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May 09, 2025
Pro Se Plaintiff’s Frivolous Suit Dismissed

Suit Claiming Ex-President Attempted to Kill Plaintiff for Profit, Insurance Fraud, Assaults, Battery, and False Imprisonment Dismissed

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In a suit entitled Ivette T Echenidue v. President Biden, et al., Civil Action No. 1:25-cv-00517 (UNA), Judge Chutkan of the United States District Court, District of Columbia (April 17, 2025) refused to acknowledge the claims of the plaintiff.

Judge Chutkan explained that Echenidue’s suit was before the court on its initial review of plaintiff’s pro se complaint. The court granted the in forma pauperis application and, for the reasons explained below, dismissed the case pursuant to 28 U.S.C. § 1915(e)(2)(B)(i), by which the court is required to dismiss a case “at any time” it determines that the action is frivolous.

IS THE ACTION FRIVOLOUS?

Judge Chutkan noted that “A complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)).

A complaint that lacks an arguable basis either in law or in fact is frivolous and a complaint plainly abusive of the judicial process is properly typed malicious.

Plaintiff, who purports to be from Ohio, Florida, and Georgia sued President Biden, the U.S. District Court for the Middle District of Alabama, and the Fifteenth Circuit Court of Alabama in Montgomery County, although it appears that she may attempt to sue others who are not listed in the case caption. The allegations were quite difficult for an experienced judge to follow. It consisted of a hodgepodge of alleged wrongdoing, borne out of a purported government conspiracy evidenced by “death for profit, coverups, bribes, court malfeasance, racketeering, embezzlement, collusion, insurance fraud, assaults, battery, and false imprisonment.”

Plaintiff further alleged that the defendants have threatened her with murder, and that President Biden led a charge to alienate her from her mother, who was also deprived of medical care, “stripped of her rights,” “killed for profit,” and denied a “Roman Catholic burial.” In the prayer Plaintiff demands $800 million in damages from each defendant and calls for their prosecution.

CONCLUSION

Judge Chutkan concluded that plaintiff’s allegations were frivolous, and the court cannot exercise subject matter jurisdiction over a frivolous complaint.

The federal courts are without power to entertain claims otherwise within their jurisdiction if they are so attenuated and unsubstantial as to be absolutely devoid of merit including where the plaintiff allegedly was subjected to a campaign of surveillance and harassment deriving from uncertain origins.

Applicable here, a court is obligated to dismiss a complaint as frivolous when the facts alleged rise to the level of the irrational, wholly incredible or postulate events and circumstances of a wholly fanciful kind.

Plaintiff’s allegations are sufficiently fanciful to warrant dismissal under this standard. Even generously construing plaintiff’s complaint, her allegations fail to rise above pure conjecture. For those reasons, she dismissed the suit without prejudice.

ZALMA OPINION

In 1968, when I was a law student, I was required to work in a legal aid office in Venice, California, which at the time was a slum occupied only by poor, unemployed and helpless. During that time I was faced with people asking for my legal assistance by a man who claimed he invented the Norton Bomb Site that was stolen from his mind by the US Government, a man who identified himself as Jesus of Nazareth seeking assistance for his creation of Christianity and many people who were in the process of being evicted from their homes for failure to pay rent. I learned that there wee many people who spoke clearly, intelligently, competently with what appeared to be truthful but were absolutely insane. I learned to be kind but not believe or try to assist the insane and hope to help them gain psychiatric help. Judge Chutkan apparently had a similar background and faced with the amazing and fanciful lawsuit had no choice but to dismiss it as frivolous.

(c) 2025 Barry Zalma & ClaimSchool, Inc.

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December 30, 2025
Montana Lawyer Commits Insurance Fraud and Receives Minimal Punishment

Montana County Attorney Admits to Insurance Fraud & Is Only Suspended from Practice for 60 Days
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A Lawyer Who Commits Insurance Fraud and Pleas to a Lower Charge Only Suspended

In The Matter Of: Naomi R. Leisz, Attorney at Law, No. PR 25-0150, Supreme Court of Montana (December 23, 2025) the Montana Office of Disciplinary Counsel (ODC) filed a formal disciplinary complaint with the Commission on Practice (Commission) against Montana attorney Naomi R. Leisz.

On September 25, 2025, Leisz tendered a conditional admission and affidavit of consent. Leisz acknowledged the material facts of the complaint were true and she had violated the Montana Rules of Professional Conduct as alleged by ODC.

ADMISSIONS

Leisz admitted that in April 2022, her minor son was involved in a car accident in which he hit a power pole. Leisz’s son ...

00:08:27
December 30, 2025
Montana Lawyer Commits Insurance Fraud and Receives Minimal Punishment

Montana County Attorney Admits to Insurance Fraud & Is Only Suspended from Practice for 60 Days
Post 5251

Read the full article at https://lnkd.in/gnBaCjmv, see the video at https://lnkd.in/gfpVsyAd and at https://lnkd.in/gC73Nd8z, and at https://zalma.com/blog plus more than 5250 posts.

A Lawyer Who Commits Insurance Fraud and Pleas to a Lower Charge Only Suspended

In The Matter Of: Naomi R. Leisz, Attorney at Law, No. PR 25-0150, Supreme Court of Montana (December 23, 2025) the Montana Office of Disciplinary Counsel (ODC) filed a formal disciplinary complaint with the Commission on Practice (Commission) against Montana attorney Naomi R. Leisz.

On September 25, 2025, Leisz tendered a conditional admission and affidavit of consent. Leisz acknowledged the material facts of the complaint were true and she had violated the Montana Rules of Professional Conduct as alleged by ODC.

ADMISSIONS

Leisz admitted that in April 2022, her minor son was involved in a car accident in which he hit a power pole. Leisz’s son ...

00:08:27
December 26, 2025
Liability Insurance only Responds to Fortuitous Acts

Insurer’s Exclusion for Claims of Assault & Battery is Effective
Post 5250

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Bar Fight With Security is an Excluded Assault & Battery

In The Cincinnati Specialty Underwriters Insurance Company v. Mainline Private Security, LLC, et al., Civil Action No. 24-3871, United States District Court, E.D. Pennsylvania (December 16, 2025) two violent attacks occurred in Philadelphia involving young men, Eric Pope (who died) and Rishabh Abhyankar (who suffered catastrophic injuries). Both incidents involved security guards provided by Mainline Private Security, LLC (“Mainline”) at local bars. The estates of the victims sued the attackers, the bars, and Mainline for negligence and assault/battery. The insurer exhausted a special limit and then denied defense or indemnity to Mainline Private Security.

INSURANCE COVERAGE

Mainline had purchased a commercial ...

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4 hours ago
“Sudden” is the Opposite of “Gradual”

Court Must Follow Judicial Precedent
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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

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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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