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January 07, 2025
Fraud Resulted in Criminal Conviction of Daniel Carpenter

Daniel Carpenter Guilty of $30 Million Fraud Out of Prison and Fights Collection of Judgment

Keeping the Proceeds of Fraud Refused by Tenth Circuit

Post 4966

Universitas Education, LLC sued to recover funds it lost in an elaborate insurance fraud scheme perpetrated by convicted felon Daniel Carpenter. The underlying litigation occurred in the Southern District of New York, leading to a civil judgment against multiple defendants. Among the corporate entities allegedly used to perpetrate the fraud was Avon Capital, LLC and several of its affiliates located in Oklahoma, Nevada, and Wyoming. Universitas sought to garnish a $6.7 million insurance portfolio held by SDM Holdings, which Avon owns, located in Oklahoma.

In Universitas Education, LLC v. Avon Capital, LLC, Nos. 23-6125, 23-6167, 23-6126, 23-6168, 24-6066, 24-6033, United States Court of Appeals, Tenth Circuit (December 31, 2024), after registering the judgment in Oklahoma, Universitas sought summary judgment on its entitlement to the funds.

The district court entered summary judgment for Universitas and authorized a receivership over Avon and SDM. Avon and SDM appealed, claiming a myriad of procedural defects and disputes on the merits. After an adverse appellate decision the court again entered judgment in favor of Universitas after Universitas re-registered the New York judgment. The district court re-entered summary judgment in its favor, and reauthorized the receivership over Avon and SDM. Avon and SDM challenged that ruling, claiming the district court lost jurisdiction over the claims and that Universitas did not properly revive them as required by Oklahoma law.

BACKGROUND

Fraud Resulted in Criminal Conviction of Daniel Carpenter

Carpenter had devised and carried out an insurance fraud scheme that, among other wrongdoing, defrauded Universitas of $30 million in life insurance proceeds. The fraud was uncovered, and Mr. Carpenter was convicted for his crimes.

In its efforts to recover losses, Universitas sued in the Southern District of New York, naming as defendants a group of Mr. Carpenter’s corporate entities. One of those entities was Avon Capital, LLC, a Connecticut company.

Universitas eventually secured a judgment in that suit for $30.6 million in 2014, of which $6.7 million was against Avon Capital, LLC. Each of these Avon entities was ninety-nine percent owned by Carpenter Financial and one percent owned by Caroline Financial-both of which were controlled by Daniel Carpenter.

The district court referred cross-motions for summary judgment, along with follow-on evidentiary motions, to the magistrate judge, who issued a 73-page Report and Recommendation finding that the entities were “one and the same for purposes of their liability to Universitas.” The magistrate judge also determined that, because Avon-WY fraudulently acquired the SDM insurance portfolio using stolen funds (provided by Avon-NV), the insurance portfolio was subject to garnishment.

The district court agreed and granted summary judgment to Universitas over the objections of Avon and SDM. The district court traced the fraudulently transferred funds to Avon-WY’s acquisition of SDM Holdings life insurance portfolio and pierced Avon-WY’s corporate veil to allow Universitas to execute the judgment against the insurance portfolio.

In an order issued February 11, 2021, the district court enjoined Avon-WY from transferring or disbursing any of its interests in SDM and placed it into a receivership under Oklahoma law.

ANALYSIS

Avon and SDM raised a combined cascade of nineteen issues on appeal.

JURISDICTION AFTER THE MANDATE
Receivership

Avon and SDM argued that the district court erred by reappointing a receiver over Avon Capital-WY and its interests in SDM Holding. The appointment of the receiver rests on interpretation of an authorizing statute, the district court’s interpretation was reviewed and found to be proper.

CONCLUSION

In 2008, Mr. Carpenter stole $30 million worth of life insurance proceeds that were meant for Universitas. Universitas received its arbitration judgment against Mr. Carpenter and his entities, including Avon, in 2012. That judgment is valid for twenty years. Mr. Carpenter has been tried and convicted for his fraudulent business activities twice. See generally, United States v. Carpenter, 405 F.Supp.2d 85 (D. Mass. Dec. 15, 2005); United States v. Carpenter, 190 F.Supp.3d 260, 274 (D. Conn. June 6, 2016).

He has been sentenced and even fully served out those sentences in the years since Universitas first received its judgment.

While Mr. Carpenter’s debt to society may have been repaid, his entities’ debts to Universitas certainly have not and the judgment may be collected from the receivers.

ZALMA OPINION

Insurance fraud perpetrators, like Mr. Carpenter, prefer to spend time in jail rather than pay the victims of his crime by multiple motions, trials, appeals and obfuscation. This case put to rest Mr. Carpenter’s attempts to avoid payment to the victim of his fraud, Universitas and the lawyers will be forced to deal with the need to pay Universitas $30 million plus interest..

(c) 2025 Barry Zalma & ClaimSchool, Inc.

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00:09:30
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Read the full article at https://lnkd.in/gqva4sJq, see the video at https://lnkd.in/gR7AAuJR and at https://lnkd.in/gYfDxq_D, and at https://zalma.com/blog plus more than 5250 posts.

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In State Of Montana v. Lila Lynn Lord, 2025 MT 302, No. DA 24-0343, Supreme Court of Montana (December 30, 2025) Lila Lord (Lord) appealed her conviction for Tampering with Evidence following a jury trial in the Seventh Judicial District Court, Richland County. The case centered on a staged burglary in Sidney, Montana, orchestrated by Marie Chris Entzel with the intent to collect insurance proceeds to cover her son’s legal fees. Entzel recruited several individuals — including David Skaw, Lawrence Pohl, Laurie McGregor, and the defendant, Lila Lord — to assist in removing valuable items from her home, causing property damage and theft of items such as an enclosed trailer, boat and trailer, refrigerator, pistol, and television....

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Zalma’s Insurance Fraud Letter – January 2, 2026

Posted on January 2, 2026 by Barry Zalma
ZIFL – Volume 30 Number 1

THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL

See the video at https://rumble.com/v73nifg-zalmas-insurance-fraud-letter-january-2-2026.html and at https://youtu.be/vZC1e-_qwDg

Supreme Court of Louisiana Removes Judge

Judge Who Lied to Get Elected Cannot Serve

In In Re: Judge Tiffany Foxworth-Roberts, No. 2025-O-01127, Supreme Court of Louisiana (December 11, 2025) the Louisiana Supreme Court in an opinion by Chief Justice Weimer dealt with the recommendation of the Judiciary Commission of Louisiana (Commission) that Judge Tiffany Foxworth-Roberts be removed from office for:

1. making false and misleading statements regarding her judicial campaigns;
2. making false and misleading statements to police investigating the reported burglary of her car; and
3. withholding information and providing false, incomplete, or misleading information during the investigation by the Office of Special Counsel (OSC), as well as in the proceedings before the Commission....

00:08:13
January 02, 2026
Zalma’s Insurance Fraud Letter – January 2, 2026

Posted on January 2, 2026 by Barry Zalma
ZIFL – Volume 30 Number 1

THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL

See the video at https://rumble.com/v73nifg-zalmas-insurance-fraud-letter-january-2-2026.html and at https://youtu.be/vZC1e-_qwDg

Supreme Court of Louisiana Removes Judge

Judge Who Lied to Get Elected Cannot Serve

In In Re: Judge Tiffany Foxworth-Roberts, No. 2025-O-01127, Supreme Court of Louisiana (December 11, 2025) the Louisiana Supreme Court in an opinion by Chief Justice Weimer dealt with the recommendation of the Judiciary Commission of Louisiana (Commission) that Judge Tiffany Foxworth-Roberts be removed from office for:

1. making false and misleading statements regarding her judicial campaigns;
2. making false and misleading statements to police investigating the reported burglary of her car; and
3. withholding information and providing false, incomplete, or misleading information during the investigation by the Office of Special Counsel (OSC), as well as in the proceedings before the Commission....

00:08:13
December 31, 2025
“Sudden” is the Opposite of “Gradual”

Court Must Follow Judicial Precedent
Post 5252

Read the full article at https://www.linkedin.com/pulse/sudden-opposite-gradual-barry-zalma-esq-cfe-h7qmc, see the video at and at and at https://zalma.com/blog plus more than 5250 posts.

Insurance Policy Interpretation Requires Application of the Judicial Construction Doctrine

In Montrose Chemical Corporation Of California v. The Superior Court Of Los Angeles County, Canadian Universal Insurance Company, Inc., et al., B335073, Court of Appeal, 337 Cal.Rptr.3d 222 (9/30/2025) the Court of Appeal refused to allow extrinsic evidence to interpret the word “sudden” in qualified pollution exclusions (QPEs) as including gradual but unexpected pollution. The court held that, under controlling California appellate precedent, the term “sudden” in these standard-form exclusions unambiguously includes a temporal element (abruptness) and cannot reasonably be construed to mean ...

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December 29, 2025
Doctor Accused of Insurance Fraud Sues Insurer Who Accused Him

Lack of Jurisdiction Defeats Suit for Defamation

Post 5250

Posted on December 29, 2025 by Barry Zalma

See the video at and at

He Who Represents Himself in a Lawsuit has a Fool for a Client

In Pankaj Merchia v. United Healthcare Services, Inc., Civil Action No. 24-2700 (RC), United States District Court, District of Columbia (December 22, 2025)

FACTUAL BACKGROUND
Parties & Claims:

The plaintiff, Pankaj Merchia, is a physician, scientist, engineer, and entrepreneur, proceeding pro se. Merchia sued United Healthcare Services, Inc., a Minnesota-based medical insurance company, for defamation and related claims. The core allegation is that United Healthcare falsely accused Merchia of healthcare fraud, which led to his indictment and arrest in Massachusetts, causing reputational and business harm in the District of Columbia and nationwide.

Underlying Events:

The alleged defamation occurred when United ...

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December 15, 2025
Zalma’s Insurance Fraud Letter – December 15, 2025

Zalma’s Insurance Fraud Letter

Read the full article at https://lnkd.in/dG829BF6; see the video at https://lnkd.in/dyCggZMZ and at https://lnkd.in/d6a9QdDd.

ZIFL Volume 29, Issue 24

Subscribe to the e-mail Version of ZIFL, it’s Free! https://visitor.r20.constantcontact.com/manage/optin?v=001Gb86hroKqEYVdo-PWnMUkcitKvwMc3HNWiyrn6jw8ERzpnmgU_oNjTrm1U1YGZ7_ay4AZ7_mCLQBKsXokYWFyD_Xo_zMFYUMovVTCgTAs7liC1eR4LsDBrk2zBNDMBPp7Bq0VeAA-SNvk6xgrgl8dNR0BjCMTm_gE7bAycDEHwRXFAoyVjSABkXPPaG2Jb3SEvkeZXRXPDs%3D

Zalma’s Insurance Fraud Letter (ZIFL) continues its 29th year of publication dedicated to those involved in reducing the effect of insurance fraud. ZIFL is published 24 times a year by ClaimSchool and is written by Barry Zalma. It is provided FREE to anyone who visits the site at http://zalma.com/zalmas-insurance-fraud-letter-2/

Zalma’s Insurance Fraud Letter

Merry Christmas & Happy Hannukah

Read the following Articles from the December 15, 2025 issue:

Read the full 19 page issue of ZIFL at ...

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