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.
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 ...
Excellence in Claims Handling
Posted on October 29, 2026 by Barry Zalma
Common Problems in a Jewelers’ Block Policy Investigation
If you are not a subscriber you will read from this link until you reach the paywall end of this blog post as the free part of Excellence in Claims Handling. You should consider joining as a paid member to get full access to articles for members only, to our news, analysis, insurance coverage, claims, insurance fraud and insurance webinars, by clicking at the button above.
This is a taste of the latest Excellence in Claims Handling Article for subscribers to my substack. Subscribe to my substack at https://lnkd.in/gmmzUVBy
The History of the Jewelers’ Block Policy
The ‘jewelers’ block policy’ had its origin about 1920, and since that time the policy and the proposal upon which it is based have become more or less standard.
The Inland-Marine Insurance Bureau, of which appellant is a member, prescribes contracts and proposals for such policies that are ...
Self Insurance is Excess Over Primary Insurance
Post 4572
Posted on October 29, 2026 by Barry Zalma
Employment Plan is Insurance Because it Transferred Risk and Contained Claim, Exclusion, and Priority Provisions.
In Ajay Kolli, & c. et al. v. Kaleida Health, 2026 NY Slip Op 06167, No. 72, New York Court of Appeals (October 22, 2026) Dr. Venkateswara Kolli treated a patient in 2011 while serving as an on-call, per diem physician for Kaleida Health. The patient later sued Dr. Kolli and Kaleida for medical malpractice.
In 2011, decedent Dr. Venkateswara Kolli treated a patient as part of his duties pursuant to an on-call, per diem physician employment agreement with defendant Kaleida Health. The patient subsequently sued Dr. Kolli and Kaleida. Dr. Kolli sought indemnity from his primary medical malpractice insurer, MLMIC Insurance Company (MLMIC), as well as his excess insurer Healthcare Professionals Insurance Company (HPIC).
The underlying medical malpractice action settled after Dr. Kolli’s death. Kaleida, MLMIC, and ...
RICO Suit Against Law Firm & Health Care Pros Fails
Posted on October 28, 2026 by Barry Zalma
UBER AND FEDEX FIGHT FRAUD
Racketeer Influenced and Corrupt Organizations Act (RICO) is Designed to Defeat Fraud Perpetrators
In Uber Technologies, Inc., et al. v. Simon & Simon P.C., et al., Civil Action No. 25-5365, United States District Court, E.D. Pennsylvania (October 13, 2026) Uber Technologies, Inc. and Federal Express Corporation sued attorney Marc Simon, his firm Simon & Simon, P.C., and several medical professionals and practices under the Racketeer Influenced and Corrupt Organizations Act (RICO).
They allege the defendants orchestrated a scheme to generate and litigate fraudulent personal injury claims arising from motor vehicle accidents involving Uber and FedEx drivers. Uber and FedEx incurred defense costs and paid settlements on some claims. The court earlier denied a motion to dismiss, finding proximate causation adequately pleaded. Fact discovery is set to close December 21, 2026.
Discovery showed Uber’s...
