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

00:09:05
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Videos
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September 18, 2026
Expert May Only Testify to What Experience Supports

Insurance Expert May Not Testify to Speculative and Contains Unsupported Conclusions.

Posted on September 18, 2026 by Barry Zalma

See the full video at and at https://rumble.com/v7fmifw-expert-may-only-testify-to-what-experience-supports.html

In Michele A. Over, and The Estate Of Paul R. Over v. State Farm Mutual Automobile Insurance Company, and State Farm Fire And Casualty Company, Civil Action No. 23-cv-02243-PAB-STV, United States District Court, D. Colorado (September 14, 2026) Michele and Paul Over sued State Farm Fire and State Farm Auto over hail-damage and stolen-vehicle claims.

The operative dispute concerned State Farm Auto’s motion to exclude or limit opinions from plaintiffs’ insurance-industry expert, Aaron Castillo. Castillo.

Law

The proponent of expert testimony must establish by a preponderance of the evidence that an expert is qualified and that the opinions are helpful, sufficiently grounded, and reliably derived and applied. Experience-based opinions must explain how the...

00:03:10
September 17, 2026
Convicted on 29 Tax-Refund-Fraud Counts

150 Months in Prison for Tax Fraud
Post 4846

Posted on September 17, 2026 by Barry Zalma

See the full video at https://lnkd.in/g8rh3JBX and https://lnkd.in/gmkdy-9C, In United States Of America v. Thomas Addaquay, Nos. 25-10609, 25-10611, United States Court of Appeals, Eleventh Circuit (September 9, 2026) the Eleventh Circuit affirmed all challenged convictions, the 150-month aggregate sentence, and the challenged $4,123,474.55 restitution award.

FACTS

In United States Of America v. Thomas Addaquay, United States Of America v. Thomas Addaquay, Nos. 25-10609, 25-10611, United States Court of Appeals, Eleventh Circuit (September 9, 2026) the Eleventh Circuit affirmed all challenged convictions, the 150-month aggregate sentence, and the challenged $4,123,474.55 restitution award.
FACTS

Thomas Addaquay controlled United Consolidated Accounting and Business Services (UC), nominally a check-cashing business.

The government proved a three-stage tax-refund scheme that converted the resulting refund checks into usable funds through ...

00:05:23
September 14, 2026
Court Enforces Fifth Amendment & Refuses to Compel Answers

Major Fraud Perpetrator Asserts Fifth Amendment Privilege to Avoid Prosecution

Post 5489

Posted on September 14, 2026 by Barry Zalma

Fraudster Refuses to Answer Questions About His Alleged Fraud

See the full video at https://lnkd.in/gvicAMDr and at https://lnkd.in/gvicAMDr

In Great American Insurance Co. v. Gemstone Property Management, LLC, et al., No. 23-cv-9100 (LJL), United States District Court, S.D. New York (September 8, 2026) Great American Insurance Company alleged that it was defrauded through a scheme in which Subin Associates, LLP recruited individuals to stage construction-site injuries, arranged unnecessary medical treatment and litigation funding, and pursued fraudulent personal-injury claims.

Luis Manuel Garcia Salcedo, resulted in a $6 million settlement. Non-party Jose Hernandez allegedly worked as an assistant manager at Subin, operated Hernandez Associates, and owned litigation-funding companies that shared office space with Subin and provided services to its clients.

After Great American ...

00:05:14
11 hours ago
Supervisory Officials are not Individually Liable

Sovereign Immunity Defeats Suit Against Police Officers

Post 4866

Posted on October 21, 2026 by Barry Zalma

In Chad Lightfoot, et al. v. Progressive Direct Insurance Company, et al., Civil Action No. 26-434, United States District Court, E.D. Louisiana (October 9, 2026) Chad Lightfoot was involved in an Orleans Parish automobile accident in 2011 and filed claims with several insurers, including Progressive.

After a related civil dispute, Progressive counsel allegedly submitted a false affidavit stating that Lightfoot had fraudulently received a $50,000 payment. A New Orleans police detective relied on the affidavit to obtain an arrest warrant, and Louisiana State Police Lieutenant Alan Arcana allegedly reported that Lightfoot had received the payment. Lightfoot was arrested in 2015 and charged with theft, insurance fraud, and perjury.

Plaintiffs alleged that no record of the payment existed and that the criminal charges were dismissed on October 15, 2024.

Lightfoot and Geralyn Hawkins filed suit in October 2025 and ...

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October 19, 2026
Plaintiff’s Reading of the Policy is Plaintiff’s Reasonable Allegations Posted on October 19, 2026 by Barry Zalma CLASS ACTION THAT STATES A SIMPLE CLEAR AND PLAUSIBLE CAUSE OF ACTION SURVIVES Post 4868 In Sheila Marino v. Farmers New World Life Insura

Plaintiff’s Reading of the Policy is Plaintiff’s Reasonable Allegations

Posted on October 19, 2026 by Barry Zalma

Post 4868

CLASS ACTION THAT STATES A SIMPLE CLEAR AND PLAUSIBLE CAUSE OF ACTION SURVIVES

In Sheila Marino v. Farmers New World Life Insurance Company, No. 2:25-cv-02200-JNW, United States District Court, W.D. Washington, Seattle (October 13, 2026) defendant Farmers New World Life Insurance Company’s (“FNWL”) moved to dismiss Plaintiff Sheila Marino’s putative class action involving flexible universal life insurance.

Marino filed a putative class action in King County Superior Court alleging: (1) breach of contract, (2) breach of the implied covenant of good faith and fair dealing, and (3) violation of the Washington Consumer Protection Act (CPA).

She pleaded two theories: an “overcharge” theory and an “underpayment of interest” theory asked the Court to take judicial notice of historical Federal Funds Effective Rates.

THE LAW

Pleading Standard.

To survive a Rule 12(b)(6) motion, a ...

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October 20, 2026
Suit Must be Ripe When Filed

A Suit Filed Before the Claim Exists is Fatal

Post 4870

Posted on October 20, 2026 by Barry Zalma

In Louis Briggs v. Shaun Wimberly; Somerset Services, Inc.; And Wimberly & Associates, PLLC, and Louis Briggs v. Shaun Wimberly And Wimberly & Associates, PLLC Nos. 2024-CA-1471-MR, 2025-CA-1366-MR, Court of Appeals of Kentucky (October 9, 2026) Louis Briggs was arrested in 2014 after an incident with police and charged with several offenses, including third-degree assault.

Probable cause was found and an indictment was returned, but the charges were eventually dismissed. His attorney, Shaun Wimberly, then filed a federal civil rights suit for Briggs in a United States district court, which also asserted state-law claims. The district court dismissed most of the claims and declined to exercise jurisdiction over the remaining state-law claims. Briggs blamed Wimberly for the result, fired him, and appealed to the Sixth Circuit.

While the federal appeal was pending, Briggs filed a legal malpractice action against Wimberly in the Jefferson Circuit Court. The Sixth ...

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