ZIFL – Volume 28, Issue 20
THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
Read the full article at https://lnkd.in/gt5Kyumz, See the full 18 page issue of ZIFL at https://lnkd.in/gBUgEBmP, and at https://zalma.com/blog plus more than 5200 posts.
Zalma’s Insurance Fraud Letter (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 https://lnkd.in/gVT5G9s
The Contents of the October 15, 2025 Issue of ZIFL Includes:
Zalma’s Insurance Fraud Letter (ZIFL) continues its 28th 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 15, 2025 Issue of ZIFL Includes:
Insurer’s Attempt to Obtain Summary Judgment Against Fraudsters Fails
To Prove Fraud Admissible Evidence is Required
Allegations That Health Care Providers Assist in No Fault Fraud Escape MSJ for Lack of Evidence
In Nationwide General Insurance Company, et al v. Billeesha Brown, et al, 2025 NY Slip Op 33374(U), Motion Seq. No. 003, Supreme Court, Nassau County (September 15, 2025).
See the full 18 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/10/ZIFL-10-15-2025.pdf
Guilty of Arson & Fraud on Public
GoFundMe Request Based on Fake Claim of Racial Animus
Avonte Ahikim Hartsfield burned down his own food truck and falsely reported that he was the victim of arson in October 2021.
In The People v. Avonte Ahikim Hartsfield, D084114, California Court of Appeals, Fourth District, First Division (September 24, 2025) affirmed the conviction.
See the full 18 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/10/ZIFL-10-15-2025.pdf
More McClenny Moseley & Associates Issues
This is ZIFL’s thirty seventh 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. The saga of MMA has become a never-ending story.
See the full 18 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/10/ZIFL-10-15-2025.pdf
Ethical Behavior for the Fraud Investigator
The concept of ethical behavior refers to well-founded standards of right and wrong that prescribe what humans ought to do, usually in terms of rights, obligations, benefits to society, fairness, or specific virtues, all of which are essential to the lawyer.
See the full 18 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/10/ZIFL-10-15-2025.pdf
“Post Loss Underwriting” is an Oxymoron
Some plaintiffs’ lawyers contend that rescission is, rather than an equitable remedy of mistake, misrepresentation, concealment or fraud, is really “post loss underwriting.”
See the full 18 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/10/ZIFL-10-15-2025.pdf
Public Policy and Rescission
Rescission, by definition, is an equitable remedy. That means the result when asserting the remedy must be fair to the persons or entities involved.
When a policy is rescinded, it is considered void ab initio and is considered never to have existed. Finding no public policy that forbade rescission the Michigan Supreme Court allowed rescission.
See the full 18 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/10/ZIFL-10-15-2025.pdf
Health Insurance Fraud Convictions
St Mary’s Health Obtains $510,000,000 Verdict Against UHS
Universal Health Services of Delaware, Inc. (UHS) and its affiliates were found liable in a landmark verdict with significant implications for the healthcare industry a Washoe County, Nevada jury awarded Saint Mary’s Health Network over $510 million in damages.
See the full 18 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/10/ZIFL-10-15-2025.pdf
The Interview Is an Essential Form of Fact Gathering for Fraud Investigation
The beginning of a thorough insurance fraud investigation is the interview of the insured and, if a third party claim, the claimant. The interview is often informal. It can be recorded with an audio recording device; it can be recorded with a handwritten statement signed by the witness or it can be recorded by a certified shorthand reporter.
See the full 18 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2025/10/ZIFL-10-15-2025.pdf
Convictions of Other Than Health Insurance Fraud
Public Adjuster, Already in Prison, Sentenced to Another 19 Years Concurrent
Andrew Aga, sometimes known as Andrew Mitchell, a public adjuster who pleaded guilty in March to defrauding Brotherhood Mutual Insurance Co. and a Georgia church out of millions of dollars has been sentenced to 19 years in prison.
Barry Zalma
Barry Zalma, Esq., CFE, now limits his practice to service as an insurance consultant specializing in insurance coverage, insurance claims handling, insurance bad faith and insurance fraud almost equally for insurers and policyholders. Barry Zalma, Inc., 4441 Sepulveda Boulevard, CULVER CITY CA 90230-4847, 310-390-4455. Subscribe to Excellence in Claims Handling at https://barryzalma.substack.com/welcome.
Arsonist Tried To Represent Himself, Failed, and Sought Habeas Relief
Post number 5357
Read the full article at https://www.linkedin.com/pulse/he-who-acts-his-own-lawyer-has-idiot-client-barry-zalma-esq-cfe-d4bwc, See the full video at and at and at https://zalma.com/blog.
Karacson’s Arson for Profit Attempt Required Skill & Experience to Succeed
In Steve Ellis Karacson v. David Shaver, Warden, No. 25-1089, United States Court of Appeals, Sixth Circuit (May 20, 2026) Steve Karacson was convicted in Michigan state court of arson and insurance fraud after evidence showed he burned his own insured home. Investigators found multiple points of origin, gasoline odor, and evidence tying him to the scene, including cell-phone location data and a receipt showing he had purchased a gas can and gloves shortly before the fire.
FACTS
Karacson initially had appointed counsel, but his relationships with both appointed attorneys ...
Foolish to Repeatedly Disobey Court Orders
All That Remains For Trial Is Plaintiff’s Damages On Each Of These Claims And Establishing Proximate Causation Of Those Damages.
Post number 5348
See the full video at and at and at https://zalma.com/blog plus 5300 posts.
In Linh Wang v. Esurance Insurance Company, No. C24-0447-JCC, United States District Court, W.D. Washington, Seattle (May 1, 2026) John C. Coughenour, United States District Judge, found that throughout this case, culminating with its briefing on Plaintiff’s renewed motion and that Defendant has subjected Plaintiff to unnecessary motion practice for clearly discoverable information and made dubious representations (including to the Court).
FACTUAL BACKGROUND
This case involves an underinsured/uninsured motorist insurance bad faith claim arising from a 2017 motor vehicle collision. The plaintiff, Linh Wang, alleges that Esurance Insurance ...
The Right to Negotiate with Insurer is Not an Assignment of Claims
Post number 5347
Read the full article at https://www.linkedin.com/pulse/ambiguous-contract-repair-assignment-barry-zalma-esq-cfe-2xppc, see the full video at https://rumble.com/v79is1s-ambiguous-contract-to-repair-not-an-assignment.html and at and at https://zalma.com/blog plus more than 5300 posts.
Nebraska Requires an Actual Assignment to Allow Contractor to Sue Insurer
In Millard Gutter Company, a corporation doing business as Millard Roofing and Gutter v. Farmers Mutual Insurance Company of Nebraska, also known as Farmers Mutual Insurance, also known as Farmers Mutual, No. A-24-818, Court of Appeals of Nebraska (May 5, 2026) Millard sued Farmers as an assignee of Jane Anzalone who had hired Millard Gutter to repair the roof of her home and agreed to allow Millard Gutter to coordinate with her insurer, Farmers Mutual, concerning reimbursement for repairs authorized under her insurance policy.
FACTUAL BACKGROUND
In ...
It is a Crime to Lie to Your Insurer That Accident Happened After Policy Inception
Post number 5386
Posted on July 3, 2026 by Barry Zalma
Conviction for Fraud Affirmed Because Evidence Overwhelming
In State Of Washington v. Saleem Mumin Robinson, No. 87244-3-I, Court of Appeals of Washington, Division 1 (June 29, 2026) Saleem Robinson was involved in an automobile collision on May 18, 2021. The other driver, Mohamed Waggeh, photographed Robinson’s documents and later reported the collision to GEICO, identifying the time as approximately 12:40 p.m.
That same day, at 6:06 p.m., more than five hours after the accident, Robinson purchased Progressive insurance for the vehicle involved in the collision.
The next morning, Robinson called Progressive to report the claim and stated that the accident occurred around 6:15 p.m. Progressive recorded that call without advising Robinson that it was being recorded. Progressive later conducted a special investigative unit investigation the claim because it was submitted shortly ...
Deprive Insurer of the Ability to Properly and Timely Investigate Claim & Recover Nothing
Posted on July 2, 2026 by Barry Zalma
Post number 5385
No Contract Claim No Bad Faith Claim
In South Alexander Development I, LLC v.Markel American Insurance Co., Civil Action No. 23-1436-JWD-SDJ, United States District Court, M.D. Louisiana (June 24, 2026) South Alexander Development I, LLC (SADI) owned and operated a solar farm in Springfield, Louisiana that allegedly sustained significant Hurricane Ida damage.
After SADI submitted a claim, MAIC ultimately paid $1,099,614.02 for undisputed physical damage plus the $210,000 income-loss policy limit. SADI later sued for breach of contract and statutory bad faith, contending MAIC failed to fully investigate and adjust the claim; MAIC sought summary judgment, arguing SADI failed to cooperate and withheld material repair-cost information.
LAW:
Louisiana insurance policies are interpreted as contracts according to their plain meaning, and the insured bears the burden ...
Deprive Insurer of the Ability to Properly and Timely Investigate Claim & Recover Nothing
Posted on July 2, 2026 by Barry Zalma
Post number 5385
No Contract Claim No Bad Faith Claim
In South Alexander Development I, LLC v.Markel American Insurance Co., Civil Action No. 23-1436-JWD-SDJ, United States District Court, M.D. Louisiana (June 24, 2026) South Alexander Development I, LLC (SADI) owned and operated a solar farm in Springfield, Louisiana that allegedly sustained significant Hurricane Ida damage.
After SADI submitted a claim, MAIC ultimately paid $1,099,614.02 for undisputed physical damage plus the $210,000 income-loss policy limit. SADI later sued for breach of contract and statutory bad faith, contending MAIC failed to fully investigate and adjust the claim; MAIC sought summary judgment, arguing SADI failed to cooperate and withheld material repair-cost information.
LAW:
Louisiana insurance policies are interpreted as contracts according to their plain meaning, and the insured bears the burden ...
