FILED
`DALLAS COUNTY
`10/31/2018 10:56 AM
`FELICIA PITRE
`DISTRICT CLERK
`
`Martin Reyes
`
`CAUSE NO. DC1814521
`
`
`CARLISLE A. BRAUN,
`
` Plaintiff,
`
`vs.
`
`ALLSTATE VEHICLE AND
`PROPERTY INSURANCE COMPANY,
`
` Defendant.
`
`
`
`
`
`
`
`
`
`
`
`
`
`IN THE DISTRICT COURT
`
`
`
`162ND JUDICIAL DISTRICT
`
`
`
`DALLAS COUNTY, TEXAS
`
`DEFENDANT’S MOTION TO DISMISS FOR LACK OF JURISDICTION
`
`TO THE HONORABLE JUDGE OF SAID COURT:
`
`
`
`NOW COMES ALLSTATE VEHICLE AND PROPERTY INSURANCE COMPANY,
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`hereinafter referred to as "Defendant," and files this following DEFENDANT’S MOTION TO
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`DISMISS FOR LACK OF JURISDICTION and in support thereof would show the Court as
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`follows:
`
`I.
`
`SUMMARY OF ARGUMENT
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`Defendant seeks to enforce its no-action clause, which expressly requires an insured to
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`submit a signed and sworn proof of loss (“POL”) 91 days before filing a lawsuit against Allstate.
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`Plaintiff Carlisle A. Braun (“Plaintiff”) agreed to this language in his homeowner’s insurance
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`contract. Instead of returning a signed and sworn POL, however, Plaintiff filed this lawsuit in
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`violation of the express condition precedent to filing suit. Because Plaintiff has not yet complied
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`with the POL condition to sue, this lawsuit is not ripe for this Court’s consideration and should be
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`dismissed without prejudice to allow the parties to pursue the contractually agreed upon
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`mechanism for resolving disputes such as this one.
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`

`

`
`
`I I .
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`
`
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`SUPPORTING EVIDENCE
`
`Exhibit 1
`
`Affidavit of Steven Mielke
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`Exhibit 2
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`Certified copy of Homeowner’s Policy no. 000836924202, issued by
`Allstate Vehicle and Property Insurance and effective April 29,
`2018through April 29, 2019.
`
`I I I .
`
`
`
`
`
`BACKGROUND FACTS
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`Defendant issued Plaintiff homeowners policy no. 000836924202, effective April 29, 2018,
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`through April 29, 2019. (Certified copy of Allstate Vehicle and Property Insurance Company’s
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`Policy attached as Exhibit “2.”). The policy includes an explicit condition that Plaintiff was
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`contractually obligated to satisfy if she disagreed with Defendant’s loss determination and before
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`she filed a lawsuit against Defendant. The policy provides:
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`
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`13.
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`Action Against Us
`
`No one may bring an action against us in any way related to the
`existence or amount of coverage, or the amount of loss for which
`coverage is sought, under a coverage to which Section I
`Conditions applies, unless:
`
`* * *
`
`c)
`
`in the event that you and we fail to agree on the
`amount of loss claimed by you, unless you have
`previously provided to us a signed sworn proof of
`loss, it is a condition under this Action Against Us
`provision that no later than 91 days prior to
`commencing any action against us that we receive
`from you a signed sworn proof of loss, which
`contains, to the best of your knowledge and belief,
`the following information:
`
`1)
`
`the date, time, location and cause of
`loss;
`
`Botkin vs. Allstate
`DEFENDANT’S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION
`0493178131.1
`
`
`PAGE 2
`
`
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`

`

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`
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`2)
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`3)
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`4)
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`5)
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`6)
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`7)
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`8)
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`the interest insured persons and
`others have in the property, including
`any encumbrances;
`
`any other insurance that may cover
`the loss;
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`any changes in title, use, occupancy
`or possession of the property that
`have occurred during
`the policy
`period;
`
`at our request, the specifications of
`any damaged building structure or
`other structure;
`
`the estimated or actual cost to repair
`or replace the property stolen or
`damaged by the loss with materials
`of like kind and quality;
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`the amount you have actually spent to
`repair or replace the property stolen or
`damaged by the loss; and
`
`in the event that you give us a signed
`proof of loss, and after submitting
`that to us, you determine that you
`want to include a claim for additional
`damage or loss, you must submit to
`us a supplemental proof of loss
`which identifies the amount of the
`additional
`loss
`for
`each
`item
`damaged or stolen.
`
`d)
`
`If after we receive your proof of loss as described
`in paragraph c) above, you and we are still not able
`to agree on the amount of loss, then either party
`may make a written demand for an appraisal, as
`described in Section I Conditions, Appraisal. If
`this demand for appraisal is made before an action
`is filed against us in a court of competent
`jurisdiction, then appraisal must occur before a suit
`can be filed against us. If the demand for appraisal
`is made after an action has been filed against us in
`
`Botkin vs. Allstate
`DEFENDANT’S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION
`0493178131.1
`
`
`PAGE 3
`
`
`
`

`

`
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`a court of competent jurisdiction, then the parties
`agree to ask the court to abate the further
`proceeding of that action until the appraisal is
`completed and a determination of the amount of
`loss is made as described in (Exhibit 2 at p. 2 of 3)
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`On or about August 11, 2018, Plaintiff’s house, located at 4136 Meadowlane, Dallas,
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`Texas, allegedly suffered damages during a hail and windstorm. (See Plaintiff’s Original
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`Petition) On August 17, 2018, Plaintiff reported the claim to Allstate. (Affidavit of Steven
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`Mielke attached as Exhibit 1 at ¶ 3-4.). On August 28, 2018, Allstate adjuster Brett Holcomb
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`(“Adjuster”) inspected Plaintiff’s property. The Adjuster’s inspection revealed three wind
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`damaged shingles and very minor hail damage to a storm cap. Damage to the front porch soffit
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`was found to be an ongoing issue. Id. Allstate’s estimate totaled $3,383.80. After application of
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`the $3,600.00 deductible, Allstate paid Plaintiff $0 for her claim as the damages fell below the
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`deductible.
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`Plaintiff did not return a signed and sworn proof of loss. (Exhibit 1 at ¶ 5.) Instead, on
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`September 24, 2018, Plaintiff filed this lawsuit.
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`
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`IV.
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`ARGUMENT AND AUTHORITIES
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`A.
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`It is the Plaintiff’s Burden to Establish Subject Matter Jurisdiction
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`Plaintiff has the burden to affirmatively demonstrate the trial court's jurisdiction.
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`
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`Heckman v. Williamson County, 369 S.W.3d 137, 150 (Tex. 2012). When assessing a
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`jurisdictional challenge, a court’s analysis begins with the live pleadings. Id. A court may also
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`consider evidence submitted by the defendant to negate the existence of jurisdiction—and the
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`court must consider such evidence when necessary to resolve the jurisdictional issue. Id. A plea
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`to the jurisdiction is the proper vehicle for challenging ripeness, which focuses on when a lawsuit
`
`Botkin vs. Allstate
`DEFENDANT’S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION
`0493178131.1
`
`
`PAGE 4
`
`
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`

`

`
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`may be brought. See Waco ISD v. Gibson, 22 S.W.3d 849, 851-52 (Tex. 2000); Patterson v.
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`Planned Parenthood, 971 S.W.2d 439, 442 (Tex. 1998).
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`B.
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`This Court Lacks Subject Matter Jurisdiction to Hear This Lawsuit Because
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`Plaintiff’s Claims Are Not Ripe – The Express Condition Precedent to Filing
`a Lawsuit is not satisfied.
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`Historically, proof of loss (“POL”) policy conditions were independent of the no-action
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`(“Action Against Us”) clause under a property policy, and they were necessary conditions
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`precedent for recovery under a policy. Am. Teachers Life Ins. Co. v. Brugette, 728 S.W.2d 763,
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`764 (Tex. 1987); First Sw. Lloyds Ins. Co. v. MacDowell, 769 S.W.2d 954, 959 (Tex. App.—
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`Texarkana 1989, writ denied); see Hanover Ins. Co. of New York v. Hagler, 532 S.W.2d 136, 137
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`(Tex. Civ. App.—Dallas 1976, writ ref’d n.r.e.) (“It is a settled principle of law in Texas that a
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`stipulation in an insurance contract requiring notice and proof of loss within a reasonable time
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`and on reasonable terms is valid and must be complied with to recover under the policy.”);
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`McKay v. American Central Ins. Co., 245 S.W.2d 529, 530 (Tex. App.—San Antonio 1952, no
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`writ) (filing of a proof of loss is a prerequisite to recover on the policy). A condition precedent is
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`an event that must happen or be performed before a right can accrue to enforce an obligation.
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`Solar Applications Eng’g, Inc. v. T.A. Operating Corp., 327 S.W.3d 104, 108 (Tex. 2010)
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`(quoting Centex Corp. v. Dalton, 840 S.W.2d 952, 956 (Tex.1992)). “Conditions precedent to an
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`obligation to perform [under a contract] are those acts or events, which occur subsequently to the
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`making of a contract, that must occur before there is a right to immediate performance and before
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`there is a breach of contractual duty.” Beacon Nat’l Ins. Co. v. Glaze, 114 S.W.3d 1, 3 (Tex.
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`App. – Tyler 2003, pet. denied) (citing Hohenberg Bros. Co. v. George E. Gibbons & Co., 537
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`S.W.2d 1, 3 (Tex.1976)). “Where furnishing proof of loss is a condition precedent to liability, no
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`right of action lies against the Insurer until the condition is performed, or its performance has
`
`Botkin vs. Allstate
`DEFENDANT’S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION
`0493178131.1
`
`
`PAGE 5
`
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`

`

`
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`been waived or excused.” Aetna Ins. Co. v. Durbin, 417 S.W.2d 485, 486-87 (Tex. Civ. App.—
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`Dallas, 1967, no writ) (citing Whitehead v. Nat. Casualty Co., 273 S.W.2d 678, 680 (Tex. Civ.
`
`App.—Fort Worth 1954, writ ref’d).
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`Defendant’s new no-action/“Action Against Us” clause specifically requires the insured
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` to send Allstate a signed and sworn POL at least 91 days before suing Allstate. The
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`language is clear: Plaintiff cannot file suit against Allstate disputing the amount of loss unless he
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`has submitted a signed and sworn POL at least 91 days before filing suit. This condition is
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`designed to allow Allstate an opportunity to investigate the insured’s dispute of the loss amount
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`and, if desired, to negotiate a settlement or to invoke appraisal before Plaintiff commences
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`litigation. (Exhibit 2 at p. 49-50.) The purpose of requiring a sworn and signed proof of loss is
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`“to enable the insurer to properly investigate the circumstances of the loss while the occurrence is
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`fresh in the minds of witnesses, to prevent fraud, and to enable it to form an intelligent estimate
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`of its rights and liabilities so that it may adequately prepare to defend any claim that may arise.”
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`Hanover Ins. Co. of New York v. Hagler, 532 S.W.2d 136, 138 (Tex. Civ. App.—Dallas 1975,
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`writ ref’d n.r.e.); see also First Southwest Lloyds Ins. Co. v. MacDowell, 769 S.W.2d 954, 959
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`(Tex. App.—Texarkana 1989, writ denied) (purpose of proof of loss is to apprise the insurer of
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`the facts); Dairyland Cty. Mut. Ins. Co. v. Keys, 568 S.W.2d 457, 459 (Tex. Civ. App.—Tyler
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`1978, writ ref’d n.r.e.) (same).
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`Texas courts have long construed insurance policies according to the general rules of
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`contract construction to ascertain the parties’ intent. Gilbert Texas Constr., L.P. v. Underwriters
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`at Lloyd’s London, 327 S.W.3d 118, 126 (Tex. 2010) (citing Don’s Bldg. Supply, Inc. v.
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`OneBeacon Ins. Co., 267 S.W.3d 20, 23 (Tex. 2008)). Courts should look at the language of the
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`policy because it assumes the parties intended what the words of their contract say. Id. And if an
`
`Botkin vs. Allstate
`DEFENDANT’S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION
`0493178131.1
`
`
`PAGE 6
`
`
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`

`

`
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`insurance policy provision is clear and unambiguous, then it must be enforced according to its
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`terms. Puckett v. U.S. Fire Ins. Co., 678 S.W.2d 936, 938 (Tex.1984). Courts should strive to
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`honor the parties’ agreement and not to remake their contract by reading additional provisions
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`into it. Gilbert Texas Constr., 327 S.W.3d at 126.
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`There is no dispute as to the existence and express language of the “Action Against Us”
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`clause under the policy. Further, Plaintiff is presumed to have read the policy and agreed to its
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`terms. See Rice v. Metro. Life Ins. Co., 324 S.W.3d 660, 675 (Tex. App.—Fort Worth 2010, no
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`pet.); Jenkins v. State & County Mut. Fire Ins. Co., 287 S.W.3d 891, 897 (Tex.App.—Fort Worth
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`2009, pet. denied). Plaintiff thus has a clear contractual obligation to provide Allstate a signed
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`and sworn proof of loss before filing a lawsuit. This Court should therefore honor the “Action
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`Against Us” clause’s plain meaning. Balandran v. Safeco Ins. Co. of Am., 972 S.W.2d 738, 741
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`(Tex. 1998)(noting that it is black letter law that insurance contracts are governed by the same
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`rules of construction as other contracts). Plaintiff’s failure to submit the POL in accordance with
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`the no-action clause prevents his lawsuit from being ripe and, therefore, defeats this Court’s
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`subject matter jurisdiction.
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`C.
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`Plaintiff Will Not Be Prejudiced By Dismissal, Which Is The Proper Remedy
`
`Because the Court lacks subject matter jurisdiction as explained in the preceding
`
`paragraphs, the proper remedy is to dismiss this lawsuit without prejudice. Mullins v. Estelle
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`High Sec. Unit, 111 S.W.3d 268, 274 (Tex. App.—Texarkana 2003, no pet.). Plaintiff will not be
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`prejudiced by this requested remedy, because a dismissal without prejudice does not impose any
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`final adjudication of the rights of the parties. Rather, dismissal without prejudice merely places
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`the parties in the position that they were in before the court's jurisdiction was invoked just as if
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`the suit had never been brought. Crofts v. Court of Appeals, 362 S.W.2d 101, 104 (Tex.1962).
`
`Botkin vs. Allstate
`DEFENDANT’S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION
`0493178131.1
`
`
`PAGE 7
`
`
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`

`

`
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`Plaintiff’s lawsuit should be dismissed without prejudice to allow the parties to attempt
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`resolution pursuant to the contractually agreed upon method in their insurance contract.
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`V.
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`CONCLUSION & REQUEST FOR RELIEF
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`Allstate was entitled to receive a signed and sworn proof of loss to allow it to investigate
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`the circumstances of Plaintiff’s disagreement concerning the loss while they were still fresh in
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`the witnesses’ minds, to prevent fraud, and to have the ability to resolve his dispute through
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`negotiation or appraisal before Plaintiff filed this action. Instead of submitting the signed and
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`sworn proof of loss as he contractually agreed to do, Plaintiff filed this lawsuit before it was ripe,
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`in material violation of the no-action/“Action Against Us” clause. For this reason, Defendant
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`asks this Court: (1) to enforce Allstate’s no-action/“Action Against Us” condition precedent in
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`the insurance contract; (2) to grant this Motion to Dismiss for Lack of Jurisdiction in its entirety;
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`and (3) to dismiss all of Plaintiff’s claims without prejudice to allow the parties to pursue the
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`mechanism prescribed in the policy for resolving such disputes.
`
`Botkin vs. Allstate
`DEFENDANT’S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION
`0493178131.1
`
`
`PAGE 8
`
`
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`

`

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`
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`Respectfully submitted,
`
`SUSAN L. FLORENCE & ASSOCIATES
`
`
`
`LISA CHASTAIN
`TBN: 24031936
`
`1201 Elm St., Suite 5050
`Dallas, TX 75270-2104
`DallasLegal@allstate.com
`(214) 659-4340
`(877) 678-4763 (fax)
`
`ATTORNEY FOR DEFENDANT
`ALLSTATE VEHICLE AND PROPERTY
`INSURANCE COMPANY
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing has been served in
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`compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on the 30th day of
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`October, 2018, to:
`
`Attorney for Plaintiff Braun
`Jeffrey Sprigg
`The Sprigg Law Office
`P.O. Box 2168
`Frisco, TX 75034
`
`
`LISA CHASTAIN
`
`
`
`
`
`
`Botkin vs. Allstate
`DEFENDANT’S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION
`0493178131.1
`
`
`
`
`PAGE 9
`
`
`
`

`

`CAUSE NO. DCl 814521
`IN THE DISTRICT COURT
`
`CARLISLE A. BRAUN,
`
`Plaintiff,
`
`VS.
`ALLSTATE VEHICLE AND
`PROPERTY INSURANCE COMPANY,
`
`_
`
`Defendant.
`
`162ND JUDICIAL DISTRICT
`
`DALLAS COUNTY, TEXAS
`
`‘
`
`AFFIDAVIT OF STEVEN MIELKE
`
`§ §
`
`§
`
`STATE OF TEXAS
`COUNTY OF DALLAS
`
`Before me, the undersigned authority, on this day personally appeared Steven Mielke, who
`being by me duly sworn on his oath, deposed and said thé following:
`“My name is Steven Mielke. I am employed by Allstate Insurance Company in the
`capacity of Staff Litigation Claims Service Adjuster. I am over eighteen years of age, of sound
`mind, and am competent and qualified t0 make this Affidavit. I have personal knowledge of the
`
`1.
`
`2.
`
`facts stated herein, and they are all true and correct.”
`“As part ofmy employment With Allstate, I am familiar With this lawsuit against
`Allstate Vehicle and Property Insurance Company and Carlisle A. Braun. Allstate Insurance
`Company is the designated claim administrator for Allstate Vehicle and Property Insurance
`Company (‘Allstate’), which issued Plaintiff Carlisle A. Braun’s homeowner’s policy n0.
`
`000836924202, effective April 29, 201 8 to April 29, 2019 (‘the policy’). Iregularly receive certified
`copies of insurance policies issued by Allstate as part ofmy job responsibilities. A true and correct
`copy of the policy, as it is kept in the ordinary course ofAllstate’s business, is attached to Defendant
`
`Allstate Vehicle and Property Insurance Company’s Motion to Dismiss for Lack Qf Jurisdiction as
`
`Exhibit ‘2.’”
`
`3.
`
`“As part of my employment With Allstate, I am aware that Plaintiff
`
`

`

`Carlisle A. Braun reported the insurance claim made the basis of this lawsuit to Allstate on August
`17, 018. It was assigned claim no. 0513723221, and it concerned alleged stonn damage to
`Plaintiffs property located at 4136 Meadowlane, Dallas, Texas (‘the property’).”
`
`“On August 28,
`
`2018,
`
`Allstate
`
`inspected
`
`Plaintiff’s
`
`This
`property.
`in§pection
`revealed three Wind damaged shingles and very minor hail damage t0 a storm cap. Damage to the front
`porch soffit was found to be an ongoing issue. Based on the inspection findings, no payment was issued
`to Plaintiffbecause the damage did not exceed the policy’s $3600.00 deductible.”
`4. “No signed and sworn proof 0f loss has yet been received by Allstate.”
`
`FURTHER AFFIANT SAYETH NOT.
`
`SUBSCRIBED AND SWORN TO BEFORE ME this y/(q day of October, 2018.
`My Commission Expires:
`151+ (g-AYQJ
`
`{r m)
`Notary Public, State omes
`f
`Qfl
`(/1 \Q/mjx L/Q4 r
`
`LAM ”/ng
`
`KAREN M. DEViNE
`Official Seal
`Notary Public — Smte of Illinois
`My Commlssion Expires Dec 18‘ 2021
`
`

`

`Page 1 of 2
`
`

`

`Policy number:
`Policy effective date:
`
` 836 924 202
`April 29, 2018
`
`Page 2 of 2
`
`Your Insurance Coverage Checklist
`We(cid:146)re happy to have you as an Allstate customer! This checklist outlines what(cid:146)s in this package and provides answers to some
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`£ What(cid:146)s in this package?
`See the guide below for the documents that are included.
`Next steps: review your Policy Declarations to confirm you
`have the coverages, coverage limits, premiums and
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`£ What about my bill?
`Unless you(cid:146)ve already paid your premium in full, we(cid:146)ll send
`your bill separately. Next steps: please pay the minimum
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`You can also pay your bill online at allstate.com or by
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`1100000S303861064TX000180315034341001969001007015831
`180315S303861
`064070042
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`A guide to your renewal package
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`Policy
`Declarations*
`The Policy
`Declarations
`lists policy
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`Important
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`IMPORTANT NOTICE
`To obtain information or make a complaint:
`
`AVISO IMPORTANTE
`Para obtener información o para presentar una queja:
`
`You may call Allstate’s toll–free telephone number for
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`Usted puede llamar al número de teléfono gratuito de Allstate
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`You may also write to Allstate at:
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`PO Box 660598
`Dallas, TX 75266-0598
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`Usted también puede escribir a Allstate:
`Allstate Insurance Company
`PO Box 660598
`Dallas, TX 75266-0598
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`You may contact the Texas Department of Insurance to
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`Usted puede comunicarse con el Departamento de Seguros de
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`You may write the Texas Department of Insurance:
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`E-mail: ConsumerProtection@tdi.texas.gov
`INSURANCE WEBSITE NOTICE
`To obtain price and policy form comparisons and other
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`website:
`www.helpinsure.com
`
`Usted puede escribir al Departamento de Seguros de Texas a:
`P.O. Box 149104
`Austin, TX 78714–9104
`FAX: (512) 490–1007
`Sitio web: www.tdi.texas.gov
`E-mail: ConsumerProtection@tdi.texas.gov
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`Para obtener formas para la comparación de precios y pólizas
`y para obtener otra información sobre el seguro de propiedad
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`
`PREMIUM OR CLAIM DISPUTES:
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`
`ATTACH THIS NOTICE TO YOUR POLICY:
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`DISPUTAS POR PRIMAS DE SEGUROS O
`RECLAMACIONES:
`Si tiene una disputa relacionada con su prima de seguro o con
`una reclamación, usted debe comunicarse con el agente o la
`compañía primero. Si la disputa no es resuelta, usted puede
`comunicarse con el Departamento de Seguros de Texas.
`ADJUNTE ESTE AVISO A SU PÓLIZA:
`Este aviso es solamente para propósitos informativos y no se
`convierte en parte o en condición del documento adjunto.
`X67186-4
`
`

`

`1100000S303861064TX000180315034341003056002007015831m
`180315S303861
`064070042
`
`emronoomoommnumoosumwmomFmomFoooxbuworwmmommooooo:
`
`memommmrmomr
`
`NwoOno«mo
`
`

`

`Page 1 of 4
`
`

`

`Renewal House & Home Policy Declarations
`Policy number:
` 836 924 202
`Policy effective date:
`April 29, 2018
`
`Page 2 of 4
`
`TX070RBD
`
`1100000S303861064TX000180315034341001969003007015831
`180315S303861
`064070042
`
`Applicable Deductible(s)
`(cid:149) $3,600 Windstorm and Hail
`(cid:149) $3,600 All other perils
`(cid:149) $3,600 Windstorm and Hail
`(cid:149) $3,600 All other perils
`(cid:149) $3,600 Windstorm and Hail
`(cid:149) $3,600 All other perils
`
`
`
`
`Insured property details* (continued)
`Interior wall partition:
`100% drywall
`Heating and cooling:
`Average cost heat & central air
` conditioning, 100%
`Additional details:
`Interior wall height - 8 ft, 100%
`
`Fire protection details:
`Fire department subscription - no
`Roof surface material type:
`Composition
`(cid:149) 100% architectural shingles
`Other
`(cid:149) One small skylight
`
`Roof details:
`Predominant roof type: Composition
`Roof geometry - Gable
`
`1 mile to fire department
`
`Age of roof - 4 years
`
`Mortgagees (listed in order of precedence)
`JPMORGAN CHASE BANK NA ISAOA
`P O Box 47020, Atlanta, GA 30362-0020
`Loan number: 1164313179
`INTERNATIONAL BANK OF COMMERCE ISAOA
`P O Box 866, McAllen, TX 78505-0866
`Loan number: 80091593
`
`Additional Interested Party - None
`*This is a partial list of property details. If the interior of your property includes custom
`construction, finishes, buildup, specialties or systems, please contact your Allstate
`representative for a complete description of additional property details.
`
`Coverage detail for the property insured
`Coverage
`Limits of Liability
`Dwelling Protection
`$360,000
`
`Other Structures Protection
`
`$36,000
`
`Personal Property Protection
`
`$288,000
`
`Additional Living Expense
`Family Liability Protection
`Guest Medical Protection
`
`Up to 24 months not to exceed $36,000
`$300,000 each occurrence
`$1,000 each person
`
`

`

`

`

`TX070RBD
`
`1100000S303861064TX000180315034341001969004007015831
`180315S303861
`064070042
`
`Renewal House & Home Policy Declarations
`Policy number:
` 836 924 202
`Policy effective date:
`April 29, 2018
`
`Page 4 of 4
`
`Allstate Vehicle and Property Insurance Company’s Secretary and President have signed this policy with legal authority at
`Northbrook, Illinois.
`
`Julie Parsons
`President
`
`Susan L. Lees
`Secretary
`
`

`

`

`

`Page 2 of 3
`
`(cid:151)
`
`Fine art works (including paintings, etchings, vases and
`sculptures)
`(cid:151) Manuscripts or books
`(cid:151) Home-office equipment (laptop, computer, audio/visual)
`Sports equipment (such as golf clubs)
`(cid:151)
`Affordable Protection for Your Valuables
`The cost of SPP coverage varies, but the value of your property
`is the best way to determine how much coverage you need.
`The rates are generally a small percentage of the total value of
`the items you(cid:146)re insuring. This means that your valuables are
`being protected for only a fraction of the cost.
`Regularly Review Your SPP Coverage
`Even if you currently have SPP coverage, it(cid:146)s a good idea to
`review it annually. It(cid:146)s possible that the value of your property
`has changed or that you(cid:146)ve purchased new items that have not
`been added to your coverage.
`To learn more about SPP coverage, or if you have any questions
`about your insurance policy in general, contact your Allstate
`representative, or visit us at allstate.com.
`
`X73169
`
`1100000S303861064TX000180315034341001969005007015831
`180315S303861
`064070042
`
`What You Should Know About Flood
`Insurance
`Most homeowners, renters and commercial insurance policies
`do not provide coverage for flood damage. In fact, protection
`against floods is generally available only through a separate
`policy.
`That(cid:146)s why Allstate is a participant in the National Flood
`Insurance Program (NFIP) and offers standard flood insurance
`policies.* A flood insurance policy can help complete the
`insurance protection for your property and help protect your
`financial well-being.
`You May Have More Risk from Flood Than You
`Think
`Approximately 90 percent of all disasters in the U.S. are flood
`related. While you may think that it couldn(cid:146)t happen to you,
`over 25 percent of all flood losses occur in low- to
`moderate-risk areas.
`What(cid:146)s more, flood damage is often accompanied by other
`damage, such as wind and hail (which is typically covered
`under a property policy). So if you purchase your NFIP
`coverage through Allstate, you would have the convenience
`and peace of mind that comes with working with just one claim
`
`Important notices
`Policy number:
`Policy effective date:
`
` 836 924 202
`April 29, 2018
`
`Please Check Your Policy Coverage
`Limits
`When we first issued your Allstate policy, you selected specific
`coverages and coverage limits to protect your property.
`However, your property(cid:146)s value may have changed since that
`time. We(cid:146)d like to remind you that it is your responsibility to
`carefully review your coverages and coverage limits at each
`policy renewal and make sure they provide you with adequate
`coverage.
`Please take a few minutes to review your policy. If you have any
`questions about your insurance coverage, or if you wish to
`change your policy limits, please contact your Allstate
`representative.
`
`X73175
`
`Additional Protection for Your Most
`Valuable Possessions
`Property insurance covers many belongings, but some items
`may require higher coverage limits than those in a standard
`property policy.
`Scheduled Personal Property (SPP) coverage gives you
`additional protection against loss or damage to your valuables.
`It(cid:146)s protection not typically provided with standard property
`coverage. SPP benefits typically include:
`(cid:151) No deductibles to meet
`(cid:151) Coverage for lost or damaged items
`(cid:151) Coverage for valuables kept in a storage location outside
`your home
`Items That May Need the Extra Protection
`SPP coverage provides protection for an array of valuable
`personal property. Here are some of the items you can protect
`by purchasing SPP coverage through Allstate:
`Jewelry (including wedding rings and precious or
`semi-precious stones)
`Furs
`(cid:151)
`(cid:151) Cameras (digital, still, movie, video and related
`equipment)
`Silverware and antiques (including furniture)
`(cid:151)
`(cid:151) Musical instruments
`(cid:151) Collections (stamps, coins, music)
`
`(cid:151)
`
`

`

`

`

`1100000S303861064TX000180315034341003056006007015831m
`180315S303861
`064070042
`
`emronoowoommnumoofimwmomFmomFoooxbuworwmmommooooo:
`
`memommmrmomr
`
`NwoOno«mo
`
`

`

`

`

`1100000S303861064TX000180315034341001969007007015831
`180315S303861
`064070042
`
`Page 2 of 2
`
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`previous choice still applies and you do not need to contact us
`again. If you would like to change your previous choice please
`call the number above at any time.
`We Appreciate Your Business
`Thank you for choosing Allstate. We understand your concerns
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`been helpful to you. We value our relationship with you and
`look forward to keeping you in Good Handsfi.
`If you have questions or would like more information, please
`don(cid:146)t hesitate to contact your Allstate agent or call the Allstate
`Customer Information Center at 1-800-ALLSTATE.
`We reserve the right to change our Privacy practices,
`procedures, and terms.
`Allstate Insurance Company
`Allstate entities on which behalf this notice is provided and
`amongst which information may be shared:
`The Allstate family of companies, LSA Securities, Deerbrook
`General Agency, Inc., Deerbrook Insurance Company, North
`Light Specialty Insurance Company, Northbrook Indemnity
`Company.
`Please Note: Allstate affiliates American Heritage Life
`Insurance Company, Castle Key Insurance Company and
`Castle Key Indemnity Company participate in information
`sharing with the affiliates listed above, but have a separate
`privacy notice for their customers.
`
`(ed. 10/2015)
`
`X73180v6
`
`Privacy Statement
`Policy number:
`Policy effective date:
`
` 836 924 202
`April 29, 2018
`
`We use cookies, analytics and other technologies to help us
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`To learn more, the allstate.com Privacy Statement provides
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`1) How we collect information such as IP address (the
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`How You Can Review and Correct Your P