Contract analysis

1. Verimark Grand Key Resort — Marathon, Florida The Verimark Grand Key Resort is located at Mile Marker 48, Marathon, Florida 33050, in Monroe County. The resort is a luxury destination property comprising 312 guest rooms, a full-service marina, multiple restaurants and bars, a spa and fitness center, and extensive meeting and event facilities. Prior to Hurricane Callista, the Grand Key Resort operated at a pre-loss

2. Verimark Harborview Hotel & Conference Center — Fort Myers Beach, Florida The Verimark Harborview Hotel & Conference Center is located at 1400 Estero Boulevard, Fort Myers Beach, Florida 33931, in Lee County. The property comprises 224 guest rooms and a 40,000-square-foot conference and events facility, making it a significant venue for corporate meetings, conventions, and leisure travel on Florida's southwest coa

3. Verimark Sunset Shores — St. Pete Beach, Florida The Verimark Sunset Shores is located at 7200 Gulf Boulevard, St. Pete Beach, Florida 33706, in Pinellas County. The property is a 186-room boutique resort offering upscale accommodations on the Gulf of Mexico. Prior to Hurricane Callista, Sunset Shores operated at a pre-loss ADR of $342 and an average occupancy rate of 79%. While St. Pete Beach is located farther n

I. THIS COURT HAS JURISDICTION OVER ALL DEFENDANTS Defendants' motion challenges this Court's personal jurisdiction over one or more of the Defendants. As set forth below, this Court has both specific personal jurisdiction and, in several instances, general jurisdiction over each Defendant. Each Defendant purposefully availed itself of the privilege of conducting insurance business in Florida by issuing a policy cove

II. THE COMPLAINT STATES VIABLE CLAIMS FOR RELIEF Defendants contend that VHG's Complaint fails to state claims upon which relief may be granted. This contention is without merit. Under Florida's notice-pleading standard, a complaint need only provide the defendant with fair notice of the claims asserted and the grounds upon which they rest. See Anderson v. Harborline Enterprises Hotels Corp., 202 So. 3d 846, 850 (Fl

III. DEFENDANTS' REQUEST FOR A STAY IS WITHOUT MERIT In the alternative to dismissal, Defendants request that the Court stay these proceedings. Defendants identify no cognizable basis for a stay, and their request should be denied. A court may exercise its inherent authority to stay proceedings in certain limited circumstances, such as when a related proceeding is pending in another forum, when the parties have agree