ZIFL – Volume 30 Number 5
THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
Read the full article at https://lnkd.in/gsD9eFea, see the full video at https://lnkd.in/gNiQ5zcw, https://lnkd.in/gnG8TAeT and at https://lnkd.in/gzjMXakw and at https://zalma.com/blog plus more than 5250 posts.
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:
ANTI-SLAPP MOTION STOPS CRIMINAL FROM ATTEMPT TO PROTECT HIS ASSETS FROM CONFISCATION
Convicted Criminal Seeks to Compel Receiver to Protect his Assets
The Work of a Court Appointed Receiver is Constitutionally Protected
In Simon Semaan et al. v. Robert P. Mosier et al., G064385, California Court of Appeals, Fourth District, Third Division (February 6, 2026) the Court of Appeals applied the California anti-SLAPP statute which protects defendants from meritless lawsuits arising from constitutionally protected activities, including those performed in official capacities. The court also considered the doctrine of quasi-judicial immunity, which shields court-appointed receivers from liability for discretionary acts performed within their official duties.
See the full article and the full March 1, 2026 issue at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-03-01-2026.pdf
Interesting Report on Using the Alarm System to Gather Evidence
Subrogation: Utilizing Alarm Systems as a Silent Witness to the Loss available at Subrogation: Utilizing Alarm Systems as a Silent Witness to the Loss available at https://www.claimsjournal.com/sponsored/ids-research-development/2026/02/17/335635.htm
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 a November 10 2025 lawsuit in Travis County, Texas identifies Mr. Huye, late of MMA, as the Chief Operating Officer of McCullough Heating and Air Conditioning, LLC.
See the full article and the full March 1, 2026 issue at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-03-01-2026.pdf
“Lulling” is Important in Insurance Fraud Cases
“Lulling” is frequently found in cases involving financial crimes and insurance fraud. It was recognized by the US Supreme Court in 1974 in United States v. Thomas E. Maze, 14 U.S. 395, 94 S.Ct. 645, 38 L.Ed.2d 603, No. 72—1168 (Jan. 8, 1974). SCOTUS noted that when the defendant used subsequent mailings designed to lull the victims into a false sense of security, postpone their ultimate complaint to the authorities, and therefore make the apprehension of the defendants less likely than if no mailings had taken place it is evidence of fraud.
See the full article and the full March 1, 2026 issue at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-03-01-2026.pdf
Health Insurance Fraud
Billing and Coding Abuses
Billing and coding abuses constitute a prevalent form of Medicare fraud. Providers intent on committing fraud intentionally submit inaccurate procedure or diagnosis codes to inflate reimbursements under the program's fee-for-service structure.
See the full article and the full March 1, 2026 issue at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-03-01-2026.pdf
Health Insurance Fraud Convictions
Zynex, Inc. Agrees to Criminal Resolution Addressing Claims of Millions of Dollars of Health Care Fraud, Securities Fraud and Related Offenses
See the full article and the full March 1, 2026 issue at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-03-01-2026.pdf
Other Than Health Insurance Fraud Convictions
Kansas Man Sentenced for Insurance Fraud, Forgery
Larry Wilson, aged 54, pleaded guilty on December 11, 2025, in Reno County District Court to one felony count of insurance fraud, two felony counts for making false information, and two felony counts for forgery.
See the full article and the full March 1, 2026 issue at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-03-01-2026.pdf
Coalition Against Insurance Fraud Announces New Leadership Appointments
The Coalition Against Insurance Fraud announced new leadership appointments across several of its committees and task forces, reinforcing its commitment to collaboration, innovation, and excellence in fraud prevention.
He Admitted He Did the Crime and Must Serve the Time
Fraud Perpetrators Have no Honor & 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.
See the full article and the full March 1, 2026 issue at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-03-01-2026.pdf
Insurance Fraud Bill Unanimously Passes Washington Senate
A bill intended to combat insurance fraud by updating a 20-year-old law passed the Washington state senate this week on a unanimous vote. Senate Bill 6031, which defines insurance fraud as its own crime, a Class B felony, was pushed for by Washington state Insurance Commissioner Patty Kuderer.
See the full article and the full March 1, 2026 issue at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-03-01-2026.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. Subscribe to Excellence in Claims Handling at https://barryzalma.substack.com/welcome.
See the full article and the full March 1, 2026 issue at http://zalma.com/blog/wp-content/uploads/2026/02/ZIFL-03-01-2026.pdf
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...
