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.
When Harm is Inherent in the Nature of the Act it is Intentional
Post 5237
See the video at and at and at https://zalma.com/blog plus more than 5200 posts.
No Coverage for Intentional Acts
Hitting a Person in the Face is an Intentional Act
In Unitrin Auto and Home Insurance Company v. Brian C. Sullivan, et al., George A. Ciminello, No. 2022-01607, Index No. 21632/14, Supreme Court of New York, Second Department (November 19, 2025) George A. Ciminello was injured when struck in the face by a cup filled with liquid, thrown from a moving vehicle operated by Brian C. Sullivan, with Robert Harford as the passenger who threw the cup. The vehicle approached Ciminello at about 30 mph, from 2 to 10 feet away, and Harford extended his arm to make contact. The cup splintered upon impact.
Sullivan and Harford later conceded liability on the intentional tort claim before a damages trial.
Insurance Policy:
Unitrin Auto and Home...
Obtaining Title to Church by Fraud Defeated
Post 5238
Read the full article at https://www.linkedin.com/pulse/unmitigated-gall-abuse-elderly-bishop-his-church-zalma-esq-cfe-xcasc, see the video at and at and at https://zalma.com/blog plus more than 5200 posts.
It is Villainous to Steal Church Property from Sick and Elderly Bishop
In Testimonial Cathedral Local Church of God in Christ v. EquityKey Real Estate Option, LLC et al. (Cal. Ct. App., 2d Dist., Div. 8, No. B331522 (Nov. 18, 2025) EquityKey (through broker Steven Sharpe and Frank Wheaton, a trusted advisor/friend of elderly Bishop Jimmy Hackworth) presented a deal supposedly for a $4 million life-insurance policy on Hackworth’s life with EquityKey as beneficiary. In exchange, EquityKey paid Hackworth $400,000 upfront.
Factual Background
To qualify Hackworth for the large policy, church real property on South Western Ave., Los Angeles was temporarily ...
Guilty of Money Laundering Scheme
Post 5238
See the video at https://lnkd.in/gqh7V46x and at https://lnkd.in/gmE-zrDC and at https://zalma.com/blog plus more than 5200 posts.
Prison Sentence for Fraud Must be Limited to the Fraud in Which the Defendant Participated
In United States v. Stephen O. Anagor, No. 2:24-CR-00019-DCLC-CRW (E.D. Tenn., Nov. 26, 2025) by Judge Clifton L. Corker the government sought to increase the defendant’s sentence because his co-conspirators added a fraudulent FBI scam that resulted in the victim’s suicide. Anagor sought a lower sentence because he was only involved in part of the fraud.
Charges & Plea
Defendant, a U.S. Army soldier pled guilty on June 11, 2025 to Conspiracy to Commit Mail and Wire Fraud, Aiding and Abetting Aggravated Stalking Resulting in Death and Aiding and Abetting Aggravated Identity Theft that was part of a larger 38-count superseding indictment against Anagor and co-defendants Chinagorom Onwumere and Salma Abdalkareem for an international Nigerian-based ...
The Professional Claims Handler
Post 5219
Posted on October 31, 2025 by Barry Zalma
An Insurance claims professionals should be a person who:
Can read and understand the insurance policies issued by the insurer.
Understands the promises made by the policy.
Understand their obligation, as an insurer’s claims staff, to fulfill the promises made.
Are competent investigators.
Have empathy and recognize the difference between empathy and sympathy.
Understand medicine relating to traumatic injuries and are sufficiently versed in tort law to deal with lawyers as equals.
Understand how to repair damage to real and personal property and the value of the repairs or the property.
Understand how to negotiate a fair and reasonable settlement with the insured that is fair and reasonable to both the insured and the insurer.
How to Create Claims Professionals
To avoid fraudulent claims, claims of breach of contract, bad faith, punitive damages, unresolved losses, and to make a profit, insurers ...
The History Behind the Creation of a Claims Handling Expert
The Insurance Industry Needs to Implement Excellence in Claims Handling or Fail
Post 5210
This is a change from my normal blog postings. It is my attempt. in more than one post, to explain the need for professional claims representatives who comply with the basic custom and practice of the insurance industry. This statement of my philosophy on claims handling starts with my history as a claims adjuster, insurance defense and coverage lawyer and insurance claims handling expert.
My Training to be an Insurance Claims Adjuster
When I was discharged from the US Army in 1967 I was hired as an insurance adjuster trainee by a professional and well respected insurance company. The insurer took a chance on me because I had been an Army Intelligence Investigator for my three years in the military and could use that training and experience to be a basis to become a professional insurance adjuster.
I was initially sat at a desk reading a text-book on insurance ...
The History Behind the Creation of a Claims Handling Expert
The Insurance Industry Needs to Implement Excellence in Claims Handling or Fail
Post 5210
This is a change from my normal blog postings. It is my attempt. in more than one post, to explain the need for professional claims representatives who comply with the basic custom and practice of the insurance industry. This statement of my philosophy on claims handling starts with my history as a claims adjuster, insurance defense and coverage lawyer and insurance claims handling expert.
My Training to be an Insurance Claims Adjuster
When I was discharged from the US Army in 1967 I was hired as an insurance adjuster trainee by a professional and well respected insurance company. The insurer took a chance on me because I had been an Army Intelligence Investigator for my three years in the military and could use that training and experience to be a basis to become a professional insurance adjuster.
I was initially sat at a desk reading a text-book on insurance ...
