Security First Insurance Liability Claim Interview: Dakota Allendorf

Insurance Claim and Policy Documentation

• Interviewer: Joshua Clayton, representative of Security First Insurance Company.
• Interviewee: Dakota Allendorf, a resident at the insured property.
• Policy Number: $P015193411$.
• Claim Type: Liability claim.
• Incident Date: On or about $01/07/2025$.
• Interview Date/Time: September 10, 2025 ($09/10/2025$) at $01:15\,\text{PM}$ Eastern Standard Time.
• Legal Residence of Dakota Allendorf: 1845 Live Oak Lane, Atlantic Beach, Florida, $32233$.
• Incident Location: Orlando, Florida, in the vicinity of the University of Central Florida (UCF).

Detailed Chronology of the Event (January 6–7, 2025)

• Pre-Incident Activity (Late Night, January 6):

  • Dakota Allendorf was at a UCF bar called Knights Library earlier in the evening.
  • Dakota served as the designated driver for $4$ to $5$ people, remaining sober throughout the night.
  • Around midnight, the group arrived at the GBT fraternity house.

• The Frat House Incident (Midnight – 01:00 AM):

  • Dakota was in the backyard when two fraternity brothers' puppies escaped through a gate into the street.
  • While retrieving the dogs, Dakota encountered the claimant, Keegan, in the street.
  • Keegan was involved in a physical altercation with his roommate, Hunter Lomanski.
  • Hunter was attempting to get Keegan into an Uber, but Keegan was highly intoxicated, sobbing, and emotionally distressed over a lost sentimental hat given to him by his grandfather.
  • Keegan attempted to tackle Hunter, failed, and began walking away.

• First Physical Interaction and Attempted Assistance:

  • Dakota approached Keegan to calm him down; Keegan was out of breath and stuttering.
  • Keegan insisted on walking to a Wawa gas station located approximately $0.5\,\text{miles}$ away.
  • Dakota offered to drive him or call an Uber, but Keegan refused.
  • Keegan attempted to tackle Dakota using the same "sloppy" maneuver he used on Hunter.
  • Keegan successfully picked up Dakota and slammed him onto the ground. Dakota did not fight back due to Keegan’s state of inebriation.

• Transition to UCF Campus (01:00 AM – 03:00 AM):

  • Hunter Lomanski and Ryan Coville arrived to take Keegan home, but he refused to enter their vehicle.
  • Dakota told the roommates he would stay with Keegan to ensure his safety since Keegan was in no state to be alone.
  • They walked through a residential complex called "The Ave" (where Dakota formerly lived) toward University Boulevard.
  • Keegan intended to walk to his brother’s dormitory at UCF.
  • Keegan was stumbling and fell over several times during the trek, which covered about $1.5\,\text{miles}$ from the fraternity house.

• The Woods and Second Altercation (03:00 AM – 03:30 AM):

  • Keegan attempted to take a "back way" through woods near a pond behind a building referred to as Nepton (or Nepson).
  • Dakota tried to stop him from going the wrong way and approaching the water.
  • Keegan put Dakota in a headlock. Dakota separated from him, and Keegan ran away into the darkness.
  • At approximately $03:30\,\text{AM}$, Dakota called Keegan's roommates to inform them Keegan was "out of his mind" and missing.

Post-Incident Communication and Observations

• Morning After (January 7):

  • At approximately $06:00\,\text{AM}$ or $07:00\,\text{AM}$, Keegan sent Dakota a series of aggressive text messages calling him a "piece of shit."
  • Keegan texted: "You slammed me on my neck."
  • Dakota replied: "I know," which he clarifies was a general response to Keegan’s erratic behavior and insults rather than an admission of guilt for a specific injury. This was the first time Dakota heard mention of a neck injury.

• Subsequent Encounters:

  • Approximately $1$ to $2$ months after the incident (around April), Dakota saw Keegan at a bar.
  • Keegan was not wearing a neck brace, appeared to be moving normally, and was consuming alcohol, despite claims that his neck was broken.

Legal and Insurance Assessment

• UCF Disciplinary Action:
  • The UCF judicial system (student council) investigated the incident.
  • Dakota Allendorf was found "not guilty" of any wrongdoing or disciplinary violations.
• Insurance Coverage Status:
  • Dakota is treated as an "insured" under his father's policy (Security First Insurance Company) because he resides at the insured property.
  • The insurance company has sent a disclosure to the claimant’s attorneys stating the policy limits.
• Liability Evaluation:
  • Joshua Clayton notes that Dakota appears to have acted in self-defense and as a concerned friend trying to provide aid.
  • Keegan’s extreme intoxication and prior aggression toward Hunter Lomanski indicate a propensity for instability.
  • The claimant's attorneys have refused to provide a statement from Keegan.
  • The statute of limitations for filing a lawsuit is $2\,\text{years}$, leaving approximately one year and three months of remaining time.
• Potential Defense Strategy:
  • Focus on comparative negligence of the claimant due to intoxication.
  • Highlight Dakota’s status as a sober designated driver.
  • Leverage witnesses (Hunter Lomanski and Ryan Coville) and the UCF police report.
  • Investigate the severity of "soft tissue" versus "traumatic" injuries relative to Keegan’s social activities post-incident.

Questions & Discussion

• Dakota's Injuries: Dakota reported minor injuries, including redness and scratches on his arm where the skin was broken, but nothing requiring medical treatment.
• UCF Records: Dakota asked if the insurance company had video from the UCF judicial hearings. Joshua Clayton confirmed he only has the police report and the final letter from UCF stating no disciplinary action was taken.
• Attorney Tactics: Dakota asked what "creative" meant regarding plaintiff attorneys. Joshua explained they might "bend the truth" to establish a duty was violated or claim extensive emotional and physical damages.
• Personal Connection: Joshua Clayton and Dakota Allendorf discussed their shared history with UCF. Joshua graduated in $2008$ with a degree in Finance. They identified shared locations near campus, including Ashington Park and the intersection of University and Alafaya.
• Bar History: Both mentioned local UCF bars, specifically Knights Library and Bounce. Joshua noted that Bar Louie now occupies a space that was previously a parking lot near the old Knights Library location.
• University Housing: Dakota commented on the high cost of local affiliated housing, noting rent is often around $1,200\,\text{dollars}$ per month for a room and bathroom in poor-quality buildings.