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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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00:08:27
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In Peter Barbato & North Jersey Public Adjusters Inc. v. Interstate Fire & Casualty Company, et al, No. 25-cv-5312 (JGK), United States District Court, S.D. New York (December 15, 2025) the plaintiffs, Peter Barbato and North Jersey Public Adjusters, Inc. (“NJPA”), filed suit against several insurance companies, including Interstate Fire & Casualty Company, Independent Specialty Insurance Company, and certain Underwriters at Lloyd’s of London.

FACTS

NJPA is a New Jersey-based public adjusting firm licensed in New York. The dispute centers on ...

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March 11, 2026
Public Adjusters Attempt to Represent an Insured Subject to APA Clause

Anti-Public Adjuster Clause Is Effective in New York

Post number 5301

Read the full article at https://www.linkedin.com/pulse/public-adjusters-attempt-represent-insured-subject-zalma-esq-cfe-rubfc, see the video at and at and at https://zalma.com/blog plus more than 5300 posts.

Insurers May Contractually Prevent an Insured from Hiring a Public Adjuster

In Peter Barbato & North Jersey Public Adjusters Inc. v. Interstate Fire & Casualty Company, et al, No. 25-cv-5312 (JGK), United States District Court, S.D. New York (December 15, 2025) the plaintiffs, Peter Barbato and North Jersey Public Adjusters, Inc. (“NJPA”), filed suit against several insurance companies, including Interstate Fire & Casualty Company, Independent Specialty Insurance Company, and certain Underwriters at Lloyd’s of London.

FACTS

NJPA is a New Jersey-based public adjusting firm licensed in New York. The dispute centers on ...

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March 10, 2026
Acting as Your Own Lawyer is Foolish

Proof of Highly Contaminated Water is Required for Extra Payments

Post number 5300

Read the full article at https://www.linkedin.com/pulse/acting-your-own-lawyer-foolish-barry-zalma-esq-cfe-mbg0c, see the video at and at and at https://zalma.com/blog plus more than 5300 posts.

Acting as Your Own Lawyer is Foolish

Evidence of Breach of Contract Survives Dismissal of All Other Charges

In Lee Lifeng Hsu and Jane Yuchen Hsu v. State Farm Fire And Casualty Company, C. A. No. N24C-09-020 CLS, Superior Court of Delaware (February 27, 2026) a claim to State Farm who paid approximately $61,000 after assessments but denied coverage for additional items including ceramic tiles, the kitchen floor ceiling, underlayment plywood, and numerous personal property items resulted in suit by the Hsu’s acting in pro per.
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Insurance Condition Requires Following the Intent of the Parties

Post number 5307

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In Eastside Floor Supplies, Ltd. v. SCS Agency, Inc., Hanover Insurance Company, et al., No. 2024-01501, Index No. 609883/19, 2026 NY Slip Op 01488, Supreme Court of New York, Second Department (March 18, 2026)

In May 2019, a fire damaged business personal property belonging to the plaintiffs, which was stored in portable storage containers at their Manhattan premises. At the time of the fire, the plaintiffs were insured under a businessowners insurance policy (BOP) issued by the defendant Hanover Insurance Company which provided general coverage for business personal property, and which included a specific extension for “Business Personal Property Temporarily in Portable Storage Units” (the portable storage ...

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Failure to Provide Well-Pled Facts Defeats Most of Action

ERISA Saves Fraudulent Claims Suit

Post number 5306

Read the full article at https://www.linkedin.com/pulse/failure-provide-well-pled-facts-defeats-most-action-zalma-esq-cfe-b4zuc and at https://zalma.com/blog plus more than 5300 posts.

Allegations of Fraudulent Insurance Billing Must be Pleaded with Specificity

In Genesis Laboratory Management LLC v. United Healthcare Services, Inc. and Oxford Health Plans, Inc., No. 21cv12057 (EP) (JSA), United States District Court, D. New Jersey (March 13, 2026) Genesis Laboratory Management LLC (“Genesis”), a New Jersey-based molecular diagnostic and anatomic pathology laboratory, provided COVID-19 related testing services and submitted claims for reimbursement as an out-of-network provider to United Healthcare Services, Inc. (“United”) and Oxford Health Insurance, Inc. (“Oxford”). Metropolitan Healthcare Billing, LLC (“Metropolitan”), owned by the same individual as Genesis, handled the billing for Genesis.

FACTUAL BACKGROUND

United and Oxford, who administer both ERISA and ...

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March 19, 2026
Failure to Provide Well-Pled Facts Defeats Most of Action

ERISA Saves Fraudulent Claims Suit

Post number 5306

Read the full article at https://www.linkedin.com/pulse/failure-provide-well-pled-facts-defeats-most-action-zalma-esq-cfe-b4zuc and at https://zalma.com/blog plus more than 5300 posts.

Allegations of Fraudulent Insurance Billing Must be Pleaded with Specificity

In Genesis Laboratory Management LLC v. United Healthcare Services, Inc. and Oxford Health Plans, Inc., No. 21cv12057 (EP) (JSA), United States District Court, D. New Jersey (March 13, 2026) Genesis Laboratory Management LLC (“Genesis”), a New Jersey-based molecular diagnostic and anatomic pathology laboratory, provided COVID-19 related testing services and submitted claims for reimbursement as an out-of-network provider to United Healthcare Services, Inc. (“United”) and Oxford Health Insurance, Inc. (“Oxford”). Metropolitan Healthcare Billing, LLC (“Metropolitan”), owned by the same individual as Genesis, handled the billing for Genesis.

FACTUAL BACKGROUND

United and Oxford, who administer both ERISA and ...

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