Dr and Mrs Stapenhurst
30 Chestefield Road
London
N3 1PR
Dear Sirs,
I am writing this letter in respect of Mrs Stephanie Worcester’s insurance claim against [insert name of insurer/ Policy number]. Please find enclosed written consent of Mrs Worcester for me to communicate with you in relation to this claim.
Background
Mrs Worcester notified [insurance company] of her claim under policy [policy number] on [date] in relation to a serious leak in her flat at [Ely Place] (the index incident). You accepted responsibility to restore the residence to its pre-index incident state of repair on [insert date]. You provided Mrs Worcester with a firm estimate that the drying of the flat and restoration work would take [two months].
Despite your acceptance of liability on [date], it took a further [insert number of weeks] before the drying stage of the repairs was commenced.
Offer of alternative accommodation
[insert name of insurers] accepted that Mrs Worcester would not be able to remain resident at [flat address] during the drying or restoration works. She was offered accommodation in a hotel or informed that she could stay with a friend or relative and receive a small ‘disturbance allowance’. Mrs Worcester opted to stay with her daughter and son-in-law in London as she was extremely concerned about not being able to make food for herself in a hotel.
At no stage was Mrs Worcester offered alternative accommodation comparable to the insured property which would enable her to continue with her normal work and leisure pursuits as easily and comfortably as possible, as per the ombudsman guidance. Mrs Worcester has suffered substantial distress and inconvenience as a result.
The Drying Stage
The contractors chosen and appointed by [insert insurer name] to carry out the drying work on Mrs Worcester’s residence were unsuitable and caused unnecessary stress and delay.
1)	The drying was commenced without the removal of the wet carpet causing significant delay until the carpet was subsequently removed. It was expected that the insurer would appoint reasonably competent contractors who would be aware of the difficulties in drying out a flat with the wet carpet in situ.
2)	After several weeks of attempting to dry the flat the contractors contacted Mrs Worcester to inform her that the membrane to the bathroom floor would need to be removed (scarification) or the flat would not dry. The contractors assured Mrs Worcester that the doors to the flat would be closed during this process. Mrs Worcester later found out that the front door had been left open and an elderly resident in the development who had not been informed of the works had walked into a cloud of dust.
3)	The bath was not covered during the [scarification] process – the extent of the damage to the surface is not yet clear.
4)	Mrs Worcester has experienced complaints from other residents regarding the noise form the drying machines and the heat generated. Whilst it is understood that some of this inconvenience is unavoidable, a reasonably competent contractor would have taken steps to inform the other residents of the disturbances.

The Restoration Stage
[insurance company name] appointed [initial contractors name] to complete the restoration phase of the work. Mrs Worcester expended a great deal of time and energy discussing tile and flooring fittings with the contractors.
[contractor names] agreed that the work would be completed within a time period of  [three] weeks. Due to the delays caused by the incompetence of the contractors appointed by the insurer to dry the flat, the restoration phase has been delayed. [insert contractors name] agreed to start the work by [date that was three weeks after the drying stage]. Therefore the work should have been completed by [insert date].
Mrs Worcester was informed by the contractors that because [original contractors] could not start until [insert date] they had decided to use different contractors. This caused Mrs Worcester a huge amount of distress as she was aware that it was unlikely that new contractors would be able to start any earlier than [insert date]. It was only after several phone calls that [insert name] of [insert name of insurers] informed Mrs Worcester that [insert name of original contractors] had been fired by the insurance company for reasons ‘well above his paygrade’ and nothing to do with her flat.
As at 23 October 2018 the alternative contractors appointed by the insurers have still not commenced the works.
It is very clear that the unreasonable delay to the restoration of the insured residence is the responsibility of the insurers.
Next steps
Please respond to this letter within seven days with details of the additional compensation for distress and inconvenience you are prepared to offer to Mrs Worcester.  At this stage Mrs Worcester is prepared to accept £1,000 for the distress/inconvenience caused to date. This is substantially less than what [insurers] had a duty to pay in appropriate alternative accommodation which was never offered. Please also confirm that Mrs Worcester can rent, using a short term letting site such AirBnB, a flat in Cambridge until the works are fully completed.
Please also set out the steps that [insurers] are taking to ensure the swift resolution of the delay, including a firm end date to the works.
If you do not accept the above we will have no choice but to raise this issue with the Ombudsman without further correspondence.
Yours sincerely,
Shosh Stapenhurst