THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
Post number 5287
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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.
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
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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 ...
Qui Tam Case Without Evidence to Prove Fraud Fails
Post number 5369
Read the full article at https://www.linkedin.com/pulse/qui-tam-insurer-contended-defrauded-barry-zalma-esq-cfe-pgfgc and at https://zalma.com/blog plus more than 5550 posts.
In People Of The State Of California Ex Rel. Heath & Yuen, APC v. Silver Bird Auto Leasing, LLC et al., B342847, California Court of Appeals, Second District, Eighth Division (June 5, 2026) Heath & Yuen, APC defended parties in an automobile collision case involving a McLaren and a tour van. After that case settled for $25,000, the firm filed a qui tam action under California’s Insurance Frauds Prevention Act (IFPA) against Silver Bird Auto Leasing, LLC, X-Law Group, PC, and Filippo Marchino. The firm alleged three fraudulent acts in the underlying litigation:
1. the complaint falsely stated the McLaren was making a “legal turn,”
2. respondents produced a fraudulent repair bill/estimate, and
3. respondents failed to disclose Marchino’s GEICO insurance and its payment for repairs....
Full Faith and Credit Act Controlled
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Posted on June 9, 2026 by Barry Zalma
Post number 5368
Posted on June 9, 2026 by Barry Zalma
In Prime Insurance Company, Inc. v. Medicab Transportation, LLC, Jason Rhodes, and Dale Johnson v. Prime Insurance Company, Inc and Prime Property & Casualty Insurance, Inc. No. 2:24-cv-421-SPC-KRH, United States District Court, M.D. Florida, Fort Myers Division (June 3, 2026) Medicab, a paratransit company, bought two policies in 2021: a Business Auto Policy from PPCI and a Commercial Liability Policy from Prime. Both policies, as originally written, appeared to cover injuries arising from loading and unloading patients from Medicab vans.
After a patient, Margaret St. Aubin, fell while being unloaded from a van and suffered injuries, her Estate made a $1 million demand. Prime and its claims administrator concluded that the Commercial Policy’s loading/unloading language had been included by mutual mistake, because...
Full Faith and Credit Act Controlled
Read the full article at https://lnkd.in/evHXiiFE and at https://zalma.com/blog.
Posted on June 9, 2026 by Barry Zalma
Post number 5368
Posted on June 9, 2026 by Barry Zalma
In Prime Insurance Company, Inc. v. Medicab Transportation, LLC, Jason Rhodes, and Dale Johnson v. Prime Insurance Company, Inc and Prime Property & Casualty Insurance, Inc. No. 2:24-cv-421-SPC-KRH, United States District Court, M.D. Florida, Fort Myers Division (June 3, 2026) Medicab, a paratransit company, bought two policies in 2021: a Business Auto Policy from PPCI and a Commercial Liability Policy from Prime. Both policies, as originally written, appeared to cover injuries arising from loading and unloading patients from Medicab vans.
After a patient, Margaret St. Aubin, fell while being unloaded from a van and suffered injuries, her Estate made a $1 million demand. Prime and its claims administrator concluded that the Commercial Policy’s loading/unloading language had been included by mutual mistake, because...
