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
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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
Anti-Public Adjuster Clause Is Effective in New York
Post number 5301
Read the full article at https://www.linkedin.com/pulse/public-adjusters-attempt-represent-insured-subject-zalma-esq-cfe-rubfc, see the video at and at and at https://zalma.com/blog plus more than 5300 posts.
Insurers May Contractually Prevent an Insured from Hiring a Public Adjuster
In Peter Barbato & North Jersey Public Adjusters Inc. v. Interstate Fire & Casualty Company, et al, No. 25-cv-5312 (JGK), United States District Court, S.D. New York (December 15, 2025) the plaintiffs, Peter Barbato and North Jersey Public Adjusters, Inc. (“NJPA”), filed suit against several insurance companies, including Interstate Fire & Casualty Company, Independent Specialty Insurance Company, and certain Underwriters at Lloyd’s of London.
FACTS
NJPA is a New Jersey-based public adjusting firm licensed in New York. The dispute centers on ...
Anti-Public Adjuster Clause Is Effective in New York
Post number 5301
Read the full article at https://www.linkedin.com/pulse/public-adjusters-attempt-represent-insured-subject-zalma-esq-cfe-rubfc, see the video at and at and at https://zalma.com/blog plus more than 5300 posts.
Insurers May Contractually Prevent an Insured from Hiring a Public Adjuster
In Peter Barbato & North Jersey Public Adjusters Inc. v. Interstate Fire & Casualty Company, et al, No. 25-cv-5312 (JGK), United States District Court, S.D. New York (December 15, 2025) the plaintiffs, Peter Barbato and North Jersey Public Adjusters, Inc. (“NJPA”), filed suit against several insurance companies, including Interstate Fire & Casualty Company, Independent Specialty Insurance Company, and certain Underwriters at Lloyd’s of London.
FACTS
NJPA is a New Jersey-based public adjusting firm licensed in New York. The dispute centers on ...
Proof of Highly Contaminated Water is Required for Extra Payments
Post number 5300
Read the full article at https://www.linkedin.com/pulse/acting-your-own-lawyer-foolish-barry-zalma-esq-cfe-mbg0c, see the video at and at and at https://zalma.com/blog plus more than 5300 posts.
Acting as Your Own Lawyer is Foolish
Evidence of Breach of Contract Survives Dismissal of All Other Charges
In Lee Lifeng Hsu and Jane Yuchen Hsu v. State Farm Fire And Casualty Company, C. A. No. N24C-09-020 CLS, Superior Court of Delaware (February 27, 2026) a claim to State Farm who paid approximately $61,000 after assessments but denied coverage for additional items including ceramic tiles, the kitchen floor ceiling, underlayment plywood, and numerous personal property items resulted in suit by the Hsu’s acting in pro per.
Facts
Lee Lifeng Hsu and Jane Yuchen Hsu (“Plaintiffs”) purchased a homeowners’ insurance policy from State Farm Fire...
Insurance Condition Requires Following the Intent of the Parties
Post number 5307
Principles of Contract Interpretation Compels Reading Contract as Written
Read the full article at https://www.linkedin.com/pulse/portable-storage-containers-buildings-barry-zalma-esq-cfe-fkg1c and at https://zalma.com/blog.
In Eastside Floor Supplies, Ltd. v. SCS Agency, Inc., Hanover Insurance Company, et al., No. 2024-01501, Index No. 609883/19, 2026 NY Slip Op 01488, Supreme Court of New York, Second Department (March 18, 2026)
In May 2019, a fire damaged business personal property belonging to the plaintiffs, which was stored in portable storage containers at their Manhattan premises. At the time of the fire, the plaintiffs were insured under a businessowners insurance policy (BOP) issued by the defendant Hanover Insurance Company which provided general coverage for business personal property, and which included a specific extension for “Business Personal Property Temporarily in Portable Storage Units” (the portable storage ...
ERISA Saves Fraudulent Claims Suit
Post number 5306
Read the full article at https://www.linkedin.com/pulse/failure-provide-well-pled-facts-defeats-most-action-zalma-esq-cfe-b4zuc and at https://zalma.com/blog plus more than 5300 posts.
Allegations of Fraudulent Insurance Billing Must be Pleaded with Specificity
In Genesis Laboratory Management LLC v. United Healthcare Services, Inc. and Oxford Health Plans, Inc., No. 21cv12057 (EP) (JSA), United States District Court, D. New Jersey (March 13, 2026) Genesis Laboratory Management LLC (“Genesis”), a New Jersey-based molecular diagnostic and anatomic pathology laboratory, provided COVID-19 related testing services and submitted claims for reimbursement as an out-of-network provider to United Healthcare Services, Inc. (“United”) and Oxford Health Insurance, Inc. (“Oxford”). Metropolitan Healthcare Billing, LLC (“Metropolitan”), owned by the same individual as Genesis, handled the billing for Genesis.
FACTUAL BACKGROUND
United and Oxford, who administer both ERISA and ...
ERISA Saves Fraudulent Claims Suit
Post number 5306
Read the full article at https://www.linkedin.com/pulse/failure-provide-well-pled-facts-defeats-most-action-zalma-esq-cfe-b4zuc and at https://zalma.com/blog plus more than 5300 posts.
Allegations of Fraudulent Insurance Billing Must be Pleaded with Specificity
In Genesis Laboratory Management LLC v. United Healthcare Services, Inc. and Oxford Health Plans, Inc., No. 21cv12057 (EP) (JSA), United States District Court, D. New Jersey (March 13, 2026) Genesis Laboratory Management LLC (“Genesis”), a New Jersey-based molecular diagnostic and anatomic pathology laboratory, provided COVID-19 related testing services and submitted claims for reimbursement as an out-of-network provider to United Healthcare Services, Inc. (“United”) and Oxford Health Insurance, Inc. (“Oxford”). Metropolitan Healthcare Billing, LLC (“Metropolitan”), owned by the same individual as Genesis, handled the billing for Genesis.
FACTUAL BACKGROUND
United and Oxford, who administer both ERISA and ...
