Post 5254
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Help a Person Commit Insurance Fraud & Go to Jail
Guilty of Tampering With Evidence by Hiding it in Garage
In State Of Montana v. Lila Lynn Lord, 2025 MT 302, No. DA 24-0343, Supreme Court of Montana (December 30, 2025) Lila Lord (Lord) appealed her conviction for Tampering with Evidence following a jury trial in the Seventh Judicial District Court, Richland County. The case centered on a staged burglary in Sidney, Montana, orchestrated by Marie Chris Entzel with the intent to collect insurance proceeds to cover her son’s legal fees. Entzel recruited several individuals — including David Skaw, Lawrence Pohl, Laurie McGregor, and the defendant, Lila Lord — to assist in removing valuable items from her home, causing property damage and theft of items such as an enclosed trailer, boat and trailer, refrigerator, pistol, and television.
Entzel’s husband was away and unaware of the plan; upon his return, he reported the incident to police, prompting an investigation. Entzel was charged with insurance fraud and false reports, but not with tampering with evidence. Lord was charged with conspiracy to commit insurance fraud and tampering with evidence for allegedly taking and hiding stolen items at her residence while knowing an official investigation was underway.
FACTUAL BACKGROUND
The State alleged that Entzel, Skaw, Lawrence Pohl (Pohl), Laurie McGregor, and Defendant Lord, among others, were involved in the staged burglary.
The State called Entzel, Skaw, and Officer Norby to testify. Although Entzel and Skaw had both entered guilty pleas before Lord’s trial, neither was compelled to testify as part of their plea agreements. By the time Skaw had returned 1-2 hours later, Lord was done taking apart the refrigerator.
Lord, Skaw, and Entzel loaded the refrigerator’s doors into Lord’s vehicle and the body of the refrigerator into Entzel’s truck. Entzel testified that Lord was fully aware of the insurance fraud scheme.
The jury found Lord not guilty of conspiracy to commit insurance fraud, and guilty of tampering with evidence.
LEGAL ISSUES:
On appeal, Lord challenged her conviction for tampering with evidence, raising several legal questions:
1. whether the District Court erred in denying her proposed accomplice jury instruction;
2. whether the court wrongly denied her request to allow a witness (Pohl) to testify remotely by video; and
3. whether the court erred by denying her motion for a directed verdict based on insufficient corroboration of accomplice testimony.
These issues focus on the fairness of trial procedures and the sufficiency of evidence supporting her conviction.
Did The District Court Err By Denying Defendant’s Request For A Witness To Testify By Video?
Two days before trial, Lord moved the District Court for leave for witness Lawrence Pohl to appear and testify by video, which was denied. Because Lord was ultimately acquitted of the conspiracy to commit insurance fraud charge, she suffered no prejudice from Pohl’s failure to testify.
Did The District Court Err By Denying Defendant’s Directed Verdict Motion Based On Insufficient Corroboration Of An Accomplice’s Testimony?
The Court of Appeals concluded that Entzel and Lord were not accomplices for purposes of an accomplice instruction, given Lord’s innocence defense, and as such, the State was not burdened to corroborate Entzel’s testimony. Based on the court’s review of the record it found there was sufficient evidence to support the District Court’s denial.
Lord admitted when police officers informed Lord that Entzel’s boat had been seen in her garage, Lord replied that she was at least aware a boat had been placed in her garage.
Construing the evidence in a light most favorable to the State, a rational jury could have found from this direct and circumstantial evidence that Lord had concealed or tampered with evidence, that is, Entzel’s property, while knowing that an official proceeding or investigation was about to be instituted.
ZALMA OPINION
It takes a great amount of gall for a person to assist in a criminal act – taking possession of property the defendant knew would be claimed stolen as part of an insurance fraud scheme. Lord was only convicted of taking possession of the property – a refrigerator and a boat – to assist the insurance fraud scheme. To then appeal wanting to make the originator of the crime help her avoid conviction was, as it should be, unsuccessful.
(c) 2025 Barry Zalma & ClaimSchool, Inc.
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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...
150 Months in Prison for Tax Fraud
Post 4846
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 ...
Major Fraud Perpetrator Asserts Fifth Amendment Privilege to Avoid Prosecution
Post 5489
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 ...
Denial Of Mental Health Diversion And Probation Condition Were Affirmed
Posted on October 9, 2026 by Barry Zalma
Post 4860
In The People v. Nicholas Daniel Stiles, A173483, A173646, California Court of Appeals, First District, Second Division (September 29, 2026) Nicholas Daniel Stiles pleaded no contest to one count of insurance fraud arising from his purchase of automobile insurance after a June 2021 collision, and to grand theft arising from an April 2024 incident at a 7-Eleven.
In both cases, the trial court suspended imposition of sentence and placed him on two years’ probation. Before the pleas, Stiles sought mental health diversion in both matters and filed a written motion seeking substitute appointed counsel. The diversion applications were denied, and the court never held a hearing on the motion.
LAW
Penal Code section 1001.36 permits pretrial mental health diversion when a defendant is eligible and suitable and the proposed treatment will meet the defendant’s specialized needs; denial is reviewed for ...
If Grounds For Dismissal Are Apparent From The Face Of The Complaint, A Court May Also Dismiss The Case on The Court’s Own Motion
Posted on October 5, 2026 by Barry Zalma
Pro Se Plaintiff Failed to Make a Short and Plain Statement
Post 4856
In Tak Lun Ng v. United Financial Casualty Company, No. 26-cv-03136-LJC, United States District Court, N.D. California (September 28, 2026) Tak Lun Ng, proceeding pro se, sued United Financial Casualty Company over a March 2, 2021 automobile accident and the insurer’s March 24, 2021 refusal to pay him.
He appeared to assert breach of contract, fraud, negligence, premises liability, product liability, and related theories. United removed the action from state court and moved to dismiss.
Ng missed that deadline but later filed several documents, including a motion for leave to amend, all of which the court reviewed.
LAW
Under Federal Rules of Civil Procedure, a complaint must provide a short and plain statement containing enough factual matter to state a facially plausible...
If Grounds For Dismissal Are Apparent From The Face Of The Complaint, A Court May Also Dismiss The Case on The Court’s Own Motion
Posted on October 5, 2026 by Barry Zalma
Pro Se Plaintiff Failed to Make a Short and Plain Statement
Post 4856
In Tak Lun Ng v. United Financial Casualty Company, No. 26-cv-03136-LJC, United States District Court, N.D. California (September 28, 2026) Tak Lun Ng, proceeding pro se, sued United Financial Casualty Company over a March 2, 2021 automobile accident and the insurer’s March 24, 2021 refusal to pay him.
He appeared to assert breach of contract, fraud, negligence, premises liability, product liability, and related theories. United removed the action from state court and moved to dismiss.
Ng missed that deadline but later filed several documents, including a motion for leave to amend, all of which the court reviewed.
LAW
Under Federal Rules of Civil Procedure, a complaint must provide a short and plain statement containing enough factual matter to state a facially plausible...
