Hartwell & Brennan.

Dear Ms. Okafor:

This firm represents Mr. and Mrs. Theodore R. Whitfield in connection with the above-captioned homeowner's claim. We write to formally dispute Coastal Mutual's denial of coverage dated October 22, 2024, and to demand a full and good-faith review of the claim within thirty (30) days of this correspondence.

On September 9, 2024, the Whitfield residence sustained substantial damage during Tropical Storm Helene, including partial roof uplift over the primary bedroom wing, saturation of structural decking and insulation, water intrusion through two failed second-story window assemblies, and consequential damage to interior finishes, flooring, and built-in cabinetry. The insureds timely reported the loss on September 11, 2024 and fully cooperated with every request for inspection, documentation, and sworn statement.

Your denial rests almost entirely on the field report of staff adjuster Mr. Lawrence Pritchard (Adjuster Report dated October 3, 2024), who concluded that the observed damage was attributable to "long-term wear, deferred maintenance, and pre-existing wind exposure" rather than to the named storm event. That conclusion is not supported by the evidence and is contradicted by the record in three material respects.

Points of Dispute

1. Contradiction of contemporaneous inspection. The roof was inspected and certified sound by Palmetto Roofing & Exteriors, LLC on March 18, 2024 — less than six months before the loss. That report, previously furnished to your office on September 24, 2024, documents the absence of the defects now cited by Mr. Pritchard as "pre-existing."

2. Omission of meteorological evidence. NOAA Station KCHS recorded sustained winds of 64 mph with gusts to 81 mph within one mile of the loss address during a six-hour window on September 9. The adjuster report makes no reference to these readings, nor to the covered peril of "windstorm" expressly enumerated under Section I, Coverage A, Paragraph 2(c) of the policy.

3. Independent engineering contradicts the denial. A licensed structural engineer retained by the insureds, Ms. Renata Salvador, P.E. (SC License No. 34122), inspected the property on October 9, 2024 and concluded to a reasonable degree of engineering certainty that the failure mode is consistent with wind-driven uplift and rain intrusion concurrent with the storm event. Her signed report is enclosed herewith as Exhibit A.

Taken together, these facts establish a covered loss under the plain terms of the policy. The denial appears to have been issued without meaningful consideration of the insureds' submitted evidence and may constitute a breach of Coastal Mutual's duty of good faith and fair dealing under S.C. Code Ann. § 38-59-20 and the South Carolina Unfair Trade Practices Act.

We remain open to an informal resolution and are prepared to make Ms. Salvador, Palmetto Roofing, and the insureds available for a joint re-inspection at your convenience. Kindly direct all further correspondence regarding this matter to the undersigned.