ZIFL – Volume 29, Issue 9
Posted on May 1, 2025 by Barry Zalma
See the full video at https://www.youtube.com/watch?v=pi0yFHFseG8 and at https://rumble.com/v6ss2an-zalmas-insurance-fraud-letter-may-1-2025.html
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Happy Law Day
Law Day, held annually on May 1, is a national day set aside to celebrate the rule of law. Law Day provides an opportunity to understand how law and the legal process protect our liberty, strive to achieve justice, and contribute to the freedoms that all Americans share.
Read the full 22 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/04/ZIFL-05-01-2025.pdf
The Source for the Insurance Fraud Professional
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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/ You can read the full issue of the May 1, 2025 issue at https://zalma.com/blog/wp-content/uploads/2025/04/
ZIFL-05-01-2025.pdf.
This issue contains the following articles about insurance fraud:
FRAUD DOESN’T PAY – IT COSTS
INSURANCE FRAUDSTER MUST PAY INSURER FULL RESTITUTION
Plaintiff Liberty Insurance Corporation (“Liberty”) issued a homeowners insurance policy to Defendant Jack Strunk that was active when his home was damaged by fire. Strunk made two insurance claims: one for fire damage and another for alleged theft of certain personal property after the fire. Strunk sued Liberty for the payment of the alleged damages. That case was removed to federal court and ultimately settled by Liberty paying $100,000 to Strunk.
Read this article and the full 22 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/04/ZIFL-05-01-2025.pdf
It is not Nice to Lie to Your Insurer
Material Misrepresentation on Application Provides a Defense to Claim
Lies on Application for Insurance Eliminates Coverage for a Claim
Magna Tyres USA, LLC appealed the summary judgment in favor of Coface North America Insurance Company and against its complaint of breach of contract and request for a declaratory judgment. In Magna Tyres USA, LLC v. Coface North America Insurance Company, No. 24-13036, the United States Court of Appeals, Eleventh Circuit (April 10, 2025) determined the effect of a material misrepresentation on an application for insurance.
Read this article and the full 22 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/04/ZIFL-05-01-2025.pdf
Health Insurance Fraud Convictions
Two Former Laboratory Sales Executives Sentenced To Federal Prison For Roles In Health Care Kickback Conspiracy
Stephen Kash, 51, of Winnie, Texas was sentenced to 18 months in federal prison and ordered to forfeit $779,773.70 in criminal proceeds. Courtney Love, 46, of Dallas, was sentenced to 12 months and one day in federal prison and ordered to forfeit $217,268.75 in criminal proceeds. The sentences were imposed by U.S. District Judge Jeremy D. Kernodle on April 24, 2025.
The two former laboratory sales executives were sentenced to federal prison for conspiring to violate the Anti-Kickback Statute.
Read this article and the full 22 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/04/ZIFL-05-01-2025.pdf
MORE MCCLENNY MOSELEY & ASSOCIATES ISSUES
This is ZIFL’s forty-fourth installment of the saga of McClenny, Moseley & Associates and its problems with the federal courts in the State of Louisiana and what appears to be an effort to profit from what some Magistrate and District judges indicate may be criminal conduct to profit from insurance claims relating to hurricane damage to the public of the state of Louisiana.
Velawcity Allegedly Committed Barratry on Behalf of Lawyers
To Be Sued for Barratry in Texas the Court Must Have Jurisdiction
Read this article and the full 22 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/04/ZIFL-05-01-2025.pdf
CONVICTIONS OF OTHER THAN HEALTH INSURANCE FRAUD
Defense Contractor’s Longtime Associate Pleads Guilty to Conspiracy to Defraud the United States
Thomas G. Ehr worked for or on behalf of a co-conspirator, a defense contractor who owned 50% of a business that supplied jet fuel to U.S. troops in Afghanistan and Middle East. Ehr was hired to manage several music television and entertainment projects funded with proceeds from this business. Over time Ehr played a role in several of his co-conspirator’s other investments, including a $60 million real estate investment in Tulum, Mexico, and a $50 million fuel infrastructure project.
Read this article and the full 22 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/04/ZIFL-05-01-2025.pdf
The Insured Must Produce Tax Returns If the First Party Insurer Demands Production
Every first party property policy contains a provision requiring an insured to produce all relevant documents required to be produced by the Insurer and to appear for examination under oath [California Insurance Code § 2071; NY Standard Fire Insurance policy].
Although there is no absolute privilege that protects tax returns and related documents from discovery, “due to the sensitive information contained therein and the public interest to encourage the filing by taxpayers of complete and accurate returns, their production should not be routinely required.” See Mitsui & Co. v. Puerto Rico Water Resources Authority, 79 F.R.D. 72, 80 (D.P.R. 1978).
Read this article and the full 22 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/04/ZIFL-05-01-2025.pdf
How to Interview
The interview is an essential form of fact gathering for every type of human interaction. Interviews happen everywhere; they are performed by almost everyone. Interviewing is also an art, and the most effective interviews are conducted by those who are knowledgeable and skilled in this art.
Read this article and the full 22 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/04/ZIFL-05-01-2025.pdf
Barry Zalma, Esq., CFE, Barry Zalma, Inc.,
4441 Sepulveda Boulevard
CULVER CITY CA 90230-4847
310-390-4455
[email protected], http://www.zalma.com, http://zalma.com/blog
Read this article and the full 22 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/04/ZIFL-05-01-2025.pdf
When Harm is Inherent in the Nature of the Act it is Intentional
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See the video at and at and at https://zalma.com/blog plus more than 5200 posts.
No Coverage for Intentional Acts
Hitting a Person in the Face is an Intentional Act
In Unitrin Auto and Home Insurance Company v. Brian C. Sullivan, et al., George A. Ciminello, No. 2022-01607, Index No. 21632/14, Supreme Court of New York, Second Department (November 19, 2025) George A. Ciminello was injured when struck in the face by a cup filled with liquid, thrown from a moving vehicle operated by Brian C. Sullivan, with Robert Harford as the passenger who threw the cup. The vehicle approached Ciminello at about 30 mph, from 2 to 10 feet away, and Harford extended his arm to make contact. The cup splintered upon impact.
Sullivan and Harford later conceded liability on the intentional tort claim before a damages trial.
Insurance Policy:
Unitrin Auto and Home...
Obtaining Title to Church by Fraud Defeated
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Read the full article at https://www.linkedin.com/pulse/unmitigated-gall-abuse-elderly-bishop-his-church-zalma-esq-cfe-xcasc, see the video at and at and at https://zalma.com/blog plus more than 5200 posts.
It is Villainous to Steal Church Property from Sick and Elderly Bishop
In Testimonial Cathedral Local Church of God in Christ v. EquityKey Real Estate Option, LLC et al. (Cal. Ct. App., 2d Dist., Div. 8, No. B331522 (Nov. 18, 2025) EquityKey (through broker Steven Sharpe and Frank Wheaton, a trusted advisor/friend of elderly Bishop Jimmy Hackworth) presented a deal supposedly for a $4 million life-insurance policy on Hackworth’s life with EquityKey as beneficiary. In exchange, EquityKey paid Hackworth $400,000 upfront.
Factual Background
To qualify Hackworth for the large policy, church real property on South Western Ave., Los Angeles was temporarily ...
Guilty of Money Laundering Scheme
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See the video at https://lnkd.in/gqh7V46x and at https://lnkd.in/gmE-zrDC and at https://zalma.com/blog plus more than 5200 posts.
Prison Sentence for Fraud Must be Limited to the Fraud in Which the Defendant Participated
In United States v. Stephen O. Anagor, No. 2:24-CR-00019-DCLC-CRW (E.D. Tenn., Nov. 26, 2025) by Judge Clifton L. Corker the government sought to increase the defendant’s sentence because his co-conspirators added a fraudulent FBI scam that resulted in the victim’s suicide. Anagor sought a lower sentence because he was only involved in part of the fraud.
Charges & Plea
Defendant, a U.S. Army soldier pled guilty on June 11, 2025 to Conspiracy to Commit Mail and Wire Fraud, Aiding and Abetting Aggravated Stalking Resulting in Death and Aiding and Abetting Aggravated Identity Theft that was part of a larger 38-count superseding indictment against Anagor and co-defendants Chinagorom Onwumere and Salma Abdalkareem for an international Nigerian-based ...
The Professional Claims Handler
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Posted on October 31, 2025 by Barry Zalma
An Insurance claims professionals should be a person who:
Can read and understand the insurance policies issued by the insurer.
Understands the promises made by the policy.
Understand their obligation, as an insurer’s claims staff, to fulfill the promises made.
Are competent investigators.
Have empathy and recognize the difference between empathy and sympathy.
Understand medicine relating to traumatic injuries and are sufficiently versed in tort law to deal with lawyers as equals.
Understand how to repair damage to real and personal property and the value of the repairs or the property.
Understand how to negotiate a fair and reasonable settlement with the insured that is fair and reasonable to both the insured and the insurer.
How to Create Claims Professionals
To avoid fraudulent claims, claims of breach of contract, bad faith, punitive damages, unresolved losses, and to make a profit, insurers ...
The History Behind the Creation of a Claims Handling Expert
The Insurance Industry Needs to Implement Excellence in Claims Handling or Fail
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This is a change from my normal blog postings. It is my attempt. in more than one post, to explain the need for professional claims representatives who comply with the basic custom and practice of the insurance industry. This statement of my philosophy on claims handling starts with my history as a claims adjuster, insurance defense and coverage lawyer and insurance claims handling expert.
My Training to be an Insurance Claims Adjuster
When I was discharged from the US Army in 1967 I was hired as an insurance adjuster trainee by a professional and well respected insurance company. The insurer took a chance on me because I had been an Army Intelligence Investigator for my three years in the military and could use that training and experience to be a basis to become a professional insurance adjuster.
I was initially sat at a desk reading a text-book on insurance ...
The History Behind the Creation of a Claims Handling Expert
The Insurance Industry Needs to Implement Excellence in Claims Handling or Fail
Post 5210
This is a change from my normal blog postings. It is my attempt. in more than one post, to explain the need for professional claims representatives who comply with the basic custom and practice of the insurance industry. This statement of my philosophy on claims handling starts with my history as a claims adjuster, insurance defense and coverage lawyer and insurance claims handling expert.
My Training to be an Insurance Claims Adjuster
When I was discharged from the US Army in 1967 I was hired as an insurance adjuster trainee by a professional and well respected insurance company. The insurer took a chance on me because I had been an Army Intelligence Investigator for my three years in the military and could use that training and experience to be a basis to become a professional insurance adjuster.
I was initially sat at a desk reading a text-book on insurance ...
