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.
Subscribe to Excellence in Claims Handling at https://barryzalma.substack.com/welcome.
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 ...
No Breach of Contract no Bad Faith
Post 4568
Posted on October 23, 2026 by Barry Zalma
A Party Cannot Designate One Witness While Submitting An Undifferentiated Product Of That Witness And An Undesignated Collaborator.
Post 4568
In Dustin Cain; Amanda Cain v. State Farm Fire and Casualty Company, No. 25-60442, United States Court of Appeals, Fifth Circuit (October 16, 2026) Dustin and Amanda Cain sought homeowners’ insurance benefits after a tree fell on their Mississippi home on August 27, 2022. State Farm concluded that the tree caused only a roof puncture and that other damage resulted from excluded long-term conditions. It paid $10,042.90 and later an additional $3,130.08.
The Cains relied on an engineering report and contractor estimate asserting substantially greater damage, sued for breach of contract and related relief, and designated Sean Fee as their sole expert. Fee’s report and a later repair estimate were jointly authored with Jim Irmiter, but neither document identified which opinions, work, or ...
Blockchain Fraud Detection Loses Protection
Posted on October 22, 2026 by Barry Zalma
John Earl Madden (April 10, 1936 – December 28, 2021) was an American Professional Football Coach and Sports Commentator in the National Football League Seeking Patent & Trademark Protection
BLOCKCHAIN FRAUD
Mr. Madden was more than football. He was working to establish a program called “Fraud Protection Systems, Methods, and Computer Programs for Blockchain Financial Transactions.”
In Ex parte John Madden, Appeal 2026-001497, Application 18/495,506, Technology Center 3600, United States Patent and Trademark Office, Patent Trial and Appeal Board (October 14, 2026)
The Examiner rejected claims several numbered claims under 35 U.S.C. § 101 as directed to an abstract idea without significantly more.
THE LAW
Section 101 makes patentable any new and useful process, machine, manufacture, or composition of matter.Laws of nature, natural phenomena, and abstract ideas are implicitly excluded.
THE PATENT TRIAL AND ...
Sovereign Immunity Defeats Suit Against Police Officers
Post 4866
Posted on October 21, 2026 by Barry Zalma
In Chad Lightfoot, et al. v. Progressive Direct Insurance Company, et al., Civil Action No. 26-434, United States District Court, E.D. Louisiana (October 9, 2026) Chad Lightfoot was involved in an Orleans Parish automobile accident in 2011 and filed claims with several insurers, including Progressive.
After a related civil dispute, Progressive counsel allegedly submitted a false affidavit stating that Lightfoot had fraudulently received a $50,000 payment. A New Orleans police detective relied on the affidavit to obtain an arrest warrant, and Louisiana State Police Lieutenant Alan Arcana allegedly reported that Lightfoot had received the payment. Lightfoot was arrested in 2015 and charged with theft, insurance fraud, and perjury.
Plaintiffs alleged that no record of the payment existed and that the criminal charges were dismissed on October 15, 2024.
Lightfoot and Geralyn Hawkins filed suit in October 2025 and ...
