EUO Preparation Outline (Policyholder) - Florida

EXAMINATION UNDER OATH (EUO) PREPARATION OUTLINE -- FLORIDA

Policyholder Counsel Practice Guide

Prepared for: [________________________________]
Insured Client: [________________________________]
Claim Number: [________________________________]
Insurance Company: [________________________________]
Policy Number: [________________________________]
Date of Loss: [__/__/____]
Scheduled EUO Date: [__/__/____]
EUO Location: [________________________________]
Insurer's Counsel: [________________________________]
Type of Claim: ☐ Property (Homeowners/Wind/Sinkhole) ☐ PIP/Auto ☐ Other First-Party
Preparing Attorney: [________________________________]

FLORIDA-SPECIFIC LEGAL FRAMEWORK

Overview

Florida has arguably the most developed body of EUO case law of any state, driven primarily by extensive PIP (Personal Injury Protection) litigation and first-party property insurance disputes involving hurricanes, sinkholes, and water damage claims. Florida law treats the EUO as a critical part of the claims investigation process, and compliance is strictly enforced as a condition precedent to coverage.

Statutory Framework

Fla. Stat. Section 627.736(6)(g) -- PIP EUO Requirement (Post-2013):
"An insured seeking benefits under ss. 627.730-627.7405, including an omnibus insured, must comply with the terms of the policy, which include, but are not limited to, submitting to an examination under oath. The scope of questioning during the examination under oath is limited to relevant information or information that could reasonably be expected to lead to relevant information. Compliance with this paragraph is a condition precedent to receiving benefits. An insurer that, as a general business practice as determined by the office, requests an examination under oath of an insured or an omnibus insured without a reasonable basis is subject to s. 626.9541."

This provision was enacted in response to the Florida Supreme Court's ruling in Nunez v. GEICO General Insurance Co. (2013), which held that under the pre-2013 No-Fault Law, an insurer could not require EUO attendance as a precondition to PIP benefits. The Legislature amended the statute effective January 1, 2013, to explicitly make EUO compliance a statutory condition precedent.

Fla. Stat. Section 626.9541 -- Unfair Insurance Trade Practices:
Prohibits unfair claim settlement practices including failing to act reasonably promptly on claims, misrepresenting policy provisions, and failing to adopt reasonable standards for investigation. An insurer that requests EUOs "as a general business practice" without a reasonable basis violates this section.

Fla. Stat. Section 624.155 -- Civil Remedy (Bad Faith):
Provides a statutory cause of action for bad faith failure to settle claims. While primarily applicable to third-party claims, first-party bad faith is actionable in Florida. An insurer's abuse of the EUO process can support a bad faith claim.

Key Florida Case Law

Goldman v. State Farm Fire & Cas. Co., 660 So. 2d 300 (Fla. 4th DCA 1995): The court held that an EUO is a contractual condition precedent and the insurer need not show prejudice to deny the claim based on the insured's failure to submit to an EUO. The insureds argued that a prior recorded statement and the ability to depose in litigation made the EUO unnecessary; the court rejected this argument.

Stringer v. Firemen's Fund Ins. Co., 622 So. 2d 145 (Fla. 3d DCA 1993): Held that an insured's failure to submit to an EUO is a material breach of policy conditions justifying denial of coverage.

Nunez v. GEICO General Ins. Co. (Fla. 2013): The Florida Supreme Court struck down EUOs as a precondition to PIP benefits under the pre-2013 statute, holding that the No-Fault Law did not authorize this requirement. This decision was legislatively overruled by the 2012 PIP Reform Act (effective January 1, 2013).

Sweeney v. Citizens Property Ins. Corp., 43 So. 3d 842 (Fla. 1st DCA 2010): Established that the insurer need only mail the EUO request to the insured; it is not required that the EUO be "mutually coordinated" or that the insured's failure be willful.

Haiman v. Federal Ins. Co., 798 So. 2d 811 (Fla. 4th DCA 2001): The insured's compliance with the EUO was deemed a condition precedent, and failure to attend barred recovery regardless of whether the failure prejudiced the insurer.

Continental Insurance Co. v. Herman, 576 So. 2d 313 (Fla. 3d DCA 1990): Addressed the scope of EUO questioning, recognizing that the examination may extend to all matters relevant to the claim investigation.

Distinguishing PIP EUOs from Property EUOs

Florida practitioners must distinguish between two distinct EUO frameworks:

PART 1: PRE-EUO PREPARATION CHECKLIST (FLORIDA)

1.1 Policy and Statutory Review

☐ Obtain complete policy with all endorsements, declarations, and Florida amendatory endorsements
☐ Identify the EUO clause (typically in "Conditions" section)
☐ Determine the type of claim:

• ☐ PIP/No-Fault (subject to Section 627.736(6)(g))
• ☐ Homeowners/Property (subject to contractual conditions)
• ☐ Wind/Hurricane (check for Citizens or Florida specialty carrier provisions)
• ☐ Sinkhole (subject to Fla. Stat. Section 627.707 procedures)

• ☐ Commercial property
  ☐ For PIP claims: Verify whether the policy was in effect on or after January 1, 2013 (triggering statutory EUO condition precedent)
  ☐ Review the insurer's EUO demand letter for:

• Specific policy provision cited

• Proposed date, time, and location
• Document production requests
• Whether the letter threatens coverage forfeiture for non-compliance
  ☐ Review any reservation of rights letter
  ☐ Check whether a sworn proof of loss has been submitted
  ☐ Calculate the suit limitation period (5 years for breach of contract in Florida, but check policy language for shorter limitations)

1.2 Claims File and Correspondence Review

☐ Request the complete claims file (Florida does not have a pre-suit claims file disclosure statute as broad as some states, but request under the cooperation clause)
☐ Review all prior correspondence
☐ Review any recorded statements given by the insured
☐ Review any SIU (Special Investigations Unit) referral documentation
☐ Review any independent adjuster, engineer, or contractor reports
☐ Check for any prior EUO transcripts
☐ Review any denial or partial denial letters already issued
☐ Document the claims timeline for bad faith analysis

1.3 Document Gathering

☐ Policy declarations and all endorsements (including Florida-specific amendatory endorsements)
☐ Proof of loss (if submitted)
☐ All correspondence with insurer
☐ Photographs and video of loss/damage
☐ Repair estimates, contractor bids, and invoices
☐ Receipts and proof of ownership for personal property
☐ Police reports, fire department reports
☐ For sinkhole claims: geological reports, engineering reports, foundation inspection reports
☐ For hurricane/wind claims: NOAA weather data, building department permits
☐ Financial records:

• Bank statements (12-24 months)
• Federal and Florida tax returns (no state income tax, but federal returns for 2-3 years)
• Mortgage statements
• Credit card statements
  ☐ Cell phone records
  ☐ Social media content (review and preserve)
  ☐ Prior claims documentation (CLUE report)
  ☐ Title documents, deeds, mortgage documents
  ☐ HOA/condo association documents (if applicable)
  ☐ Building permits and inspection records
  ☐ For PIP: medical records, medical bills, employer verification, wage loss documentation

1.4 Timeline Reconstruction

☐ Prepare detailed chronological timeline of the loss event
☐ For hurricane claims: document storm preparation, evacuation, return timeline
☐ For sinkhole claims: document discovery of signs, engineering inspection timeline
☐ For PIP claims: document accident, medical treatment timeline, return to work
☐ Document all mitigation efforts
☐ Track all insurer contacts and response times (critical for bad faith)
☐ Note any delays between loss event and claim reporting

PART 2: CLIENT PREPARATION GUIDE (FLORIDA)

2.1 Florida-Specific EUO Expectations

Explain the following Florida-specific points to the client:

• Condition precedent: Under Florida law, failure to attend or meaningfully participate in the EUO can result in complete denial of your claim. Florida courts strictly enforce this requirement. You must attend.
• Scope: For PIP claims, the scope is limited by statute to "relevant information or information that could reasonably be expected to lead to relevant information." For property claims, the scope is broader and governed by the policy language.
• Right to counsel: You have the right to have an attorney present. However, your attorney's role during the actual examination is limited -- your attorney cannot object to questions or ask you questions during the EUO in the same manner as a deposition.
• Duration: EUOs in Florida property cases can be lengthy, particularly in sinkhole or suspected fraud cases. Expect 2-6 hours.
• Location: The EUO will typically be conducted at the insurer's attorney's office in Florida. You are entitled to a reasonably convenient location.
• What is recorded: A court reporter will be present and will create a verbatim transcript.

2.2 Key Rules for the Client

☐ Attend the EUO. Under Florida law, simply failing to show up can forfeit your claim -- even if your absence was not willful (Sweeney v. Citizens).
☐ Tell the truth. False statements under oath can result in claim denial and criminal prosecution for insurance fraud under Fla. Stat. Section 817.234.
☐ Listen to the question. Make sure you understand it before answering.
☐ Answer only what is asked. Do not volunteer information.
☐ "I don't know" and "I don't recall" are acceptable answers when truthful.
☐ Do not guess. If you are unsure, say so.
☐ Pause before answering to allow your attorney to note any concerns.
☐ Do not discuss conversations with your attorney.
☐ Request breaks as needed.
☐ Be consistent with prior statements (recorded statement, proof of loss, police report).
☐ Bring only documents that were requested or that your attorney instructs you to bring.
☐ Remain calm. Florida EUOs in suspected fraud cases can be aggressive.

2.3 Florida-Specific Preparation Topics

Hurricane/Wind Claims:

• Preparation timeline (shutters, supplies, evacuation order compliance)
• Timing of damage discovery and return to property
• Pre-existing damage vs. storm damage (the insurer will probe this extensively)
• Mitigation efforts (tarping, board-up, water extraction)
• Contractor selection and repair timeline
• Assignment of Benefits (AOB) issues -- if the insured assigned benefits to a contractor, this affects the EUO

Sinkhole Claims:

• Discovery of sinkhole indicators (cracks, settlement, water intrusion)
• Prior foundation or structural issues
• Engineering and geological reports
• Compliance with Fla. Stat. Section 627.707 sinkhole investigation procedures
• Whether the insurer conducted its own sinkhole investigation per statute

PIP/Auto Claims:

• Accident circumstances
• Medical treatment history and providers
• Prior injuries and pre-existing conditions
• Wage loss and employment information
• Whether the insured was the owner, named insured, or omnibus insured
• Relationship to any medical providers (the insurer is looking for staged accident indicators)

Water Damage/Plumbing Claims:

• Discovery of the leak or water intrusion
• Maintenance history of plumbing/HVAC
• Prior water damage claims
• Remediation contractor selection
• Mold concerns and testing

2.4 Documents Commonly Requested in Florida EUOs

☐ Florida driver's license or other government-issued photo ID
☐ Federal tax returns (2-3 years) -- Florida has no state income tax
☐ Bank account statements (all accounts, 12-24 months)
☐ Credit card statements (12-24 months)
☐ Mortgage statements and payment history
☐ Proof of ownership or receipts for claimed personal property
☐ Photographs of property (before and after loss)
☐ Cell phone records
☐ Utility bills (to establish occupancy/use)
☐ Lease or rental agreements
☐ Building permits and inspection records
☐ Contractor agreements and invoices
☐ Prior claims documentation
☐ For PIP: medical records, bills, employer documentation, wage verification
☐ For sinkhole: engineering reports, geological reports, foundation inspection reports

PART 3: FLORIDA EUO OBJECTION FRAMEWORK

3.1 Counsel's Role at Florida EUOs

In Florida, counsel's role during the EUO is more limited than in a deposition:

• Counsel may attend and observe the proceedings
• Counsel may advise the client during breaks
• Counsel may assert privilege objections
• Counsel generally may NOT make speaking objections, instruct the client not to answer (except for privilege), or cross-examine the insurer's attorney
• Florida courts have strictly enforced the insurer's right to conduct the EUO without counsel interference

However, counsel should still:

• Note objections on the record for preservation purposes
• Request breaks to confer with the client if the questioning becomes abusive or goes far beyond scope
• Assert privilege when necessary
• Document any conduct that may constitute unfair claims practices

3.2 Scope Objections

For PIP claims (Section 627.736(6)(g)):
The statutory scope limitation is "relevant information or information that could reasonably be expected to lead to relevant information." This mirrors discovery standards and provides a basis for objection.

For property claims:
The scope is governed by the policy language, which typically allows examination about matters "relevant to the claim." Object when:

☐ Questions go beyond the specific claim and loss at issue
☐ Questions probe coverage defenses rather than claim facts
☐ Questions are designed to elicit privileged information
☐ Questions about unrelated insurance policies or claims
☐ Questions about immigration status (unless directly relevant)
☐ Overly broad financial inquiries disproportionate to the claim

Sample Florida scope objection:

"For the record, we note an objection to this line of questioning as exceeding the scope of examination permitted under the policy conditions [and/or Section 627.736(6)(g)]. The question seeks information that is not relevant to the [type] claim at issue. We preserve this objection and reserve all rights."

3.3 Privilege Objections

☐ Attorney-client privilege (Fla. Stat. Section 90.502): Communications between client and attorney are privileged. Instruct client not to answer.
☐ Work product doctrine: Attorney work product is protected under Florida law.
☐ Fifth Amendment / Art. I, Section 9, Fla. Const.: The insured may invoke the right against self-incrimination. However, Florida courts follow the majority rule that Fifth Amendment invocation does not excuse the duty to cooperate and may result in forfeiture.
☐ Spousal privilege (Fla. Stat. Section 90.504): Husband-wife privilege applies.
☐ Accountant-client privilege (Fla. Stat. Section 90.5055): May protect communications with accountants.

3.4 Repeated EUO Demands

Florida insurers sometimes demand multiple EUOs. Object when:
☐ The insurer has already conducted a complete EUO and seeks a second without new information
☐ The insurer is using repeated EUO demands to delay the claim
☐ The scope of the second EUO is identical to the first

Note: The policy language "as often as may be reasonably required" gives the insurer some latitude, but reasonableness is a limiting principle.

3.5 Document Production Objections

☐ Overbreadth: Requests extending beyond the scope of the claim
☐ Privilege: Documents protected by attorney-client or work product privileges
☐ Third-party records: Cannot compel production of records the insured does not possess
☐ Destroyed in loss: If documents were destroyed in the loss event, document this for the record
☐ Undue burden: Requests that are disproportionate to the claim amount

PART 4: RESPONSE LETTER TO EUO DEMAND (FLORIDA)

4.1 Template Response -- Acknowledging and Scheduling

[Date: __/__/____]

[Insurer's Counsel Name]
[Firm Name]
[Address]
[City, State ZIP]

Re: Examination Under Oath -- [Insured Name]
Claim No.: [________________________________]
Policy No.: [________________________________]
Date of Loss: [__/__/____]

Dear [________________________________]:

This firm represents [________________________________] ("the Insured") in connection with the above-referenced claim under policy number [________________________________] issued by [________________________________].

We acknowledge the Company's demand dated [__/__/____] for an Examination Under Oath of the Insured pursuant to the policy's cooperation conditions [and Fla. Stat. Section 627.736(6)(g), if PIP claim].

Scheduling: The Insured will submit to the Examination Under Oath and proposes the following:

• Date: [__/__/____]
• Time: [____]
• Location: [________________________________]

If the proposed date is not available, please provide three alternative dates within the next [____] days.

Right to Counsel: The Insured will be represented by counsel at the EUO.

Scope: [For PIP claims: The Insured understands that the scope of the EUO is limited to "relevant information or information that could reasonably be expected to lead to relevant information" under Section 627.736(6)(g).] [For property claims: The Insured understands the examination will address matters relevant to the [type of loss] claim.] We reserve the right to note objections as appropriate.

Recording: We request that a certified court reporter attend and transcribe the proceedings. The Insured requests a copy of the transcript upon completion.

Document Production: We have reviewed the accompanying document requests and will produce responsive, non-privileged documents in the Insured's possession to the extent they are relevant to the claim. We note the following objections:

1. [________________________________]
2. [________________________________]

Reservation of Rights: The Insured's appearance does not waive any rights under the policy or Florida law, including but not limited to the right to pursue remedies under Fla. Stat. Sections 624.155 and 626.9541 if the Company fails to act in good faith.

Sincerely,

[________________________________]
Attorney for [________________________________]

PART 5: COMMON EUO QUESTION CATEGORIES (FLORIDA)

5.1 Background and Personal Information

1. State your full legal name and any aliases or prior names.
2. What is your date of birth and Social Security number?
3. What is your current address? How long have you resided there?
4. List all Florida addresses where you have lived in the past 10 years.
5. What is your marital status? Identify spouse and household members.
6. What is your occupation and employer?
7. Describe your employment history for the past 10 years.
8. Have you ever been convicted of a crime in Florida or any other state?
9. Have you ever filed for bankruptcy?

5.2 Insurance History

10. How did you obtain the current policy? Agent or broker name?
11. How long have you been insured by this company?
12. Have you ever had a policy cancelled, non-renewed, or not accepted in Florida?
13. What other insurance policies do you currently maintain?
14. List all insurance claims on any policy in the past 10 years.
15. Have you ever had an insurance claim denied? Describe.
16. Have you ever submitted to an examination under oath before?
17. Have you ever been investigated by an insurer's SIU?

5.3 Property Description (Property Claims)

18. Describe the insured property at [address].
19. When did you acquire the property? Purchase price and terms?
20. Current mortgage balance and lender?
21. Are mortgage payments current?
22. Current estimated market value?
23. What improvements have been made since purchase?
24. Describe the condition of the property before the loss.
25. Security system? Active at time of loss?
26. Who has keys or access to the property?
27. Occupancy at time of loss -- who was present?
28. Any portion rented, leased, or used for business?
29. Is the property in a flood zone? Hurricane zone? Sinkhole area?
30. Prior losses or damage to this property?

5.4 Loss Event (Adapted for Florida Common Claims)

Hurricane/Wind:

31. When did you first learn that the hurricane/storm was approaching?
32. What preparations did you make (shutters, evacuation, etc.)?
33. Did you evacuate? When did you return?
34. Describe the condition of the property when you returned.
35. What damage did you observe?
36. When did you first contact the insurance company?
37. Did you take emergency measures to prevent further damage?
38. Did any water enter the property during the storm? Through what opening?

Sinkhole:

39. When did you first notice signs of potential sinkhole activity?
40. What signs did you observe (cracks, settling, water intrusion)?
41. Did you report the potential sinkhole activity to anyone before filing a claim?
42. Were any engineering or geological investigations conducted before the claim?
43. Have you made any foundation repairs?

Water Damage:

44. When and how did you discover the water damage?
45. What was the source of the water?
46. How long do you believe water had been intruding before discovery?
47. When was the plumbing/HVAC last inspected or serviced?
48. Have you had prior water damage at this property?

PIP/Auto:

49. Describe the accident in detail.
50. Where were you going at the time of the accident?
51. Were you the driver, passenger, or pedestrian?
52. Describe your injuries.
53. What medical treatment have you received? From whom?
54. Are you still treating?
55. Have you returned to work?
56. Describe any pre-existing injuries or conditions.

5.5 Damages and Repairs

57. What is the total amount of your claim?
58. How was that amount calculated?
59. Who prepared the estimate?
60. Have any repairs been completed?
61. Did you obtain multiple estimates?
62. How did you select the repair contractor?
63. Did you execute an Assignment of Benefits (AOB) to any contractor or vendor?
64. Describe any personal property damaged or destroyed.
65. Do you have proof of ownership for each claimed item?
66. Are you claiming additional living expenses? For what period?

5.6 Financial Information

67. All sources of income (you and spouse)?
68. Total household income last year?
69. All bank accounts and approximate balances?
70. Outstanding debts and obligations?
71. Current on all payments?
72. Own other Florida real property?
73. Property listed for sale at time of loss?
74. Financial difficulties at time of loss?
75. Back property taxes owed?

5.7 Post-Loss Activities

76. Actions taken since the loss regarding this claim?
77. Public adjuster retained? Who and when?
78. Attorney consulted? When?
79. Other recorded or sworn statements about this loss?
80. Social media posts about the loss?
81. All documents provided to the insurance company?
82. Anything to add or correct?

PART 6: POST-EUO ACTION ITEMS (FLORIDA)

6.1 Immediate Post-EUO Steps

☐ Debrief with client immediately
☐ Prepare memo to file: topics covered, duration, objections, assessment
☐ Request transcript copy
☐ Note any undertakings for supplemental document production

6.2 Transcript Review

☐ Review transcript for accuracy
☐ Compare to prior statements for consistency
☐ Identify any potentially harmful answers
☐ Prepare correction or supplemental statement if necessary

6.3 Post-EUO Coverage Demand

☐ If no coverage determination within 60-90 days after EUO, send coverage demand:

• Note full compliance with all cooperation obligations including EUO
• Demand coverage determination within 30 days
• Cite Fla. Stat. Section 626.9541 (unfair claims practices)
• Note that continued delay may constitute bad faith under Section 624.155
• Reserve all rights
  ☐ Consider filing a Civil Remedy Notice under Section 624.155 if the insurer fails to act

6.4 Bad Faith Documentation

☐ Maintain detailed timeline of all claims-handling activities
☐ Document any delays, unreasonable demands, or failures to communicate
☐ Preserve all correspondence
☐ Track elapsed time from loss to EUO to coverage determination
☐ Note any conduct that may support a bad faith claim:

• Unreasonable delay in scheduling the EUO
• Using EUO to fish for coverage defenses rather than investigate the claim
• Demanding repeated EUOs without justification
• Failing to make a coverage determination within a reasonable time after the EUO
• Requesting EUOs "as a general business practice" without a reasonable basis (Section 626.9541)

6.5 Assignment of Benefits Considerations

If the insured executed an AOB to a contractor or medical provider:
☐ Determine whether the AOB transfers the EUO obligation
☐ Review whether the contractor/provider has already been examined
☐ Assess whether the AOB complicates the insured's EUO obligations

PART 7: FLORIDA-SPECIFIC PRACTICE NOTES

7.1 Florida's Strict Enforcement

Florida courts strictly enforce the EUO as a condition precedent. Key practice points:

• No prejudice required: Per Goldman v. State Farm, the insurer need not show prejudice from the insured's failure to attend. Non-attendance alone may forfeit the claim.
• Mailing suffices: Per Sweeney v. Citizens, the insurer need only mail the EUO request. There is no requirement that the EUO be "mutually coordinated."
• Willfulness irrelevant: Even an inadvertent failure to attend may result in forfeiture.
• Bottom line: In Florida, the insured must attend the EUO. There is very little room for gamesmanship.

7.2 PIP EUO Practice

The 2012 PIP Reform Act (effective January 1, 2013) fundamentally changed Florida PIP EUO practice:

• EUO compliance is now a statutory condition precedent (Section 627.736(6)(g))
• The scope is limited to relevant information or information reasonably expected to lead to relevant information
• Insurers that request EUOs as a general business practice without reasonable basis face Section 626.9541 sanctions
• The insured must be the actual insured or omnibus insured -- the statute does not extend to third-party claimants

7.3 Sinkhole Claim EUOs

Sinkhole claims in Florida involve unique EUO considerations:

• The insurer must conduct a sinkhole investigation per Section 627.707 before denying the claim
• EUO questions may focus on the insured's knowledge of geological conditions before purchase
• Prior engineering reports or home inspections are critical documents
• The insurer may probe whether the insured concealed known sinkhole conditions at the time of application

7.4 Hurricane and Catastrophe EUOs

Following major hurricanes, Florida insurers conduct high volumes of EUOs:

• Timing is critical -- insureds may be displaced and difficult to locate
• The insurer's duty to investigate promptly does not disappear during catastrophes
• Courts have been somewhat more lenient with scheduling in catastrophe situations
• Document the insured's displacement, temporary housing, and difficulty obtaining documents lost in the storm

7.5 Fifth Amendment in Florida

Florida follows the majority rule: invoking the Fifth Amendment does not excuse the duty to cooperate. Per Goldman and Stringer, the insured must answer even if the answers may be incriminating. If criminal charges are pending:

• Request a continuance of the EUO until criminal matters are resolved
• Coordinate with criminal defense counsel
• Consider whether the insured can answer some questions while invoking the privilege on narrow issues
• Document the criminal exposure for the record

7.6 2022 and 2023 Florida Insurance Reforms

Recent Florida legislative reforms (SB 2-A (2022) and HB 837 (2023)) have significantly impacted insurance litigation in Florida:

• Elimination of one-way attorney fee provisions in most property insurance cases
• Elimination of Assignment of Benefits for residential property claims (SB 2-A)
• Changes to bad faith litigation standards
• These reforms affect the strategic calculus of EUO disputes and should be reviewed carefully

SOURCES AND REFERENCES

• Fla. Stat. Section 627.736: https://www.flsenate.gov/laws/statutes/2024/627.736
• Fla. Stat. Section 626.9541: https://www.flsenate.gov/laws/statutes/2024/626.9541
• Fla. Stat. Section 624.155: https://www.flsenate.gov/laws/statutes/2024/624.155
• Goldman v. State Farm Fire & Cas. Co., 660 So. 2d 300 (Fla. 4th DCA 1995)
• Stringer v. Firemen's Fund Ins. Co., 622 So. 2d 145 (Fla. 3d DCA 1993)
• Sweeney v. Citizens Property Ins. Corp., 43 So. 3d 842 (Fla. 1st DCA 2010)
• Haiman v. Federal Ins. Co., 798 So. 2d 811 (Fla. 4th DCA 2001)
• Continental Insurance Co. v. Herman, 576 So. 2d 313 (Fla. 3d DCA 1990)
• Krapf Legal, "Examination Under Oath (EUO): What to Expect and How to Prepare": https://krapflegal.com/recources/bad-faith/examination-under-oath-florida/
• Policy Advocate, "Examinations Under Oath: What You Need to Know": https://policyadvocate.com/blog/examinations-under-oath-what-you-need-to-know/
• Chartwell Law, "Florida First-Party Property Case Law Signals That Insurance Carriers Need Only Request an EUO Via Mail": https://www.chartwelllaw.com/resources/florida-first-party-property-case-law-signals-that-insurance-carriers-need-only-request-an-examination-under-oath-via-mail
• GED Lawyers, "Examination Under Oath (EUO) in Florida: What to Know": https://www.gedlawyers.com/faqs/examination-under-oath-euo-in-florida-what-to-know/

This template is provided for informational purposes only and does not constitute legal advice. It must be reviewed and customized by a qualified attorney licensed in Florida before use. Florida insurance law has undergone significant legislative changes in 2022-2023. Do not use this template without professional legal review.

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