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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September 15, 2025
Zalma’s Insurance Fraud Letter – September 15, 2025

THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL

Post 5190

ZIFL Volume 29, Issue 18

See the full video at https://rumble.com/v6yuis6-zalmas-insurance-fraud-letter-september-15-2025.html and at https://youtu.be/64CobaRmzd0, at https://zalma.com/blog, and https://zalma.com/blog/wp-content/uploads/2025/08/ZIFL-09-01-2025-1.pdf.

Posted on September 15, 2025 by Barry Zalma
ZIFL Volume 29, Issue 18

THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL

Subscribe to the e-mail Version of ZIFL, it’s Free!
Post 5190

See the full video at https://rumble.com/v6yuis6-zalmas-insurance-fraud-letter-september-15-2025.html and at https://youtu.be/64CobaRmzd0

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/
The Contents of the September 15, 2025 Issue of ZIFL Includes:
Evidence Established that Rudolf Murdered His Wife in Africa
Not Nice & Crime to Kill Your Wife for the Insurance Money
Shotgun Murder of Wife in Africa Not an Accident

In United States Of America v. Lawrence Rudolph, National Association Of Criminal Defense Lawyers, Amicus Curiae, No. 23-1278, United States Court of Appeals, Tenth Circuit (September 8, 2025) affirmed his conviction.

The United States Court of Appeals, Tenth Circuit’s opined on the appeal of Lawrence Rudolph, convicted for the foreign murder of his wife Bianca Rudolph and related mail fraud charges.

Read the full article and the full 18 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/08/ZIFL-09-01-2025-1.pdf

MORE MCCLENNY MOSELEY & ASSOCIATES ISSUES

This is ZIFL’s fifty first 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.
6/13/2025 – MMA Law Firm’s Chapter 11 Disclosure Statement includes a section titled “What Happened in Louisiana?” – see page 20 – but the most important truths are found between the lines (and in what’s omitted entirely).

Health Insurance Fraud Convictions

New York Cardiologist Guilty – 37 Months in Prison

Niranjan Mittal, a Brooklyn-based cardiologist, has been sentenced to 37 months in prison for his participation in a years-long healthcare fraud and bribery scheme that involved paying other physicians for referrals and fabricating patient records. The 72-year-old was also sentenced to two years of supervised release and forced to forfeit all proceeds that can be traced to this scheme.

Read the full article and the full 18 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/08/ZIFL-09-01-2025-1.pdf

FRAUD CONVICTIONS FOR OTHER THAN HEALTH INSURANCE FRAUD

Chutzpah: An Arson for Profit to Pay Restitution for a Previous Conviction|

Emmajean Mowery committed the crimes of arson-for-profit to receive a payout to help cover a previous, court-ordered restitution sum for burning a previous home. Mowery increased her insurance policy weeks before the 2023 arson fire.

Mowery, a Pennsylvania woman was sentenced up to three years in prison for intentionally setting fire to her rented home in 2023 as a part of a scheme to collect an insurance payout.

Read the full article and the full 18 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/08/ZIFL-09-01-2025-1.pdf

Ethics for the Insurance Professional

Insurance is, by definition, a business of the utmost good faith. This means that both parties to the contract of insurance must act fairly and in good faith to each other and do nothing that will deprive the other of the benefits the contract of insurance promised.

Without the covenant of good faith and fair dealing, and ethical people who work in the insurance industry applying and fulfilling the covenant, effective insurance to spread the risk of loss to a large community of insurance professionals, is impossible. One cannot act fairly and in good faith without being a person with a well-formed ethical compass.

This article was adapted from my book The Compact Book on Ethics for the Insurance Professional Available from amazon.com.

Read the full article and the full 18 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/08/ZIFL-09-01-2025-1.pdf

What Happens When PI Lawyers Sue Each Other

The Insurance Journal reported on September 11, 2025 that two high-profile Boston-area personal injury law firms have sued each other alleging trade secret theft, breach of loyalty, conspiracy, unfair competition and more. You can read the full report at the link.

It is a very interesting and detailed article by Andrew G. Simpson and I recommend you read the entire article.
Fraud in The Presentation of a Claim

Insurance fraud in the presentation of a claim, by definition, voids insurance. In 1884 the U.S. Supreme Court considered the issue and decided that a fraud in the presentation of a claim, even if it was not intended to deceive the insurer and would have had little effect on the indemnity paid, still caused the policy to be void and the claim to be denied. [Claflin & Others v. Commonwealth Insurance Company.; Same v. Western Assurance Company.; Same v. Franklin Insurance Company, 110 U.S. 81; 3 S. Ct. 507; 28 L. Ed. 76; 1884 U.S. LEXIS 1661]

Read this article and the full 18 page issue of the September 15, 2025 issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/09/ZIFL-09-15-2025.pdf

BARRY ZALMA

Barry Zalma, Esq., CFE, Barry Zalma, Inc., 4441 Sepulveda Boulevard, CULVER CITY CA 90230-4847, 310-390-4455

Read the full article and the full 18 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/08/ZIFL-09-15-2025-1.pdf

00:09:09
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October 03, 2025
Insurer’s Attempt to Obtain Summary Judgment Fails

To Prove Fraud Admissible Evidence is Required
Post 5200

See the full video at https://lnkd.in/g9cmMseN and at https://lnkd.in/g5eAYwdN, and at https://zalma.com/blog plus more than 5200 posts.

Allegations That Health Care Providers Assist in No Fault Fraud Escape MSJ

In NATIONWIDE GENERAL INSURANCE COMPANY, NATIONWIDE MUTUAL INSURANCE COMPANY, and any and all of their subsidiaries, affiliates and/or parent companies. Plaintiffs v. BILLEESHA BROWN, MANUEL A. CRUZ, ALGELIS TATIS, The “Individual Defendants”, et al and the “Healthcare Provider Defendants”, Index No. 618243/2023, 2025 NY Slip Op 33374(U), Motion Seq. No. 003, Supreme Court, Nassau County (September 15, 2025) dealt with a motion for summary judgment (MSJ) filed by the insurers.

Case Overview:

This is a declaratory judgment action where the plaintiff, NATIONWIDE GENERAL INSURANCE COMPANY, seeks a determination that it is not obligated to provide first-party automobile insurance coverage, including No Fault benefits and/or uninsured/underinsured ...

00:08:10
October 02, 2025
Guilty of Arson & Fraud on Public

GoFundMe Request Based on Fake Claim of Racial Animus
Post 5199

Posted on October 2, 2025 by Barry Zalma

See the full video at and at

An Attempt to Profit the Public by Setting Fire to his Own Food Truck Fails

Avonte Ahikim Hartsfield burned down his own food truck and falsely reported that he was the victim of arson in October 2021. He then created a GoFundMe campaign titled “Rebuilding After a Series of Hate Crimes,” claiming he was a victim of hate crimes and arson. The campaign raised $102,276 from more than 2,000 donors.

In The People v. Avonte Ahikim Hartsfield, D084114, California Court of Appeals, Fourth District, First Division (September 24, 2025) affirmed the conviction.

FACTS

Investigation and Evidence:

The fire department and police conducted investigations and found that the fire was intentionally set by an open flame. Surveillance footage placed Hartsfield near the scene at the time of the fire. ...

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October 01, 2025
Zalma’s Insurance Fraud Letter – October 1, 2025

ZIFL Volume 29, Issue 19

THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL

Read the full article at https://lnkd.in/gXNZQBRy, sSee the full video at https://lnkd.in/gygJwCG9 and at https://zalma.com/blog.

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/

The Contents of the October 1, 2025 Issue of ZIFL Includes:

Another Anniversary -- October 1, 1979 - 2025 - 

Forty five years ago today I left the world of the employed and became an entrepreneur by opening my own law firm. The law practice was incorporated shortly thereafter as Barry Zalma, Inc. When I opened for business on October 1, 1979, I had no clients and no certainty that I would have any in the future. I had borrowed money from the bank to carry me through the first six months and was concerned about my ...

00:10:35
September 09, 2025
The Dishonest Chiropractor/Physician

How a Need for Profit Led Health Care Providers to Crime
Post 5185
Posted on September 8, 2025 by Barry Zalma

See the full video at https://lnkd.in/gePN7rjm and at https://lnkd.in/gzPwr-9q

This is a Fictionalized True Crime Story of Insurance Fraud from an Expert who explains why Insurance Fraud is a “Heads I Win, Tails You Lose” situation for Insurers.

The Dishonest Chiropractor/Physician

How a Need for Profit Led Health Care Providers to Crime

See the full video at and at

This is a Fictionalized True Crime Story of Insurance Fraud from an Expert who explains why Insurance Fraud is a “Heads I Win, Tails You Lose” situation for Insurers. The story is designed to help to Understand How Insurance Fraud in America is Costing Everyone who Buys Insurance Thousands of Dollars Every year and Why Insurance Fraud is Safer and More Profitable for the ­­­Perpetrators than any Other Crime.

How Elderly Doctors Fund their ...

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September 08, 2025
The Dishonest Chiropractor/Physician

How a Need for Profit Led Health Care Providers to Crime
Post 5185
Posted on September 8, 2025 by Barry Zalma

See the full video at https://lnkd.in/gePN7rjm and at https://lnkd.in/gzPwr-9q

This is a Fictionalized True Crime Story of Insurance Fraud from an Expert who explains why Insurance Fraud is a “Heads I Win, Tails You Lose” situation for Insurers.

The Dishonest Chiropractor/Physician

How a Need for Profit Led Health Care Providers to Crime

See the full video at and at

This is a Fictionalized True Crime Story of Insurance Fraud from an Expert who explains why Insurance Fraud is a “Heads I Win, Tails You Lose” situation for Insurers. The story is designed to help to Understand How Insurance Fraud in America is Costing Everyone who Buys Insurance Thousands of Dollars Every year and Why Insurance Fraud is Safer and More Profitable for the ­­­Perpetrators than any Other Crime.

How Elderly Doctors Fund their ...

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September 03, 2025

Barry Zalma: Insurance Claims Expert Witness
Posted on September 3, 2025 by Barry Zalma
The Need for a Claims Handling Expert to Defend or Prove a Tort of Bad Faith Suit

© 2025 Barry Zalma, Esq., CFE

When I finished my three year enlistment in the US Army as a Special Agent of US Army Intelligence in 1967, I sought employment where I could use the investigative skills I learned in the Army. After some searching I was hired as a claims trainee by the Fireman’s Fund American Insurance Company. For five years, while attending law school at night while working full time as an insurance adjuster I became familiar with every aspect of the commercial insurance industry.

On January 2, 1972 I was admitted to the California Bar. I practiced law, specializing in insurance claims, insurance coverage and defense of claims against people insured and defense of insurance companies sued for breach of contract and breach of the implied covenant of good faith and fair dealing. After 45 years as an active lawyer, I asked that my license to practice law be declared inactive ...

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