Zalma on Insurance
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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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March 10, 2026
Acting as Your Own Lawyer is Foolish

Proof of Highly Contaminated Water is Required for Extra Payments

Post number 5300

Read the full article at https://www.linkedin.com/pulse/acting-your-own-lawyer-foolish-barry-zalma-esq-cfe-mbg0c, see the video at and at https://youtu.be/wqXxEHuJ1T0, and at https://zalma.com/blog plus more than 5300 posts.

Acting as Your Own Lawyer is Foolish

Evidence of Breach of Contract Survives Dismissal of All Other Charges

In Lee Lifeng Hsu and Jane Yuchen Hsu v. State Farm Fire And Casualty Company, C. A. No. N24C-09-020 CLS, Superior Court of Delaware (February 27, 2026) a claim to State Farm who paid approximately $61,000 after assessments but denied coverage for additional items including ceramic tiles, the kitchen floor ceiling, underlayment plywood, and numerous personal property items resulted in suit by the Hsu’s acting in pro per.
Facts

Lee Lifeng Hsu and Jane Yuchen Hsu (“Plaintiffs”) purchased a homeowners’ insurance policy from State Farm Fire...

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May 11, 2026
Severe Punishment for Failure to Obey Court Orders

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

See the full video at and at and at https://zalma.com/blog plus 5300 posts.

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 ...

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May 08, 2026
Ambiguous Contract to Repair not an Assignment

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 ...

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May 08, 2026
Admit to Crime & Be Ready to do The Time

Attempt to Withdraw Plea After Sentencing Fails

Post number 5346

Read the full article at https://www.linkedin.com/pulse/admit-crime-ready-do-time-barry-zalma-esq-cfe-hgyce, see the video at and at and at https://zalma.com/blog plus more than 5300 posts.

Stealing from Insurers and Employer Gets Defendant Five Years in Prison

In State of Wisconsin v. Jacquelyn R. Harris, No. 2025AP489-CR, Court of Appeals of Wisconsin (April 22, 2026) Harris pled no contest and was found guilty. She was sentenced to five years of initial confinement and three years of extended supervision, with restitution ordered in the amounts of $31,086 to Kaliber and $25,000 to Erie Insurance Company.

FACTUAL BACKGROUND

In late 2022, Jacquelyn R. Harris was charged with theft in a business setting under WIS. STAT. § 943.20(1)(b) (2023-24). Harris, while employed as the office manager for Kaliber Collision Repair in Port ...

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16 hours ago

Plaintiff May Try Again to get a Judgment
Posted on May 22, 2026 by Barry Zalma
Just Because a Defendant Defaults Evidence is Needed to get a Judgment

Even on a Default Motion the Plaintiff Must Do More Than Rely on Conclusory Allegations.
Post number 5356

The Commissioners Of The State Insurance Fund v. Capcon Construction Industries Corp., Capcon Construction Supply Corp., Jab Masonry Corp., Agra Masonry Inc., Agra Industries Usa Corp, A & A Masonry Corp., Alexander Shvartsberg, Darren Caputo, Maryann Furman, Index No. 452680/2024, MOTION SEQ. No. 003, 2026 NY Slip Op 31767(U), Supreme Court, New York County (April 20, 2026)
FACTS

The Commissioners of the State Insurance Fund (SIF) had already obtained two judgments for unpaid workers’ compensation insurance premiums: one against A\&A Masonry Corp. and another, much larger one, against Agra Masonry Inc. SIF then brought this action against several related corporations and individuals, alleging that they all operated as a single de facto enterprise and that assets had ...

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May 21, 2026
Proactive Insurer Makes a Fraudster Pay

Defaulting Fraud Perpetrator Lets Insurer Defeat Fraud
Post number 5355

Posted on May 21, 2026 by Barry Zalma

In Transamerica Life Insurance Company v. John Joseph Egan, et al., No. 25-cv-06167-JD, United States District Court, N.D. California (May 12, 2026) Transamerica Life Insurance Company issued John Egan a life insurance policy with a long-term care rider that covered in-home skilled nursing or other professional care if he qualified as chronically ill.

FACTUAL BACKGROUND

In 2023, Egan submitted a claim alleging severe pain, major loss of daily functioning, and limited mobility following an auto accident. Transamerica approved coverage and paid benefits based on those representations and repeated proofs of loss describing in-home care services. After later surveillance in 2024 and 2025 showed Egan working, driving, shopping, and otherwise functioning without visible impairment — and showed no evidence of in-home care — Transamerica concluded that the claim was fraudulent and filed suit.

Transamerica surveilled ...

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May 21, 2026
Proactive Insurer Makes a Fraudster Pay

Defaulting Fraud Perpetrator Lets Insurer Defeat Fraud
Post number 5355

Posted on May 21, 2026 by Barry Zalma

In Transamerica Life Insurance Company v. John Joseph Egan, et al., No. 25-cv-06167-JD, United States District Court, N.D. California (May 12, 2026) Transamerica Life Insurance Company issued John Egan a life insurance policy with a long-term care rider that covered in-home skilled nursing or other professional care if he qualified as chronically ill.

FACTUAL BACKGROUND

In 2023, Egan submitted a claim alleging severe pain, major loss of daily functioning, and limited mobility following an auto accident. Transamerica approved coverage and paid benefits based on those representations and repeated proofs of loss describing in-home care services. After later surveillance in 2024 and 2025 showed Egan working, driving, shopping, and otherwise functioning without visible impairment — and showed no evidence of in-home care — Transamerica concluded that the claim was fraudulent and filed suit.

Transamerica surveilled ...

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