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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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7 hours ago
Zalma’s Insurance Fraud Letter – January 15, 2026

ZIFL Volume 30, Number 2

THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL

Post number 5260

Read the full article at https://lnkd.in/gzCr4jkF, see the video at https://lnkd.in/g432fs3q and at https://lnkd.in/gcNuT84h, https://zalma.com/blog, and at https://lnkd.in/gKVa6r9B.

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 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/ This issue contains the following articles about insurance fraud:

Read the full 19 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/01/ZIFL-01-15-2026.pdf.

The Contents of the January 15, 2026 Issue of ZIFL Includes:

Use of the Examination Under Oath to Defeat Fraud

The insurance Examination Under Oath (“EUO”) is a condition precedent to indemnity under a first party property insurance policy that allows an insurer ...

00:09:20
January 14, 2026
USDC Must Follow the Finding of the Administrator of the ERISA Plan

ERISA Life Policy Requires Active Employment to Order Increase in Benefits

Post 5259

Read the full article at https://lnkd.in/gXJqus8t, see the full video at https://lnkd.in/g7qT3y_y and at https://lnkd.in/gUduPkn4, and at https://zalma.com/blog plus more than 5250 posts.

In Katherine Crow Albert Guidry, Individually And On Behalf Of The Estate Of Jason Paul Guidry v. Metropolitan Life Insurance Company, et al, Civil Action No. 25-18-SDD-RLB, United States District Court, M.D. Louisiana (January 7, 2026) Guidry brought suit to recover life insurance proceeds she alleges were wrongfully withheld following her husband’s death on January 9, 2024.

FACTUAL BACKGROUND

Jason Guidry was employed by Waste Management, which provided life insurance coverage through Metropolitan Life Insurance Company (“MetLife”). Plaintiff contends that after Jason’s death, the defendants (MetLife, Waste Management, and Life Insurance Company of North America (“LINA”)) engaged in conduct intended to confuse and ultimately deny her entitlement to...

00:07:30
January 13, 2026
Mediation in State Court Resolves Action in USDC

Failure to Respond to Motion to Dismiss is Agreement to the Motion
Post 5259

Read the full article at https://lnkd.in/gP52fU5s, see the video at https://lnkd.in/gR8HMUpp and at https://lnkd.in/gh7dNA99, and at https://zalma.com/blog plus more than 5250 posts.

In Mercury Casualty Company v. Haiyan Xu, et al., No. 2:23-CV-2082 JCM (EJY), United States District Court, D. Nevada (January 6, 2026) Plaintiff Mercury Casualty Company (“plaintiff”) moved to dismiss. Defendant Haiyan Xu and Victoria Harbor Investments, LLC (collectively, “defendants”) did not respond.

This case revolves around an insurance coverage dispute when the parties could not be privately resolved, litigation was initiated in the Eighth Judicial District Court of Nevada. Plaintiff subsequently filed for a declaratory judgment in this court.

On or about April 15, 2025, the state court action was dismissed with prejudice pursuant to a stipulation following mediation. Plaintiff states that the state court dismissal renders its ...

00:04:26
December 31, 2025
“Sudden” is the Opposite of “Gradual”

Court Must Follow Judicial Precedent
Post 5252

Read the full article at https://www.linkedin.com/pulse/sudden-opposite-gradual-barry-zalma-esq-cfe-h7qmc, see the video at and at and at https://zalma.com/blog plus more than 5250 posts.

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

See the video at and at

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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