provide "water removal and remediation services.” Id. at 7. As part of those services, the company was r…

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