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/
Follow Mr. Zalma on Twitter at https://twitter.com/bzalma. Go to Barry Zalma videos at Rumble.com at https://rumble.com/c/c-262921.
Go to Barry Zalma on YouTube- https://www.youtube.com/channel/UCysiZklEtxZsSF9DfC0Expg, Go to the Insurance Claims Library – https://zalma.com/blog/insurance-claims-library/, https://gettr.com/@zalma
Barry Zalma, Inc., 4441 Sepulveda Boulevard, CULVER CITY CA 90230-4847, 310-390-4455.
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Neither Defense nor Indemnity Available Because of Exclusion
Post number 5293
See the video at and at and at https://zalma.com/blog plus more than 5250 posts.
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Security at Low Income Housing to Risky for Insurer
In Everest Indemnity Insurance Company v. Kates Detective & Security Services Agency, Inc., et al., No. 25 C 5488, United States District Court, N.D. Illinois, Eastern Division (February 18, 2026) dealt with a clear and unambiguous exclusion.
Facts
Everest Indemnity Insurance Company sued Kates Detective & Security Services Agency, Inc. and the Chicago Housing Authority (CHA) seeking a ...
Fraud Perpetrators Have no Honor
Post number 5294
See the video at and at and at https://zalma.com/blog plus more than 5250 posts.
First Circuit Affirms Sentence
In United States Of America v. Chang Goo Yoon, No. 24-1520, United States Court of Appeals, First Circuit (February 20, 2026) Chang Goo Yoon, a licensed physical therapist operating clinics in Massachusetts, engaged in a fraudulent scheme between November 2014 and November 2018. He submitted over a million dollars in false health insurance claims to private insurers, including Blue Cross Blue Shield and Aetna, as well as personal injury claims to MAPFRE, his own car insurer.
Facts
Yoon fabricated treatment notes, billed for services never rendered, and used his office address as patients’ addresses to ensure reimbursement checks were sent directly to him. This arrangement prevented patients from receiving paperwork for services they did not...
Fraud Perpetrators Have no Honor
Post number 5294
See the video at and at and at https://zalma.com/blog plus more than 5250 posts.
First Circuit Affirms Sentence
In United States Of America v. Chang Goo Yoon, No. 24-1520, United States Court of Appeals, First Circuit (February 20, 2026) Chang Goo Yoon, a licensed physical therapist operating clinics in Massachusetts, engaged in a fraudulent scheme between November 2014 and November 2018. He submitted over a million dollars in false health insurance claims to private insurers, including Blue Cross Blue Shield and Aetna, as well as personal injury claims to MAPFRE, his own car insurer.
Facts
Yoon fabricated treatment notes, billed for services never rendered, and used his office address as patients’ addresses to ensure reimbursement checks were sent directly to him. This arrangement prevented patients from receiving paperwork for services they did not...
Contract Breaches that Allow Multiple Different Grounds to Make a Policy Void
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Posted on February 24, 2026 by Barry Zalma
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If an insured breaches one or more material warranties and increases the risk covered by the policy, the contract may be voided by the insurer, depending on the jurisdiction. It is, therefore, essential that every claims investigation include efforts to establish compliance with every warranty.
In Cummings v. Fire Insurance Exchange, 292 Cal. App. 3d 1407, 249 Cal. Rptr. 568 (1988), the Court of Appeal ...
Passover for Americans
Posted on February 19, 2026 by Barry Zalma
“The Passover Seder For Americans”
For more than 3,000 years Jewish fathers have told the story of the Exodus of the enslaved Jews from Egypt. Telling the story has been required of all Jewish fathers. Americans, who have lived in North America for more than 300 years have become Americans and many have lost the ability to read, write and understand the Hebrew language in which the story of Passover was first told in the Torah. Passover is one of the many holidays Jewish People celebrate to help them remember the importance of G_d in their lives. We see the animals, the oceans, the rivers, the mountains, the rain, sun, the planets, the stars, and the people and wonder how did all these wonderful things come into being. Jews believe the force we call G_d created the entire universe and everything in it. Jews feel G_d is all seeing and knowing and although we can’t see Him, He is everywhere and in everyone.We understand...
Passover for Americans
Posted on February 19, 2026 by Barry Zalma
Read the full article at https://www.linkedin.com/pulse/passover-americans-barry-zalma-esq-cfe-5vgkc.
“The Passover Seder For Americans”
For more than 3,000 years Jewish fathers have told the story of the Exodus of the enslaved Jews from Egypt. Telling the story has been required of all Jewish fathers. Americans, who have lived in North America for more than 300 years have become Americans and many have lostthe ability to read, write and understand the Hebrew language in which the story of Passover was first told in the Torah.
Passover is one of the many holidays Jewish People celebrate to help them remember the importance of G_d in their lives. We see the animals, the oceans, the rivers, the mountains, the rain, sun, the planets, the stars, and the people and ...
