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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November 17, 2025
Zalma’s Insurance Fraud Letter November 15, 2025

See full video at https://lnkd.in/gtnsH3SW and at https://lnkd.in/geJ4FseF, and at https://zalma.com/ and at https://lnkd.in/gC2wmzqZ.

ZIFL-Volume 29 Number 22

THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
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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/

Read the full 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/11/ZIFL-11-15-2025-1.pdf

Man Bites Dog Story – Hertz Sues Alleged Fraudsters

Hertz Successfully Refuses to Pay Alleged Fraudulent Health Care Providers

Proactive Victim of Fraud Defeats Health Care Providers

More McClenny Moseley & Associates Issues

This is ZIFL’s thirty eighth 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.

7/18/2025 – MMA Plaintiff Did Nothing to Pursue Case After MMA Was Terminated as Counsel

Read the full 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/11/ZIFL-11-15-2025-1.pdf
Getting Insurance Against Intentional Act is Against Public Policy

It is against the public policy of Missouri and many other states to allow a person to insure against his or her own intentional unlawful conduct.

What is a Loss For Criminal Sentencing?

In United States of America v. Eduardo Ruben Lopez, No. 2:23-cr-00055-CDS-MDC, United States District Court, D. Nevada, (November 5, 2025) dealt with the need for the determination of the “amount of loss”.

Read the full 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/11/ZIFL-11-15-2025-1.pdf
Insurance Fraud and Artificial Intelligence

Cornell University published an article by Amir Hever, Dr. Itai Orr, and UVeye Ltd. called A New Wave of Vehicle Insurance Fraud Fueled by Genrative AI.

19% Of People Think Its Justifiable Not To Disclose Full Truth On Insurance Application

Read the full copy written article at https://www.insurancetimes.co.uk/news/19-of-people-think-its-justifiable-not-to-disclose-full-truth-on-insurance-application/1456839.article?utm_id=33629&adredir=1 about reports from Ageas UK and YouGov.

Read the full 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/11/ZIFL-11-15-2025-1.pdf

Rescission: The Equitable Remedy

Since the first insurance policy was scratched on a clay tablet and, in modern times, at least since the Eighteenth Century, insurance has been considered a business of the utmost good faith.

Health Insurance Fraud Convictions

Because of the Government’s Shut Down the DOJ is not Publishing its Press Releases About Convictions

Affiliated Pharmacies To Pay More Than $150,000 For False Claims Act Allegations

Read the full 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/11/ZIFL-11-15-2025-1.pdf
Some Fraud Convictions from Grok

October 2025 Florida (Miami)

Juan Carlos Lopez, Led a ring staging over 100 fake car crashes, defrauding auto insurers of $2.5 million., 8 years prison, $1.8 million restitution.

Read the full 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/11/ZIFL-11-15-2025-1.pdf

Right to Amend Pleading Avoids Statutory Immunity

Insurer Immune from Suit for Good Faith Report to Louisiana Department of Insurance of Suspected Fraud

Use of Runners or Cappers

Use of “runners” or “cappers” by a lawyer who pays non-lawyers to bring clients is criminal in most states.

Read the full 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/11/ZIFL-11-15-2025-1.pdf

Convictions of Other Than Health Insurance Fraud

Washington Woman’s Fraud Conviction Saves Workers’ Compensation System Much

Lemapu Dorothy Seinafo, 56, pleaded guilty to one count of third-degree theft and was ordered to repay nearly $48,000 of the pension payments.

Fraud & the Bard of Avon

On a rare occasion, a court will fall prey to a need to be poetic. It happened in California when the Court of Appeal started off its insurance coverage opinion with: “O thou invisible spirit of wine, if thou hast no name to be known by, let us call thee devil!” (Shakespeare, Othello, act II, scene 3.)

Read the full 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/11/ZIFL-11-15-2025-1.pdf

Insurance Fraud & the Lawyer

In a criminal case in California an attorney I worked with both as an adjuster and later as a defense lawyer.

WHAT A FRAUD TRAINED ADJUSTER MUST UNDERSTAND

To turn a claims person into a fraud trained adjuster, the adjuster must become familiar with all .:

Read the full 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2025/11/ZIFL-11-15-2025-1.pdf

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.

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Videos
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September 18, 2026
Expert May Only Testify to What Experience Supports

Insurance Expert May Not Testify to Speculative and Contains Unsupported Conclusions.

Posted on September 18, 2026 by Barry Zalma

See the full video at and at https://rumble.com/v7fmifw-expert-may-only-testify-to-what-experience-supports.html

In Michele A. Over, and The Estate Of Paul R. Over v. State Farm Mutual Automobile Insurance Company, and State Farm Fire And Casualty Company, Civil Action No. 23-cv-02243-PAB-STV, United States District Court, D. Colorado (September 14, 2026) Michele and Paul Over sued State Farm Fire and State Farm Auto over hail-damage and stolen-vehicle claims.

The operative dispute concerned State Farm Auto’s motion to exclude or limit opinions from plaintiffs’ insurance-industry expert, Aaron Castillo. Castillo.

Law

The proponent of expert testimony must establish by a preponderance of the evidence that an expert is qualified and that the opinions are helpful, sufficiently grounded, and reliably derived and applied. Experience-based opinions must explain how the...

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September 17, 2026
Convicted on 29 Tax-Refund-Fraud Counts

150 Months in Prison for Tax Fraud
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Posted on September 17, 2026 by Barry Zalma

See the full video at https://lnkd.in/g8rh3JBX and https://lnkd.in/gmkdy-9C, In United States Of America v. Thomas Addaquay, Nos. 25-10609, 25-10611, United States Court of Appeals, Eleventh Circuit (September 9, 2026) the Eleventh Circuit affirmed all challenged convictions, the 150-month aggregate sentence, and the challenged $4,123,474.55 restitution award.

FACTS

In United States Of America v. Thomas Addaquay, United States Of America v. Thomas Addaquay, Nos. 25-10609, 25-10611, United States Court of Appeals, Eleventh Circuit (September 9, 2026) the Eleventh Circuit affirmed all challenged convictions, the 150-month aggregate sentence, and the challenged $4,123,474.55 restitution award.
FACTS

Thomas Addaquay controlled United Consolidated Accounting and Business Services (UC), nominally a check-cashing business.

The government proved a three-stage tax-refund scheme that converted the resulting refund checks into usable funds through ...

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September 14, 2026
Court Enforces Fifth Amendment & Refuses to Compel Answers

Major Fraud Perpetrator Asserts Fifth Amendment Privilege to Avoid Prosecution

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Posted on September 14, 2026 by Barry Zalma

Fraudster Refuses to Answer Questions About His Alleged Fraud

See the full video at https://lnkd.in/gvicAMDr and at https://lnkd.in/gvicAMDr

In Great American Insurance Co. v. Gemstone Property Management, LLC, et al., No. 23-cv-9100 (LJL), United States District Court, S.D. New York (September 8, 2026) Great American Insurance Company alleged that it was defrauded through a scheme in which Subin Associates, LLP recruited individuals to stage construction-site injuries, arranged unnecessary medical treatment and litigation funding, and pursued fraudulent personal-injury claims.

Luis Manuel Garcia Salcedo, resulted in a $6 million settlement. Non-party Jose Hernandez allegedly worked as an assistant manager at Subin, operated Hernandez Associates, and owned litigation-funding companies that shared office space with Subin and provided services to its clients.

After Great American ...

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November 13, 2026
Habeas Relief Requires Cognizable Responses to State Defenses

Claims of Res Judicata and Procedural Default Defeats Habeas

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Posted on November 13, 2026 by Barry Zalma

A Health Insurance Fraud Conviction Rested On Knowingly Submitting Materially False Or Misleading Claim Information With Specific Intent To Defraud.

A Health Insurance Fraud Conviction Rested On Knowingly Submitting Materially False Or Misleading Claim Information With Specific Intent To Defraud.

In Tariq Mustafa Abdulaziz v. Commissioner Of Correction, No. CV 26-5002432-S, Superior Court of Connecticut, Judicial District of Tolland, Habeas Docket (October 29, 2026) Tariq Mustafa Abdulaziz submitted 114 claims for in-home, face-to-face services purportedly provided to thirty program participants during four one-week periods. The department paid Neurostrategies, Inc., $13,650.

FACTS

The defendant waived his right to a jury trial and elected a trial to the court, D'Addabbo, J. Trial occurred over the course of eight days in August, 2022. The state presented testimony from ten witnesses and introduced thirty-three exhibits into ...

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November 12, 2026
Common Interest Doctrine Protects Confidentiality

Theft of Confidential Information

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Posted on November 12, 2026 by Barry Zalma

In People Center, Inc. v. Deel, Inc., et al., No. 25-cv-02576-CRB (LJC), United States District Court, N.D. California (November 7, 2026) People Center, doing business as Rippling, and Deel compete in payroll and human-resource management software. Rippling alleges that Deel and its executives recruited Rippling employee Keith O’Brien, based in Ireland, to disclose confidential information and trade secrets.
THE IRISH SUIT

Rippling sued O’Brien in Ireland and Deel in the United States. O’Brien subsequently retained separate counsel, supplied an affidavit describing the alleged espionage, and entered into a Cooperation Agreement with Rippling. In exchange for his cooperation, Rippling agreed to provide financial assistance, indemnification, and conditional dismissal of the Irish proceedings. The agreement also permitted renewed proceedings or a monetary judgment upon a material breach.

The Irish proceedings against O’Brien were dismissed...

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November 11, 2026
After Dismissal Fraud Victim May Amend Complaint After Dismissal

A Proposed Amended Complaint That Includes New Factual Allegations to Remedy Pleading Deficiencies

Posted on November 11, 2026 by Barry Zalma
After Dismissal Fraud Victim May Amend Complaint After Dismissal
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If A Proposed Amendment Is Not Clearly Futile, Then Denial Of Leave To Amend Is Improper

In John Hancock Life & Health Insurance Company v. Caring Connections LLC, Arthur Feldheim, and Blime a/k/a Vera Feldheim, Civ. No. 25-7574 (MAS)(JBD), United States District Court, D. New Jersey (November 6, 2026) John Hancock sued Caring Connections LLC, Arthur Feldheim, and Blime a/k/a Vera Feldheim on June 5, 2025, asserting thirteen claims, including fraud, breach of contract, and aiding and abetting fraud.

On March 26, 2026, this Court entered an order granting Caring Connections’ motion to dismiss and granting in part and denying in part the Feldheims’ motion to dismiss. The dismissed claims were dismissed without prejudice, and John Hancock timely sought leave to amend.

They also argued that the New ...

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