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October 16, 2023
Zalma’s Insurance Fraud Letter – October 15, 2023

ZIFL Volume 27, Issue 20

Barry Zalma

Oct 16, 2023

Read the full article at https://lnkd.in/gwKMg8yC and see the full video at https://lnkd.in/gJdfQu_B and at https://lnkd.in/gAzA9tb2 and at https://zalma.com/blog plus more than 4600 posts.

This, the twentieth issue of the 27th year of publication Zalma’s Insurance Fraud Letter.

Man Bites Dog: GEICO Bites Fraudsters - Don’t Ty to Defraud GEICO It Bites Back

GEICO sued Defendants ALP Supply, Inc. (“ALP”), PV Supply, Inc. (“PV”), and Pal Vakula, alleging common law fraud and unjust enrichment claims.

Read the full issue of Read the full article at https://lnkd.in/gwKMg8yC

McClenny Moseley & Associates Issues

This is ZIFL’s sixteenth installment of the saga of McClenny, Moseley & Associates.

Read the full issue of ZIFL at Read the full article at https://lnkd.in/gwKMg8yC

Evidence Required to Prove Fraud

Insurer Not Required to Disclose How it Selects Limits and Premium

Read the full issue of ZIFL Read the full article at https://lnkd.in/gwKMg8yC

Good News From The Coalition Against Insurance Fraud

Nerik Ilyayev and Mukhiddin Kadirov have pleaded guilty for multiple cases of insurance fraud. The pair face at least 10 years in prison each, with sentences pending.

Read the full issue of ZIFL atRead the full article at https://lnkd.in/gwKMg8yC

Not Wise to Explain Scheme to Defraud to FBI Informants

Insurance Fraudster Tries Multiple Bases for Appeal & Still Goes to Jail

For his conduct, a jury convicted Higgins on three counts of mail fraud under 18 U.S.C. §§ 1341-42 and two counts of retaliating against a witness, victim, or an informant under 18 U.S.C. § 1513(e). In United States of America v. Brian Higgins, No. 22-3538, United States Court of Appeals, Sixth Circuit (October 6, 2023) affirmed his conviction.

Read the full issue of ZIFL at Read the full article at https://lnkd.in/gwKMg8yC

California Conference of Arson Investigators Training Seminar

As One of the Speakers, I encourage you to SIGN UP TODAY FOR THE OCTOBER 16 – 19, 2023 CCAI Fire Investigation Training Seminar – where you can learn How Insurers and Arson Investigators Have Taken the Profit from Arson-for-Profit from Attorney Barry Zalma, Esq.

Register today by calling 909 865-5004 Or click here to register online.

Read the full issue of ZIFL at Read the full article at https://lnkd.in/gwKMg8yC

Health Insurance Fraud Convictions

Husband And Wife Sent to Prison For $8M Health Care Fraud

Read the about dozens of convictions at this part of the full issue of ZIFL at Read the full article at https://lnkd.in/gwKMg8yC

Other Insurance Fraud Convictions

Newtown Man Ordered to Pay Restitution for Fraudulent Practices
John Paul Reis, 56, of Newtown Township, Pennsylvania entered an open guilty plea.

Read the about dozens of convictions at this part of the full issue of ZIFL at Read the full article at https://lnkd.in/gwKMg8yC

Read the full issue of ZIFL at https://lnkd.in/gkn3fpFX

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Videos
Posts
September 18, 2026
Expert May Only Testify to What Experience Supports

Insurance Expert May Not Testify to Speculative and Contains Unsupported Conclusions.

Posted on September 18, 2026 by Barry Zalma

See the full video at and at https://rumble.com/v7fmifw-expert-may-only-testify-to-what-experience-supports.html

In Michele A. Over, and The Estate Of Paul R. Over v. State Farm Mutual Automobile Insurance Company, and State Farm Fire And Casualty Company, Civil Action No. 23-cv-02243-PAB-STV, United States District Court, D. Colorado (September 14, 2026) Michele and Paul Over sued State Farm Fire and State Farm Auto over hail-damage and stolen-vehicle claims.

The operative dispute concerned State Farm Auto’s motion to exclude or limit opinions from plaintiffs’ insurance-industry expert, Aaron Castillo. Castillo.

Law

The proponent of expert testimony must establish by a preponderance of the evidence that an expert is qualified and that the opinions are helpful, sufficiently grounded, and reliably derived and applied. Experience-based opinions must explain how the...

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September 17, 2026
Convicted on 29 Tax-Refund-Fraud Counts

150 Months in Prison for Tax Fraud
Post 4846

Posted on September 17, 2026 by Barry Zalma

See the full video at https://lnkd.in/g8rh3JBX and https://lnkd.in/gmkdy-9C, In United States Of America v. Thomas Addaquay, Nos. 25-10609, 25-10611, United States Court of Appeals, Eleventh Circuit (September 9, 2026) the Eleventh Circuit affirmed all challenged convictions, the 150-month aggregate sentence, and the challenged $4,123,474.55 restitution award.

FACTS

In United States Of America v. Thomas Addaquay, United States Of America v. Thomas Addaquay, Nos. 25-10609, 25-10611, United States Court of Appeals, Eleventh Circuit (September 9, 2026) the Eleventh Circuit affirmed all challenged convictions, the 150-month aggregate sentence, and the challenged $4,123,474.55 restitution award.
FACTS

Thomas Addaquay controlled United Consolidated Accounting and Business Services (UC), nominally a check-cashing business.

The government proved a three-stage tax-refund scheme that converted the resulting refund checks into usable funds through ...

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September 14, 2026
Court Enforces Fifth Amendment & Refuses to Compel Answers

Major Fraud Perpetrator Asserts Fifth Amendment Privilege to Avoid Prosecution

Post 5489

Posted on September 14, 2026 by Barry Zalma

Fraudster Refuses to Answer Questions About His Alleged Fraud

See the full video at https://lnkd.in/gvicAMDr and at https://lnkd.in/gvicAMDr

In Great American Insurance Co. v. Gemstone Property Management, LLC, et al., No. 23-cv-9100 (LJL), United States District Court, S.D. New York (September 8, 2026) Great American Insurance Company alleged that it was defrauded through a scheme in which Subin Associates, LLP recruited individuals to stage construction-site injuries, arranged unnecessary medical treatment and litigation funding, and pursued fraudulent personal-injury claims.

Luis Manuel Garcia Salcedo, resulted in a $6 million settlement. Non-party Jose Hernandez allegedly worked as an assistant manager at Subin, operated Hernandez Associates, and owned litigation-funding companies that shared office space with Subin and provided services to its clients.

After Great American ...

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21 hours ago
Restitution Sentence Affirmed

Psychiatrist Who Was Convicted of Fraud Asked the First Circuit to Reduce his Punishment
Post 4851

Posted on September 24, 2026 by Barry Zalma

Fraud to Private and Public Health Insurers Doesn’t Pay

In United States v. Gustavo Kinrys, Nos. 24-1592, 24-1716, United States Court of Appeals, First Circuit (September 21, 2026) Gustavo Kinrys, a Massachusetts psychiatrist, submitted fraudulent claims to private and public health insurers from 2015 through 2018, including bills for more than 1,000 sessions when he or the purported patient was outside the country. When insurers requested supporting records, he delayed through a fictitious office manager and created false documentation.

A jury convicted Kinrys on fourteen counts. The district court imposed a 99-month sentence, calculated intended loss at slightly more than $19 million based on billed amounts, ordered $6,537,309.59 in restitution, and ordered $6,527,391.19 in forfeiture.

At sentencing, the district court calculated Kinrys’s base offense level to be ...

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September 23, 2026
Payment and Performance Bonds Are Not Designed to Profit from Failure to Perform

The Collateral-Source Rule is a Narrow Exception to the Prohibition Against Double Recovery

Post 4850

Posted on September 23, 2026 by Barry Zalma

A Surety Stands In The Principal’s Shoes And May Assert The Principal’s Defenses.

In Hudson Insurance Company v. Archer Western Federal, JV, No. 1:24-cv-544 (PTG/IDD), United States District Court, E.D. Virginia, Alexandria Division (September 18, 2026) Archer Western Federal, JV (“AWF”), the prime contractor for a new fire station at Marine Corps Base Quantico, subcontracted roofing work to Eastern General Contractor, Inc. (“EGC”) for $456,330.

Hudson Insurance Company (“Hudson”) issued payment and performance bonds, each with a $456,330 penal sum.

AWF later sought recovery under both bonds.

LAW

Under Virginia law, the collateral-source rule is a narrow exception to the prohibition against double recovery. A surety stands in the principal’s shoes and may assert the principal’s defenses. Liability under the bonds required EGC’s ...

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September 22, 2026
Fraudsters May Not Enjoin Suit Alleging Fraudulent PIP Claims

Defendants May Not Enjoin a Suit Alleging They Defrauded the Plaintiffs

Plaintiffs, automobile insurers, sued medical professionals and healthcare entities, alleging a scheme to submit fraudulent personal injury protection (PIP) bills and supporting documentation for services that were not performed or were medically unnecessary. The complaint asserted common-law fraud, violations of the New Jersey Insurance Fraud Prevention Act (IFPA), aiding and abetting fraud, unjust enrichment, and declaratory relief.

While the action was pending, Plaintiffs moved to stay and enjoin related PIP arbitrations. A magistrate judge recommended denial. in State Farm Guaranty Insurance Company v. Tri-County Chiropractic And Rehabilitation Center P.C., Civil Action No. 22-4852, United States District Court, D. New Jersey (September 15, 2026)

After the New Jersey Supreme Court decided Allstate New Jersey Insurance Company v. Carteret Comprehensive Medical Care, P.C., the federal court reopened the case and considered the parties’ supplemental...

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