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Insurance Claims professional presents articles and videos on insurance, insurance Claims and insurance law for insurance Claims adjusters, insurance professionals and insurance lawyers who wish to improve their skills and knowledge. Presented by an internationally recognized expert and author.
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February 17, 2026
Zalma’s Insurance Fraud Letter – February 15, 2026

THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
Post number 5287

Read the full article at https://lnkd.in/g8YCDK8a, see the full video at https://lnkd.in/g-3B_Tv7 and at https://lnkd.in/g9nhJXM5, and at https://zalma.com/blog plus more than 5250 posts.

ZIFL – Volume 30 Number 4

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:

Over 600 Independent Collection Actions Aids Fraud

Multiple Suits or Arbitration on Fraudulent Claims Irreparably Harm GEICO
GEICO Successfully Fights No Fault Auto Insurance Claims Fraud by Fraudsters Seeking Independent Trials or Arbitrations for Each Suspected Fraudulent Claim

In Government Employees Insurance Company, et al v. Bhargav Patel, MD, Patel Medical Care, P.C., John Doe Defendants 1 through 10, No. 24-191, USCA, Second Circuit (February 3, 2026) Government Employees Insurance Company (GEICO) and its subsidiaries, brought a civil action under the Racketeering Influenced and Corrupt Organization Act (“RICO”) against Dr. Bhargav Patel, Patel Medical Care, P.C., and other associated defendants.

Read the full 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-02-15-2026.pdf.

More McClenny Moseley & Associates Issues

This is ZIFL’s forty second 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.

In MMA LAW FIRM, PLLC v. MORRIS BART, LLC, ADVERSARY PRO. NO. 24-3127, Civil Action No. 4:24-CV-4446, United States District Court, S.D. Texas, Houston Division (January 23, 2026) the case arose from a series of civil actions linked to adversary proceedings in the Bankruptcy Court for the Southern District of Texas, specifically involving MMA Law Firm, PLLC and Morris Bart, LLC. Central to the dispute are attorneys’ fees and costs related to thousands of cases filed in Louisiana following Hurricane Ida in 2021, which caused widespread property damage.

Read the full article and the 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-02-15-2026.pdf.

Commissioner Lara And Assemblymember Calderon Announce Legislation Transforming The California FAIR Plan

A Press Release from the California Department of Insurance

Read the full article and the 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-02-15-2026.pdf.

Health Insurance Fraud Convictions

Guilty to Conspiracy to Violate the Anti-Kickback Statute
Defendant submitted approximately $6.5 million in kickback-tainted claims to Medicare

Deane Gilmore, 35, of Brandon, Fla., pleaded guilty to one count of conspiracy to pay and receive kickbacks before U.S. District Court Judge Brian E. Murphy, who scheduled sentencing for May 12, 2026. Gilmore was charged in December 2025.

Read the full article and dozens of convictions and the 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-02-15-2026.pdf.
Other Than Health Insurance Fraud Convictions

Michigan AG Secures Judgment Against Contractors Over Consumer Scam

Caltons Lawn Care & Landscaping LLC and its owners, Aron Dean Calton and Leslie Calton, of Kent City, for violating the Michigan Consumer Protection Act. The company took advanced payments or deposits for lawn service and pool projects, performed little or no work, and then ignored or blocked customers who requested refunds.

Read the full article and dozens of convictions and the 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-02-15-2026.pdf.
Insurers Must be Proactive When Victims of Fraud

UPCODING FRAUDSTER NEEDS TO PRODUCE DOCUMENTS DEMANDED

Health Insurance Fraud Can Be Stopped by Aggressive Insurers

In Unitedhealthcare Services, Inc., United Healthcare Insurance Co., and UMR, Inc. v. Team Health Holdings, Inc., Ameriteam Services, LLC, and HCFS Health Care Financial Services, Inc., No. 3:21-CV-364-DCLC-DCP, United States District Court, E.D. Tennessee, Knoxville (February 2, 2026) Plaintiffs are health insurance providers and claim administrators who process and pay approximately one million claims daily, relying on automated adjudication and truthful information from providers.

Read the full article and the 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-02-15-2026.pdf.

Proposed Expert Testimony That is Both Reliable and Relevant is Proper

Not All Expert Testimony must be Scientifically Reliable

In Church Mutual Insurance Company, S.I. v. Chabad Of New Mexico, No. 1:24-cv-00090-MIS-SCY, United States District Court, D. New Mexico (February 10, 2026) the USDC dealt with a declaratory judgment filed by Church Mutual that it owes no duty to cover Chabad’s claims because the property was “vacant” for more than sixty consecutive days before the acts of arson, and therefore no coverage is owed pursuant to the Policy’s “Vacancy” loss condition.

Read the full 20 page issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-02-15-2026.pdf.

Barry Zalma

Barry Zalma, Inc., 4441 Sepulveda Boulevard, CULVER CITY CA 90230-4847, 310-390-4455.

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, Subscribe to Excellence in Claims Handling at https://barryzalma.substack.com/welcome.

00:11:25
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1 hour ago
Win Some and Lose Some

Opiod Producer Seeks Indemnity from CGL Insurers

Post number 5288

Read the full article at https://lnkd.in/guNhStN2, see the full video at https://lnkd.in/gYqkk-n3 and at https://lnkd.in/g8U3ehuc, and at https://zalma.com/blog plus more than 5250 posts.

Insurers Exclude Damages Due to Insured’s Products

In Matthew Dundon, As The Trustee Of The Endo General Unsecured Creditors’ Trust v. ACE Property And Casualty Insurance Company, et al., Civil Action No. 24-4221, United States District Court, E.D. Pennsylvania (February 10, 2026) Matthew Dundon, trustee of the Endo General Unsecured Creditors’ Trust, sued multiple commercial general liability (CGL) insurers for coverage of opioid-related litigation involving Endo International PLC a pharmaceutical manufacturer.

KEY FACTS

Beginning as early as 2014, thousands of opioid suits were filed by governments, third parties, and individuals alleging harms tied to opioid manufacturing and marketing.

Bankruptcy & Settlements

Endo filed Chapter 11 in August 2022; before bankruptcy it ...

00:08:32
February 16, 2026
Expert’s Personal Knowledge or Experience Can Assist Jury

Not All Expert Testimony must be Scientifically Reliable
Post number 5284

Read the full article at https://lnkd.in/gcS7tWC8; see the video at https://lnkd.in/g7N27nuK and at https://lnkd.in/gcYh2sZG, and at https://zalma.com/blog plus more than 5250 posts.

In Church Mutual Insurance Company, S.I. v. Chabad Of New Mexico, No. 1:24-cv-00090-MIS-SCY, United States District Court, D. New Mexico (February 10, 2026) the USDC dealt with a declaratory judgment filed by Church Mutual that it owes no duty to cover Chabad’s claims because the property was “vacant” for more than sixty consecutive days before the acts of arson, and therefore no coverage is owed pursuant to the Policy’s “Vacancy” loss condition.

FACTUAL BACKGROUND

Church Mutual Insurance Company, S.I. (“Church Mutual”) renewed an insurance policy for Chabad of New Mexico (“Chabad”) covering real property in Rio Rancho, New Mexico. The policy included a “Vacancy” loss condition, stating that if the building was vacant for more than 60 ...

00:07:40
February 13, 2026
Expert’s Personal Knowledge or Experience Can Assist Jury

Not All Expert Testimony must be Scientifically Reliable
Post number 5284

Read the full article at https://lnkd.in/gcS7tWC8; see the video at https://lnkd.in/g7N27nuK and at https://lnkd.in/gcYh2sZG, and at https://zalma.com/blog plus more than 5250 posts.

In Church Mutual Insurance Company, S.I. v. Chabad Of New Mexico, No. 1:24-cv-00090-MIS-SCY, United States District Court, D. New Mexico (February 10, 2026) the USDC dealt with a declaratory judgment filed by Church Mutual that it owes no duty to cover Chabad’s claims because the property was “vacant” for more than sixty consecutive days before the acts of arson, and therefore no coverage is owed pursuant to the Policy’s “Vacancy” loss condition.

FACTUAL BACKGROUND

Church Mutual Insurance Company, S.I. (“Church Mutual”) renewed an insurance policy for Chabad of New Mexico (“Chabad”) covering real property in Rio Rancho, New Mexico. The policy included a “Vacancy” loss condition, stating that if the building was vacant for more than 60 ...

00:07:40
January 30, 2026
Anti-Concurrent Cause Exclusion Effective

You Get What You Pay For – Less Coverage Means Lower Premium

Post number 5275

Posted on January 30, 2026 by Barry Zalma

See the video at and at

When Experts for Both Sides Agree That Two Causes Concur to Cause a Wall to Collapse Exclusion Applies

In Lido Hospitality, Inc. v. AIX Specialty Insurance Company, No. 1-24-1465, 2026 IL App (1st) 241465-U, Court of Appeals of Illinois (January 27, 2026) resolved the effect of an anti-concurrent cause exclusion to a loss with more than one cause.

Facts and Background

Lido Hospitality, Inc. operates the Lido Motel in Franklin Park, Illinois. In November 2020, a windstorm caused one of the motel’s brick veneer walls to collapse. At the time, Lido was insured under a policy issued by AIX Specialty Insurance Company which provided coverage for windstorm damage. However, the policy contained an exclusion for any loss or damage directly or indirectly resulting from ...

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January 29, 2026
Resolution of Coverage Issues Appropriate Under Federal Declaratory Judgment Act

Declaratory Relief Available to an Insurer from USDC

Post number 5274

Read the full article at https://www.linkedin.com/pulse/resolution-coverage-issues-appropriate-under-federal-barry-wfpoc, see the video at and at and at https://zalma.com/blog plus more than 5250 posts.

Insurer Seeks Limitation of Liability of Child Killed by Foster Dogs

In the Cincinnati Specialty Underwriters Insurance Company, an Ohio corporation v. Dennis Murphy, as Personal Representative of the Wrongful Death Estate of Avery Colin Jackson-Dunphy, Deceased; Patrick Admiral Dunphy, an Individual; Danika Thompson, an Individual; and Animal Services Center Of The Messila Valley, a New Mexico limited Liability Company, No. CIV 24-1039 JB/JFR, United States District Court, D. New Mexico (January 23, 2026) resolved the issues raised about the court's jurisdiction.

Cincinnati Specialty Underwriters Insurance Company ...

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January 26, 2026
Insurance Fraud Gets You Three Squares and a Cot

Posted on January 26, 2026 by Barry Zalma
Insurance Fraud Should Not be a Retirement Plan

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Health Insurance Providers Are Attempting Insurance Fraud to Fund Retirement

Every insurer is required by its shareholders, members, state statutes and state regulations to do everything possible to deter and defeat attempts at insurance fraud. Most insurers, therefore, have a staff of fraud investigators working under their Special Investigative Unit (SIU) and the SIU works to train the claims handlers to recognize the indicators or red flags of fraud.

Much to the surprise of...

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