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December 30, 2025
Montana Lawyer Commits Insurance Fraud and Receives Minimal Punishment

Montana County Attorney Admits to Insurance Fraud & Is Only Suspended from Practice for 60 Days
Post 5251

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A Lawyer Who Commits Insurance Fraud and Pleas to a Lower Charge Only Suspended

In The Matter Of: Naomi R. Leisz, Attorney at Law, No. PR 25-0150, Supreme Court of Montana (December 23, 2025) the Montana Office of Disciplinary Counsel (ODC) filed a formal disciplinary complaint with the Commission on Practice (Commission) against Montana attorney Naomi R. Leisz.

On September 25, 2025, Leisz tendered a conditional admission and affidavit of consent. Leisz acknowledged the material facts of the complaint were true and she had violated the Montana Rules of Professional Conduct as alleged by ODC.

ADMISSIONS

Leisz admitted that in April 2022, her minor son was involved in a car accident in which he hit a power pole. Leisz’s son failed to report the accident. Leisz later filed an insurance claim in which she falsely claimed she was the driver of the vehicle at the time of the collision. Leisz’s insurance company paid the claim. Leisz noted her son was insured under the policy and she assumed the insurer agrees the accident would have been covered by it.

Leisz later learned she was going to face criminal charges from the incident. On June 30, 2023, she resigned from her position as Sanders County Attorney. Leisz self-reported that she was voluntarily going on inactive status with the Montana State Bar, effective July 3, 2023. However, Leisz did not subsequently contact the Montana State Bar and change her status to inactive status. However, she resumed practicing because ODC had not taken action on her self-report by the time her criminal matter concluded.

THE CRIME

Leisz was charged with Criminal Insurance Fraud, a felony, in July 2023. She ultimately pled guilty to Obstructing Justice, a misdemeanor, pursuant to a plea agreement. The Sanders County District Court entered its order sentencing Leisz to six months incarceration in Sanders County Jail, all suspended, plus fines, fees, community service, and restitution to Northern Lights, Inc., in the amount of $3,293.00, for the damage to the power pole.

THE ADMISSION & CONSENT TO DISCIPLINE

In the tendered Conditional Admission and Affidavit of Consent, Leisz admitted she agreed to discipline in the form of: a 60-day suspension from the practice of law; paying the costs of these proceedings; and complying with all notice requirements of the state rules.

In its Findings of Fact, Conclusions of Law, and Recommendation for Discipline, the Commission recommended the Court accept Leisz’s conditional admissions for violating M. R. Pro. Cond. 8.4, and impose discipline in the form of:

1. A 60-day suspension from the practice of law in Montana;
2. Payment of costs incurred by ODC and the Commission in connection with this matter; and
3. Compliance with all notice requirements in MRLDE 29 and 30.

The Commission further considered aggravating factors in this case to be Leisz’s refusal to cooperate with law enforcement, her false insurance claim, and her misstatement to ODC that she was going on inactive status. The Commission found mitigating factors to include Leisz’s sincere remorse, her many years of practice without disciplinary incidents, her voluntary withdrawal from practice, and no monetary harm to a client.

The Montana Supreme Court accepted the Commission’s Recommendation that it accept Leisz’s Rule 26 tendered admission is ACCEPTED AND ADOPTED.

Leisz was SUSPENDED from the practice of law for 60 days, effective 30 days from the date of thE Order of Discipline.

Leisz shall pay the costs of these proceedings and Leisz shall comply with all notice requirements of the rules.

ZALMA OPINION

Ms. Leisz saved her career as a lawyer my admitting her criminal conduct, agreeing to conviction for obstruction of justice to avoid trial and conviction for felony insurance fraud and being disbarred from the practice of law by stating remorse which convinced the Commission created to disciple felonious attorneys who recommended easy to survive punishment which was accepted by the Supreme Court. I’m old fashioned and can find no excuse for a lawyer committing insurance fraud and would have recommended a more severe punishment to the Supreme Court if I were on the Commission.

(c) 2025 Barry Zalma & ClaimSchool, Inc.

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January 16, 2026
Just Because the Defendant Defaults the Court Still has Discretion

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 ...

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January 15, 2026
Zalma’s Insurance Fraud Letter – January 15, 2026

ZIFL Volume 30, Number 2

THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL

Post number 5260

Read the full article at https://lnkd.in/gzCr4jkF, see the video at https://lnkd.in/g432fs3q and at https://lnkd.in/gcNuT84h, https://zalma.com/blog, and at https://lnkd.in/gKVa6r9B.

Zalma’s Insurance Fraud Letter (ZIFL) continues its 30th 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/ This issue contains the following articles about insurance fraud:

Read the full 19 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/01/ZIFL-01-15-2026.pdf.

The Contents of the January 15, 2026 Issue of ZIFL Includes:

Use of the Examination Under Oath to Defeat Fraud

The insurance Examination Under Oath (“EUO”) is a condition precedent to indemnity under a first party property insurance policy that allows an insurer ...

00:09:20
January 14, 2026
USDC Must Follow the Finding of the Administrator of the ERISA Plan

ERISA Life Policy Requires Active Employment to Order Increase in Benefits

Post 5259

Read the full article at https://lnkd.in/gXJqus8t, see the full video at https://lnkd.in/g7qT3y_y and at https://lnkd.in/gUduPkn4, and at https://zalma.com/blog plus more than 5250 posts.

In Katherine Crow Albert Guidry, Individually And On Behalf Of The Estate Of Jason Paul Guidry v. Metropolitan Life Insurance Company, et al, Civil Action No. 25-18-SDD-RLB, United States District Court, M.D. Louisiana (January 7, 2026) Guidry brought suit to recover life insurance proceeds she alleges were wrongfully withheld following her husband’s death on January 9, 2024.

FACTUAL BACKGROUND

Jason Guidry was employed by Waste Management, which provided life insurance coverage through Metropolitan Life Insurance Company (“MetLife”). Plaintiff contends that after Jason’s death, the defendants (MetLife, Waste Management, and Life Insurance Company of North America (“LINA”)) engaged in conduct intended to confuse and ultimately deny her entitlement to...

00:07:30
December 31, 2025
“Sudden” is the Opposite of “Gradual”

Court Must Follow Judicial Precedent
Post 5252

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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 ...

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December 29, 2025
Doctor Accused of Insurance Fraud Sues Insurer Who Accused Him

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 ...

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December 15, 2025
Zalma’s Insurance Fraud Letter – December 15, 2025

Zalma’s Insurance Fraud Letter

Read the full article at https://lnkd.in/dG829BF6; see the video at https://lnkd.in/dyCggZMZ and at https://lnkd.in/d6a9QdDd.

ZIFL Volume 29, Issue 24

Subscribe to the e-mail Version of ZIFL, it’s Free! https://visitor.r20.constantcontact.com/manage/optin?v=001Gb86hroKqEYVdo-PWnMUkcitKvwMc3HNWiyrn6jw8ERzpnmgU_oNjTrm1U1YGZ7_ay4AZ7_mCLQBKsXokYWFyD_Xo_zMFYUMovVTCgTAs7liC1eR4LsDBrk2zBNDMBPp7Bq0VeAA-SNvk6xgrgl8dNR0BjCMTm_gE7bAycDEHwRXFAoyVjSABkXPPaG2Jb3SEvkeZXRXPDs%3D

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 ...

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