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
Post 5228

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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15 hours ago
ANTI-SLAPP MOTION SUCCEEDS

Convicted Criminal Seeks to Compel Receiver to Protect his Assets

Post number 5291

See the video at and at and at https://www.zalma.com/blog plus more than 5250 posts.

The Work of a Court Appointed Receiver is Constitutionally Protected

In Simon Semaan et al. v. Robert P. Mosier et al., G064385, California Court of Appeals, Fourth District, Third Division (February 6, 2026) the Court of Appeals applied the California anti-SLAPP statute which protects defendants from meritless lawsuits arising from constitutionally protected activities, including those performed in official capacities. The court also considered the doctrine of quasi-judicial immunity, which shields court-appointed receivers from liability for discretionary acts performed within their official duties.

Facts

In September 2021, the State of California filed felony charges against Simon Semaan, alleging violations of Insurance Code section 11760(a) for making...

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February 19, 2026
Who’s On First – an “Other Insurance Clause” Dispute

When There are Two Different Other Insurance Clauses They Eliminate Each Other and Both Insurers Owe Indemnity Equally

Post number 5289

In Great West Casualty Co. v. Nationwide Agribusiness Insurance Co., and Conserv FS, Inc., and Timothy A. Brennan, as Administrator of the Estate of Pat- rick J. Brennan, deceased, Nos. 24-1258, 24-1259, United States Court of Appeals, Seventh Circuit (February 11, 2026) the USCA was required to resolve a dispute that arose when a tractor-trailer operated by Robert D. Fisher (agent of Deerpass Farms Trucking, LLC-II) was involved in a side-impact collision with an SUV driven by Patrick J. Brennan, resulting in Brennan’s death.

Facts

Deerpass Trucking, an interstate motor carrier, leased the tractor from Deerpass Farms Services, LLC, and hauled cargo for Conserv FS, Inc. under a trailer interchange agreement. The tractor was insured by Great West Casualty Company with a $1 million policy limit, while the trailer was insured by Nationwide Agribusiness Insurance Company with a $2 million ...

00:08:46
February 18, 2026
Win Some and Lose Some

Opiod Producer Seeks Indemnity from CGL Insurers

Post number 5288

Read the full article at https://lnkd.in/guNhStN2, see the full video at https://lnkd.in/gYqkk-n3 and at https://lnkd.in/g8U3ehuc, and at https://zalma.com/blog plus more than 5250 posts.

Insurers Exclude Damages Due to Insured’s Products

In Matthew Dundon, As The Trustee Of The Endo General Unsecured Creditors’ Trust v. ACE Property And Casualty Insurance Company, et al., Civil Action No. 24-4221, United States District Court, E.D. Pennsylvania (February 10, 2026) Matthew Dundon, trustee of the Endo General Unsecured Creditors’ Trust, sued multiple commercial general liability (CGL) insurers for coverage of opioid-related litigation involving Endo International PLC a pharmaceutical manufacturer.

KEY FACTS

Beginning as early as 2014, thousands of opioid suits were filed by governments, third parties, and individuals alleging harms tied to opioid manufacturing and marketing.

Bankruptcy & Settlements

Endo filed Chapter 11 in August 2022; before bankruptcy it ...

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February 19, 2026

Passover for Americans
Posted on February 19, 2026 by Barry Zalma
“The Passover Seder For Americans”

For more than 3,000 years Jewish fathers have told the story of the Exodus of the enslaved Jews from Egypt. Telling the story has been required of all Jewish fathers. Americans, who have lived in North America for more than 300 years have become Americans and many have lost the ability to read, write and understand the Hebrew language in which the story of Passover was first told in the Torah. Passover is one of the many holidays Jewish People celebrate to help them remember the importance of G_d in their lives. We see the animals, the oceans, the rivers, the mountains, the rain, sun, the planets, the stars, and the people and wonder how did all these wonderful things come into being. Jews believe the force we call G_d created the entire universe and everything in it. Jews feel G_d is all seeing and knowing and although we can’t see Him, He is everywhere and in everyone.We understand...

February 19, 2026

Passover for Americans

Posted on February 19, 2026 by Barry Zalma

Read the full article at https://www.linkedin.com/pulse/passover-americans-barry-zalma-esq-cfe-5vgkc.

Available at https://www.amazon.com/Passover-Seder-American-Family-Zalma-ebook/dp/B0848NFWZP/ref=tmm_kin_swatch_0?_encoding=UTF8&qid=1584364029&sr=8-4

“The Passover Seder For Americans”

For more than 3,000 years Jewish fathers have told the story of the Exodus of the enslaved Jews from Egypt. Telling the story has been required of all Jewish fathers. Americans, who have lived in North America for more than 300 years have become Americans and many have lostthe ability to read, write and understand the Hebrew language in which the story of Passover was first told in the Torah.

Passover is one of the many holidays Jewish People celebrate to help them remember the importance of G_d in their lives. We see the animals, the oceans, the rivers, the mountains, the rain, sun, the planets, the stars, and the people and ...

January 30, 2026
Anti-Concurrent Cause Exclusion Effective

You Get What You Pay For – Less Coverage Means Lower Premium

Post number 5275

Posted on January 30, 2026 by Barry Zalma

See the video at and at

When Experts for Both Sides Agree That Two Causes Concur to Cause a Wall to Collapse Exclusion Applies

In Lido Hospitality, Inc. v. AIX Specialty Insurance Company, No. 1-24-1465, 2026 IL App (1st) 241465-U, Court of Appeals of Illinois (January 27, 2026) resolved the effect of an anti-concurrent cause exclusion to a loss with more than one cause.

Facts and Background

Lido Hospitality, Inc. operates the Lido Motel in Franklin Park, Illinois. In November 2020, a windstorm caused one of the motel’s brick veneer walls to collapse. At the time, Lido was insured under a policy issued by AIX Specialty Insurance Company which provided coverage for windstorm damage. However, the policy contained an exclusion for any loss or damage directly or indirectly resulting from ...

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