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
Post 5063
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
Subscribe to the e-mail Version of ZIFL, it’s Free!
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
Arsonist Tried To Represent Himself, Failed, and Sought Habeas Relief
Post number 5357
Read the full article at https://www.linkedin.com/pulse/he-who-acts-his-own-lawyer-has-idiot-client-barry-zalma-esq-cfe-d4bwc, See the full video at and at and at https://zalma.com/blog.
Karacson’s Arson for Profit Attempt Required Skill & Experience to Succeed
In Steve Ellis Karacson v. David Shaver, Warden, No. 25-1089, United States Court of Appeals, Sixth Circuit (May 20, 2026) Steve Karacson was convicted in Michigan state court of arson and insurance fraud after evidence showed he burned his own insured home. Investigators found multiple points of origin, gasoline odor, and evidence tying him to the scene, including cell-phone location data and a receipt showing he had purchased a gas can and gloves shortly before the fire.
FACTS
Karacson initially had appointed counsel, but his relationships with both appointed attorneys ...
Foolish to Repeatedly Disobey Court Orders
All That Remains For Trial Is Plaintiff’s Damages On Each Of These Claims And Establishing Proximate Causation Of Those Damages.
Post number 5348
See the full video at and at and at https://zalma.com/blog plus 5300 posts.
In Linh Wang v. Esurance Insurance Company, No. C24-0447-JCC, United States District Court, W.D. Washington, Seattle (May 1, 2026) John C. Coughenour, United States District Judge, found that throughout this case, culminating with its briefing on Plaintiff’s renewed motion and that Defendant has subjected Plaintiff to unnecessary motion practice for clearly discoverable information and made dubious representations (including to the Court).
FACTUAL BACKGROUND
This case involves an underinsured/uninsured motorist insurance bad faith claim arising from a 2017 motor vehicle collision. The plaintiff, Linh Wang, alleges that Esurance Insurance ...
The Right to Negotiate with Insurer is Not an Assignment of Claims
Post number 5347
Read the full article at https://www.linkedin.com/pulse/ambiguous-contract-repair-assignment-barry-zalma-esq-cfe-2xppc, see the full video at https://rumble.com/v79is1s-ambiguous-contract-to-repair-not-an-assignment.html and at and at https://zalma.com/blog plus more than 5300 posts.
Nebraska Requires an Actual Assignment to Allow Contractor to Sue Insurer
In Millard Gutter Company, a corporation doing business as Millard Roofing and Gutter v. Farmers Mutual Insurance Company of Nebraska, also known as Farmers Mutual Insurance, also known as Farmers Mutual, No. A-24-818, Court of Appeals of Nebraska (May 5, 2026) Millard sued Farmers as an assignee of Jane Anzalone who had hired Millard Gutter to repair the roof of her home and agreed to allow Millard Gutter to coordinate with her insurer, Farmers Mutual, concerning reimbursement for repairs authorized under her insurance policy.
FACTUAL BACKGROUND
In ...
It is a Crime to Lie to Your Insurer That Accident Happened After Policy Inception
Post number 5386
Posted on July 3, 2026 by Barry Zalma
Conviction for Fraud Affirmed Because Evidence Overwhelming
In State Of Washington v. Saleem Mumin Robinson, No. 87244-3-I, Court of Appeals of Washington, Division 1 (June 29, 2026) Saleem Robinson was involved in an automobile collision on May 18, 2021. The other driver, Mohamed Waggeh, photographed Robinson’s documents and later reported the collision to GEICO, identifying the time as approximately 12:40 p.m.
That same day, at 6:06 p.m., more than five hours after the accident, Robinson purchased Progressive insurance for the vehicle involved in the collision.
The next morning, Robinson called Progressive to report the claim and stated that the accident occurred around 6:15 p.m. Progressive recorded that call without advising Robinson that it was being recorded. Progressive later conducted a special investigative unit investigation the claim because it was submitted shortly ...
Deprive Insurer of the Ability to Properly and Timely Investigate Claim & Recover Nothing
Posted on July 2, 2026 by Barry Zalma
Post number 5385
No Contract Claim No Bad Faith Claim
In South Alexander Development I, LLC v.Markel American Insurance Co., Civil Action No. 23-1436-JWD-SDJ, United States District Court, M.D. Louisiana (June 24, 2026) South Alexander Development I, LLC (SADI) owned and operated a solar farm in Springfield, Louisiana that allegedly sustained significant Hurricane Ida damage.
After SADI submitted a claim, MAIC ultimately paid $1,099,614.02 for undisputed physical damage plus the $210,000 income-loss policy limit. SADI later sued for breach of contract and statutory bad faith, contending MAIC failed to fully investigate and adjust the claim; MAIC sought summary judgment, arguing SADI failed to cooperate and withheld material repair-cost information.
LAW:
Louisiana insurance policies are interpreted as contracts according to their plain meaning, and the insured bears the burden ...
Deprive Insurer of the Ability to Properly and Timely Investigate Claim & Recover Nothing
Posted on July 2, 2026 by Barry Zalma
Post number 5385
No Contract Claim No Bad Faith Claim
In South Alexander Development I, LLC v.Markel American Insurance Co., Civil Action No. 23-1436-JWD-SDJ, United States District Court, M.D. Louisiana (June 24, 2026) South Alexander Development I, LLC (SADI) owned and operated a solar farm in Springfield, Louisiana that allegedly sustained significant Hurricane Ida damage.
After SADI submitted a claim, MAIC ultimately paid $1,099,614.02 for undisputed physical damage plus the $210,000 income-loss policy limit. SADI later sued for breach of contract and statutory bad faith, contending MAIC failed to fully investigate and adjust the claim; MAIC sought summary judgment, arguing SADI failed to cooperate and withheld material repair-cost information.
LAW:
Louisiana insurance policies are interpreted as contracts according to their plain meaning, and the insured bears the burden ...
