Zalma on Insurance
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Insurance Claims professional presents articles and videos on insurance, insurance Claims and insurance law for insurance Claims adjusters, insurance professionals and insurance lawyers who wish to improve their skills and knowledge. Presented by an internationally recognized expert and author.
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July 01, 2025
Zalma’s Insurance Fraud Letter – July 1, 2025

See the full video at https://rumble.com/v6vkjrv-zalmas-insurance-fraud-letter-july-1-2025.html and at https://youtu.be/_rIBWqPcJDQ

ZIFL – Volume 29 No. 13 – July 1, 2025

Post 5111

Uber Technologies Inc. sued a group of lawyers, medical providers and rideshare drivers it claims staged car accidents, manufactured damages and received unnecessary medical procedures to take advantage of insurance policies in Florida, costing the rideshare giant “several million dollars” in legal fees.

Uber accused the group of conspiring to “generate an excuse to deliver unnecessary medical care, submit false insurance claims for recovery and file frivolous lawsuits to sue for non-existent damages” between 2023 and 2024. The five drivers named in the suit were “recruited with bribes to stage accidents,” Uber said in the federal suit filed in south Florida. The group recruited claimants who took their cars to designated body shops to manufacture the “false impression that the accidents resulted in injury,” the company said.

Read the full article and the full 19 pages of the issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/06/ZIFL-07-01-2025.pdf

Health Insurance Fraud Convictions

Fugitive Physician Sentenced to Prison in Medicare Fraud Scheme

Lilit Gagikovna Baltaian, 61, a Porter Ranch, California physician was sentenced June 12, 2025 in Los Angeles to 54 months in prison for health care fraud arising from her false home health certifications and related fraudulent billings to Medicare. She is a fugitive and was sentenced in absentia.

According to court documents Baltaian was a physician licensed to practice in California and an enrolled Medicare provider. From January 2012 to July 2018, she falsely certified patients to receive home health care from at least four Los Angeles area home health agencies. These certifications were used by the home health agencies to fraudulently bill Medicare. In some instances, Baltaian pre-signed blank, undated physician certification forms knowing that the home health agencies would falsify the forms to make appear that she had seen the Medicare beneficiaries and made clinical findings to support the need for home health care, when she had done neither. Baltaian received cash payments related to these referrals and also separately billed Medicare for signing the fraudulent certifications.

Read the full article and the full 19 pages of the issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/06/ZIFL-07-01-2025.pdf

Prisoner’s Loses Suit Against Sheriff for Failure to Exhaust Administrative Remedies

Creative Litigation Fails Because Crime Does not Pay

Prisoner Acting as His Own Lawyer Misses Prerequisite to His Suit

In this pro se prisoner case brought under 42 U.S.C. § 1983, United States Magistrate Judge Bradley W. Rath’s Report and Recommendation recommends that Defendants Sheriff John Ledbetter, Geneva Drummond, and VitalCore’s Motions for Summary Judgment be granted, that Plaintiff Monnie Villarreal’s Motion to Amend be denied as moot, and that the Court dismiss this case without prejudice for failure to exhaust administrative remedies.

In Monnie Villarreal v. Vitalcore, et al. No. 1:24-cv-99-HSO-BWR, United States District Court, S.D. Mississippi, (June 18, 2025) the District Judge adopted Magistrate Judge’s Report and Recommendation as the opinion of the Court.

Read the full article and the full 19 pages of the issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/06/ZIFL-07-01-2025.pdf

WHAT IS NEEDED TO DETER INSURANCE FRAUD?

To do so the insurers must train their staff to recognize the elements of both the crime of insurance fraud and the elements of the civil tort of insurance fraud. If well trained, insurance personnel collecting information about a potential insurance fraud, will know the type and quality of information that either a prosecutor or a civil defense lawyer will need to prove fraud was attempted.

Read the full article and the full 19 pages of the issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/06/ZIFL-07-01-2025.pdf

FRAUD CONVICTIONS FOR OTHER THAN HEALTH INSURANCE FRAUD

Founder of Lender Service Provider Convicted for Role in Multimillion-Dollar PPP Fraud Scheme

Stephanie Hockridge, a founder of the lender service provider Blueacorn, was convicted by a Federal Jury in connection with a scheme to fraudulently obtain tens of millions of dollars in COVID-19 relief money guaranteed by the U. S. Small Business Administration (SBA) through the Paycheck Protection Program (PPP).

Read the full article and the full 19 pages of the issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/06/ZIFL-07-01-2025.pdf

Bad Faith Set-Ups

Bad faith insurance claims are successful when a plaintiff can prove that the insurance company wrongfully denied an insurance claim and deprived the insured of the benefits of the contract of insurance without good cause. Bad faith insurance suits can arise in the context of any insurance policy.

Read the full article and the full 19 pages of the issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/06/ZIFL-07-01-2025.pdf

BARRY ZALMA

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; Subscribe to “Excellence in Claims Handling” at href=”https://barryzalma.substack.com/subscribe.”> “Excellence in Claims Handling” at href=“https://barryzalma.substack.com/subscribe.”> a href=“https://barryzalma.substack.com/subscribe.”>

Go to the podcast Zalma On Insurance at https://anchor.fm/barry-zalma, Go to Zalma’s Insurance Fraud Letter at https://zalma.com/zalmas-insurance-fraud-letter-2/ Follow Mr. Zalma on Twitter at https://twitter.com/bzalma, Go to Barry Zalma videos at Rumble.com at https://rumble.com/c/c-262921, https://gettr.com/@zalma, Go to Barry Zalma on YouTube- https://www.youtube.com/channel/UCysiZklEtxZsSF9DfC0Expg, Go to the Insurance Claims Library – https://zalma.com/blog/insurance-claims-library/

Read the full article and the full 19 pages of the issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/06/ZIFL-07-01-2025.pdf

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May 01, 2026
Zalma’s Insurance Fraud Letter – May 1, 2026

Happy Law Day

ZIFL – Volume 30, Issue 9 – May 1, 2026

Read the full article at https://www.linkedin.com/pulse/zalmas-insurance-fraud-letter-may-1-2026-barry-zalma-esq-cfe-2tywc, see the video at at and at https://zalma.com/blog plus more than 5300 posts.

THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL

ZIFL – Volume 30, Issue 9 – May 1, 2026

Zalma’s Insurance Fraud Letter (ZIFL) continues its 30th year of publication dedicated to those involved in reducing the effect of insurance fraud. ZIFL is published 24 times a year and is written by Barry Zalma.

DOJ Creates National Fraud Enforcement Division

Will the Feds Take on Insurance Fraud? Possibly as Part of a National Anti-Fraud Effort

On April 7, 2026, the Acting Attorney General, Todd Blanche, issued a memorandum establishing the Department of Justice National Fraud Enforcement Division (NFED). The memo describes an ambitious, but perhaps redundant, vision for this ...

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April 30, 2026
The Efficient Proximate Cause Doctrine Saves a Claim

When Abalone Died As a Result of Multiple Causes The Efficient Proximate Cause Requires Payment

Post number 5345

Read the full article at https://www.linkedin.com/pulse/efficient-proximate-cause-doctrine-saves-claim-barry-zalma-esq-cfe-yndlc, see the video at and at and at https://zalma.com/blog plus more than 5300 posts.

In American Abalone Farms, LLC v. Star Insurance Company et al., H052643, California Court of Appeals, Sixth District (April 27, 2026) the Court of Appeals dealt with an insurance coverage issue that required application of the efficient proximate cause doctrine.

FACTS

American Abalone Farms, LLC ("American Abalone" ) operates an aquaculture farm in Santa Cruz County, California, raising abalone in tanks. In August 2020, the CZU Lightning Complex Fires led to a prolonged power outage and road closures near the farm. As a result, the farm’s water pumps failed, causing the death of most of the ...

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April 29, 2026
Breach of a Specific Condition Precedent Is a Complete Defense

Breach of a Specific Condition Precedent Is a Complete Defense

See the video at and at and at https://zalma.com/blog plus more than 5300 posts.

In United Services Automobile Association and State Farm Mutual Automobile Insurance Company v. Anthony Wenzell, 2026 CO 25 (Colo. Apr. 27, 2026) Anthony Wenzell was rear-ended in a car accident. He had a significant prior 2014 accident that required back surgery.

Wenzell claimed underinsured-motorist (UIM) benefits under three policies: (1) the tortfeasor’s liability policy, (2) his own primary UIM policy with State Farm, and (3) an excess UIM policy issued by USAA (under his brother’s policy, which contained an “other insurance” clause making USAA’s coverage excess over any collectible insurance).

After receiving the claims, both USAA and State Farm repeatedly requested that Wenzell execute comprehensive medical-release authorizations so they could obtain his full medical records and ...

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14 hours ago

It is Fraud to Make the Same Claim Twice

Read the full article at https://www.linkedin.com/pulse/fraud-make-same-claim-twice-barry-zalma-esq-cfe-c4g8c and at https://zalma.com/blog.

Chutzpah: After Being Paid for a New Roof Insured Makes Second Claim For Same Damages

Post number 5347

No One is Entitled to be Paid for the Same Loss Twice

In Mohammed Ali Khalili v. State Farm Lloyds, No. 14-25-00611-CV, Court of Appeals of Texas (April 30, 2026) Khalili maintained a State Farm Lloyds homeowners insurance policy for decades. In 2008 he filed a roof-damage claim; State Farm paid him to replace the entire roof (shingles and gutters). Khalili never replaced the roof and repeated his claim.

BACKGROUND

In 2021 he filed a second roof claim. State Farm’s inspectors found the roof “very old” with extensive non-storm-related damage. The claim was denied because (1) the damage did not exceed the deductible and (2) State Farm had already paid for a full roof replacement.

PROCEDURAL HISTORY

State Farm filed motion for summary...

post photo preview
14 hours ago

It is Fraud to Make the Same Claim Twice

Read the full article at https://www.linkedin.com/pulse/fraud-make-same-claim-twice-barry-zalma-esq-cfe-c4g8c and at https://zalma.com/blog.

Chutzpah: After Being Paid for a New Roof Insured Makes Second Claim For Same Damages

Post number 5347

No One is Entitled to be Paid for the Same Loss Twice

In Mohammed Ali Khalili v. State Farm Lloyds, No. 14-25-00611-CV, Court of Appeals of Texas (April 30, 2026) Khalili maintained a State Farm Lloyds homeowners insurance policy for decades. In 2008 he filed a roof-damage claim; State Farm paid him to replace the entire roof (shingles and gutters). Khalili never replaced the roof and repeated his claim.

BACKGROUND

In 2021 he filed a second roof claim. State Farm’s inspectors found the roof “very old” with extensive non-storm-related damage. The claim was denied because (1) the damage did not exceed the deductible and (2) State Farm had already paid for a full roof replacement.

PROCEDURAL HISTORY

State Farm filed motion for summary...

post photo preview
April 30, 2026
Investigation of First Party Property Claims

What Must be Done after Notice of a Claim is Received by the Insurer

Read the full article at https://lnkd.in/gzvvdkMZ and at https://zalma.com/blog.

Below you will read from this post until you reach the the end of this blog post as the free part of an Excellence in Claims Handling post. To read the full article and receive all articles for members of Excellence in Claims Handling you should consider joining as a paid member to get full access to articles for members only, to our news, analysis, insurance coverage, claims, insurance fraud and insurance webinars, by clicking at the subscription link below.

A first party property policy does not insure property: it insures a person, partnership, corporation or other entity against the risk of loss of the property. Before an insured can make a claim for indemnity under a policy of first party property insurance the insured must prove that there was damage to property the risk of loss of which was insured by the policy. The obligation imposed on the insured ...

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