THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
Post number 5276
Posted on February 2, 2026 by Barry Zalma
ZIFL – Volume 30, Issue 3
See the video at https://rumble.com/v752e4i-zalmas-insurance-fraud-letter-february-1-2026.html and at https://youtu.be/UmnGuRcLsz8
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 23 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/01/ZIFL-02-01-2025.pdf.
Disappearance of Defendant is Not Evidence of Death
In United States v. Marvin Moy, No. (S3) 22 Cr. 19 (PGG), United States District Court, S.D. New York (January 7, 2026) Defendant Marvin Moy, a medical doctor, was charged in the Southern District of New York with conspiracy to commit healthcare fraud, healthcare fraud, and conspiracy to commit money laundering. The indictment alleged that Moy aided co-conspirators in operating clinics that engaged in insurance fraud.
Read the full article and the 23 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/01/ZIFL-02-01-2025.pdf.
More McClenny Moseley & Associates Issues
This is ZIFL’s forty first installment of the saga of McClenny, Moseley & Associates (MMA) 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.
“For the Final Time”: Federal Court Says MMA Firm Has “NO Rights” to Fees in Eastern District of Louisiana When a federal court says it is speaking “for the final time,” it’s usually worth paying attention.
Read the full article and the 23 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/01/ZIFL-02-01-2025.pdf.
Repeat Offender Imprisoned For False Travel Insurance Claim in UK
Copywritten article available at:
Health Insurance Fraud Convictions
Prison Time For Healthcare Employees In Multimillion Dollar Adult Daycare Fraud Scheme
Dr. Osama Nahas, 70, McAllen, and Isabel Pruneda, 54, Edinburg, were found guilty on March 1, 2024, of conspiracy to commit healthcare fraud, healthcare fraud and conspiracy to violate the Anti-Kickback Statute following a two-week trial. Pruneda was also convicted for aggravated identity theft.
Read the full article and about dozens of convictions at the 23 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/01/ZIFL-02-01-2025.pdf.
NCOIL Updates Anti-Fraud Model, Readopts ‘Storm Chaser’ Consumer Protections Model
According to A.M. Best, the National Council of Insurance Legislators updated its 30-year-old anti-insurance fraud model law and readopted the Storm Chasers Consumer Protection model act, which regulates contractors operating in the wake of a disaster.
The Insurance Fraud model act was updated to expand the definition of fraudulent acts, directly address contractor fraud, close criminal enforcement gaps and improve consumer protections, according to a weekly briefing by the Coalition Against Insurance Fraud.
Read the full article and the 23 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/01/ZIFL-02-01-2025.pdf.
Other Than Health Insurance Fraud Convictions
Kansas Man Sentenced for Insurance and Identity Fraud
Marquez Gails, age 43, pleaded guilty on January 9, 2026, in Sedgwick County District Court to one felony count of fraudulent insurance act and one felony count of identity theft. Gails fraudulently used another individual’s identity to purchase a vehicle and auto insurance for the vehicle.
Read the full article and multiple convictions at the 23 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/01/ZIFL-02-01-2025.pdf.
DOJ Announces That False Claims Act Settlements and Judgments Exceed $6.8B in Fiscal Year 2025
January 16, 2026 : Settlements and judgments under the False Claims Act exceeded $6.8 billion in the fiscal year ending Sept. 30, 2025, Deputy Attorney General Todd Blanche and Assistant Attorney General Brett A. Shumate, head of the Justice Department’s Civil Division, announced today. That amount is the highest in a single year in the history of the False Claims Act. This year, whistleblowers filed 1,297 qui tam lawsuits, the highest number in a single year, and the government opened 401 investigations, including matters announced as Administration policy objectives. Settlements and judgments since 1986, when Congress substantially strengthened the civil False Claims Act, now total more than $85 billion.
Read the full article and the 23 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/01/ZIFL-02-01-2025.pdf.
The Tort of Bad Faith & Fraud
In the 1950s, the California Supreme Court created a tort new to U.S. jurisprudence: the tort of bad faith.
A tort is a civil wrong from which one person can receive damages from another for multiple injuries. The tort of bad faith was created because an insurer failed to treat an insured fairly, and the court felt that the traditional contract damages were insufficient to properly compensate the insured. The court allowed the insured to receive, in addition to the contract damages that the insured was entitled to receive under the contract had the insurer treated the insured fairly, damages for emotional distress and punitive damages to punish the insurer for its wrongful acts. Insureds, lawyers for insureds, regulators, and courts across the United States cheered the action of the California Supreme Court, for providing a fair remedy to abused insureds. Most of the states adopted the tort created by the California Supreme Court either by statute or court decision.
Read the full article and the 23 page issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/01/ZIFL-02-01-2025.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. He also serves as an arbitrator or mediator for insurance related disputes. He practiced law for more than 44 years as an insurance coverage and claims handling lawyer and more than 58 years in the insurance business. He is available at http://www.zalma.com and [email protected].
Go to Zalma’s Insurance Fraud Letter at https://zalma.com/zalmas-insurance-fraud-letter-2/
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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.
Arsonist Tried To Represent Himself, Failed, and Sought Habeas Relief
Post number 5357
Read the full article at https://www.linkedin.com/pulse/he-who-acts-his-own-lawyer-has-idiot-client-barry-zalma-esq-cfe-d4bwc, See the full video at and at and at https://zalma.com/blog.
Karacson’s Arson for Profit Attempt Required Skill & Experience to Succeed
In Steve Ellis Karacson v. David Shaver, Warden, No. 25-1089, United States Court of Appeals, Sixth Circuit (May 20, 2026) Steve Karacson was convicted in Michigan state court of arson and insurance fraud after evidence showed he burned his own insured home. Investigators found multiple points of origin, gasoline odor, and evidence tying him to the scene, including cell-phone location data and a receipt showing he had purchased a gas can and gloves shortly before the fire.
FACTS
Karacson initially had appointed counsel, but his relationships with both appointed attorneys ...
Foolish to Repeatedly Disobey Court Orders
All That Remains For Trial Is Plaintiff’s Damages On Each Of These Claims And Establishing Proximate Causation Of Those Damages.
Post number 5348
See the full video at and at and at https://zalma.com/blog plus 5300 posts.
In Linh Wang v. Esurance Insurance Company, No. C24-0447-JCC, United States District Court, W.D. Washington, Seattle (May 1, 2026) John C. Coughenour, United States District Judge, found that throughout this case, culminating with its briefing on Plaintiff’s renewed motion and that Defendant has subjected Plaintiff to unnecessary motion practice for clearly discoverable information and made dubious representations (including to the Court).
FACTUAL BACKGROUND
This case involves an underinsured/uninsured motorist insurance bad faith claim arising from a 2017 motor vehicle collision. The plaintiff, Linh Wang, alleges that Esurance Insurance ...
The Right to Negotiate with Insurer is Not an Assignment of Claims
Post number 5347
Read the full article at https://www.linkedin.com/pulse/ambiguous-contract-repair-assignment-barry-zalma-esq-cfe-2xppc, see the full video at https://rumble.com/v79is1s-ambiguous-contract-to-repair-not-an-assignment.html and at and at https://zalma.com/blog plus more than 5300 posts.
Nebraska Requires an Actual Assignment to Allow Contractor to Sue Insurer
In Millard Gutter Company, a corporation doing business as Millard Roofing and Gutter v. Farmers Mutual Insurance Company of Nebraska, also known as Farmers Mutual Insurance, also known as Farmers Mutual, No. A-24-818, Court of Appeals of Nebraska (May 5, 2026) Millard sued Farmers as an assignee of Jane Anzalone who had hired Millard Gutter to repair the roof of her home and agreed to allow Millard Gutter to coordinate with her insurer, Farmers Mutual, concerning reimbursement for repairs authorized under her insurance policy.
FACTUAL BACKGROUND
In ...
It is a Crime to Lie to Your Insurer That Accident Happened After Policy Inception
Post number 5386
Posted on July 3, 2026 by Barry Zalma
Conviction for Fraud Affirmed Because Evidence Overwhelming
In State Of Washington v. Saleem Mumin Robinson, No. 87244-3-I, Court of Appeals of Washington, Division 1 (June 29, 2026) Saleem Robinson was involved in an automobile collision on May 18, 2021. The other driver, Mohamed Waggeh, photographed Robinson’s documents and later reported the collision to GEICO, identifying the time as approximately 12:40 p.m.
That same day, at 6:06 p.m., more than five hours after the accident, Robinson purchased Progressive insurance for the vehicle involved in the collision.
The next morning, Robinson called Progressive to report the claim and stated that the accident occurred around 6:15 p.m. Progressive recorded that call without advising Robinson that it was being recorded. Progressive later conducted a special investigative unit investigation the claim because it was submitted shortly ...
Deprive Insurer of the Ability to Properly and Timely Investigate Claim & Recover Nothing
Posted on July 2, 2026 by Barry Zalma
Post number 5385
No Contract Claim No Bad Faith Claim
In South Alexander Development I, LLC v.Markel American Insurance Co., Civil Action No. 23-1436-JWD-SDJ, United States District Court, M.D. Louisiana (June 24, 2026) South Alexander Development I, LLC (SADI) owned and operated a solar farm in Springfield, Louisiana that allegedly sustained significant Hurricane Ida damage.
After SADI submitted a claim, MAIC ultimately paid $1,099,614.02 for undisputed physical damage plus the $210,000 income-loss policy limit. SADI later sued for breach of contract and statutory bad faith, contending MAIC failed to fully investigate and adjust the claim; MAIC sought summary judgment, arguing SADI failed to cooperate and withheld material repair-cost information.
LAW:
Louisiana insurance policies are interpreted as contracts according to their plain meaning, and the insured bears the burden ...
Deprive Insurer of the Ability to Properly and Timely Investigate Claim & Recover Nothing
Posted on July 2, 2026 by Barry Zalma
Post number 5385
No Contract Claim No Bad Faith Claim
In South Alexander Development I, LLC v.Markel American Insurance Co., Civil Action No. 23-1436-JWD-SDJ, United States District Court, M.D. Louisiana (June 24, 2026) South Alexander Development I, LLC (SADI) owned and operated a solar farm in Springfield, Louisiana that allegedly sustained significant Hurricane Ida damage.
After SADI submitted a claim, MAIC ultimately paid $1,099,614.02 for undisputed physical damage plus the $210,000 income-loss policy limit. SADI later sued for breach of contract and statutory bad faith, contending MAIC failed to fully investigate and adjust the claim; MAIC sought summary judgment, arguing SADI failed to cooperate and withheld material repair-cost information.
LAW:
Louisiana insurance policies are interpreted as contracts according to their plain meaning, and the insured bears the burden ...
