Arsonist Incompetently Moves Pro Se to Avoid Prison
Post 5239
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In Christopher A. Barosh v. Morris Houser, et al., Civ. No. 22-0769, United States District Court, E.D. Pennsylvania (November 25, 2025) a convicted arsonist and insurance fraudster moved the USDC acting in Pro se filed Objections to Magistrate Judge Reid’s Recommendation that the US District Judge dismiss his § 2254 Petition to avoid jail.
BACKGROUND
In October 2005, Barosh set fire to his girlfriend’s Philadelphia home — some 25 hours before the cancellation of the property’s insurance policy. Several witnesses saw Barosh leaving the property shortly before the fire erupted. After the fire, Barosh made “two separate admissions of guilt.”
He attempted to pay an acquaintance to provide him with an alibi for the time of the arson. The eyewitnesses, brother, and acquaintance all testified at trial.
In December 2012, a Philadelphia jury convicted Barosh of arson and insurance fraud. He was sentenced to 9.5 to 22 years’ incarceration.
The Superior Court rejected Barosh’s direct appeal, and the Supreme Court denied allocatur (the right to appeal).
Acting Pro se, Barosh sought Post Conviction Relief Act (PCRA) relief. At some point, Barosh was represented by counsel. Before the PCRA Court issued a decision, Barosh appealed to Superior Court, which dismissed his claims as premature. The PCRA Court then issued a Notice to Dismiss and — after Barosh filed two more premature appeals — formally dismissed his Petition. The Superior Court affirmed, and the Supreme Court again denied allocatur.
in April 2022, this matter was referred to Magistrate Judge Reid for a Report and Recommendation. Respondents oppose relief. Judge Reid recommended that the District Court Judge dismiss Barosh’s Petition because he filed four months after the one-year deadline.
The District Court Judge reviewed de novo those portions of the Report to which Barosh files timely, specific objections and may accept, reject, or modify, in whole or part Magistrate Judge Reid’s findings or recommendations.
OBJECTIONS
Barosh argued that Judge Reid should have ruled that the AEDPA limitations clock was equitably tolled. However, the limitations clock is tolled only if Barosh has shown: (1) that he has been pursuing his rights diligently, and (2) that some extraordinary circumstance stood in his way and prevented timely filing.
Actual Innocence
Barosh argued, in the alternative, that Judge Reid should have excused his untimely filing because the actual innocence exception applies. An actual innocence claim requires a petitioner to support his allegations of constitutional error with new reliable evidence — whether it be exculpatory scientific evidence, trustworthy eyewitness accounts, or critical physical evidence — that was not presented at trial. Barosh offered no new evidence.
The District Court on the 24th day of November, 2025, upon consideration of Magistrate Judge Reid’s Report and Recommendation Petitioner’s Objections and Respondent’s Response it was ORDERED that:
1 Petitioner’s Objections to the Report and Recommendation are OVERRULED;
2 Magistrate Judge Reid’s Report and Recommendation is APPROVED and ADOPTED;
3 Petitioner’s claims are DISMISSED;
4 A certificate of appealability will not issue; and
5 The Clerk of Court shall mark this case CLOSED.
ZALMA OPINION
I never are surprised that people who are convicted of the most dangerous and violent form of insurance fraud – Arson for Profit – have the chutzpah (unmitigated gall) to continue to move the courts for freedom or reduction of sentence without facts or law supporting their claims. The court did not fall for the attempt, let the Magistrate Judge do the work and then refused the application for relief. He stays in jail as he should.
(c) 2025 Barry Zalma & ClaimSchool, Inc.
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Fraudster Tries to Reduce His Sentence by Continuing His Fraud
Post number 5267
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In Spite of Defendants Claims He Will Spend Serious Time in Prison
In United States Of America v. Henry Ford, Criminal Action No. 23-130, United States District Court, E.D. Pennsylvania (January 5, 2026) Henry Ford (no relation to the creator of the Model T), also known as “Cleothus Lefty Jackson,” was indicted and pled guilty to one count of securities fraud and aiding and abetting, along with seven counts of wire fraud.
FACTUAL BACKGROUND
Defendant falsely represented to victims that a business he controlled, Fallcatcher, had “pilot approvals in writing” with two large insurance companies and that several states “want the [Fallcatcher] technology” [Count Five]. In reality, Fallcatcher did not have any pilot programs with insurance companies and the ...
Fraudster Tries to Reduce His Sentence by Continuing His Fraud
Post number 5267
Read the full article at https://lnkd.in/gn6SUUqV, see the video at https://lnkd.in/g4PiYrAp and at https://lnkd.in/giHCPFAw, and at https://zalma.com/blog plus more than 5250 posts.
In Spite of Defendants Claims He Will Spend Serious Time in Prison
In United States Of America v. Henry Ford, Criminal Action No. 23-130, United States District Court, E.D. Pennsylvania (January 5, 2026) Henry Ford (no relation to the creator of the Model T), also known as “Cleothus Lefty Jackson,” was indicted and pled guilty to one count of securities fraud and aiding and abetting, along with seven counts of wire fraud.
FACTUAL BACKGROUND
Defendant falsely represented to victims that a business he controlled, Fallcatcher, had “pilot approvals in writing” with two large insurance companies and that several states “want the [Fallcatcher] technology” [Count Five]. In reality, Fallcatcher did not have any pilot programs with insurance companies and the ...
Even With a Default the Plaintiff Needs Evidence
Post number 5262
Read the full article at https://www.linkedin.com/pulse/just-because-defendant-defaults-court-still-has-zalma-esq-cfe-f9k2c, ee the video at and at and at https://zalma.com/blog plus more than 5250 posts.
In Chesapeake Employers’ Insurance Company v. SCD Premier Staffing Agency, LLC, et al., No. 1840-2024, Court of Special Appeals of Maryland (January 6, 2026) dealt with a complaint in the Circuit Court for Worcester County against SCD Premier Staffing Agency, LLC (“SCD”) and its owner, Suze Cadet, alleging fraud, intentional misrepresentation, negligent misrepresentation, and breach of contract, and seeking both compensatory and punitive damages.
FACTUAL BACKGROUND
SCD is or was a Maryland limited liability company owned by Cadet, and CEIC provides workers’ compensation insurance to Maryland employers.
In ...
Court Must Follow Judicial Precedent
Post 5252
Read the full article at https://www.linkedin.com/pulse/sudden-opposite-gradual-barry-zalma-esq-cfe-h7qmc, see the video at and at and at https://zalma.com/blog plus more than 5250 posts.
Insurance Policy Interpretation Requires Application of the Judicial Construction Doctrine
In Montrose Chemical Corporation Of California v. The Superior Court Of Los Angeles County, Canadian Universal Insurance Company, Inc., et al., B335073, Court of Appeal, 337 Cal.Rptr.3d 222 (9/30/2025) the Court of Appeal refused to allow extrinsic evidence to interpret the word “sudden” in qualified pollution exclusions (QPEs) as including gradual but unexpected pollution. The court held that, under controlling California appellate precedent, the term “sudden” in these standard-form exclusions unambiguously includes a temporal element (abruptness) and cannot reasonably be construed to mean ...
Lack of Jurisdiction Defeats Suit for Defamation
Post 5250
Posted on December 29, 2025 by Barry Zalma
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He Who Represents Himself in a Lawsuit has a Fool for a Client
In Pankaj Merchia v. United Healthcare Services, Inc., Civil Action No. 24-2700 (RC), United States District Court, District of Columbia (December 22, 2025)
FACTUAL BACKGROUND
Parties & Claims:
The plaintiff, Pankaj Merchia, is a physician, scientist, engineer, and entrepreneur, proceeding pro se. Merchia sued United Healthcare Services, Inc., a Minnesota-based medical insurance company, for defamation and related claims. The core allegation is that United Healthcare falsely accused Merchia of healthcare fraud, which led to his indictment and arrest in Massachusetts, causing reputational and business harm in the District of Columbia and nationwide.
Underlying Events:
The alleged defamation occurred when United ...
Zalma’s Insurance Fraud Letter
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ZIFL Volume 29, Issue 24
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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/
Zalma’s Insurance Fraud Letter
Merry Christmas & Happy Hannukah
Read the following Articles from the December 15, 2025 issue:
Read the full 19 page issue of ZIFL at ...
