ZIFL – Volume 30, Issue 7 – April 1, 2026
THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
Post number 5314
Posted on April 1, 2026 by Barry Zalma
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:
No One is Above the Law – Not Even a Police Officer
Police Officer Convicted for Fraud in Reporting an Accident Affirmed
Police Officer Should never Lie about Results of Chase
In State Of Ohio v. Anthony Holmes, No. 115123, 2026-Ohio-736, Court of Appeals of Ohio, Eighth District, Cuyahoga (March 5, 2026) a police officer appealed criminal conviction as a result of lies about a high speed chase.
Read the following article and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
There is No Honor Among Thieves
Convicted Fraudsters Try to Cheat Each Other
After failing to defraud insurers about the loss of a diamond ring the two admitted fraudsters sought possession of the seized ring which was neither lost nor stolen but was seized by the state.
In State Of North Carolina v. Kevin Ray Reece and Debra Lee Goldman, No. COA25-569, Court of Appeals of North Carolina (March 18, 2026) two fraudsters disputed the ownership of a platinum-banded diamond ring seized during a criminal investigation as the subject of Insurance Fraud.
Read the following article and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
Failure to Provide Well-Pled Facts Defeats Most of Action
ERISA Saves Fraudulent Claims Suit
Allegations of Fraudulent Insurance Billing Must be Pleaded with Specificity
In Genesis Laboratory Management LLC v. United Healthcare Services, Inc. and Oxford Health Plans, Inc., No. 21cv12057 (EP) (JSA), United States District Court, D. New Jersey (March 13, 2026) Genesis Laboratory Management LLC (“Genesis”), a New Jersey-based molecular diagnostic and anatomic pathology laboratory, provided COVID-19 related testing services and submitted claims for reimbursement as an out-of-network provider to United Healthcare Services, Inc. (“United”) and Oxford Health Insurance, Inc. (“Oxford”). Metropolitan Healthcare Billing, LLC (“Metropolitan”), owned by the same individual as Genesis, managed the billing for Genesis.
Read the following article and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
CRIME DOESN’T PAY, IT COSTS
No Right to Recover Allegedly Lost Jewelry When You Defrauded Your Insurer
Fraudulent Claims Defeated by Great Investigation
In The Cincinnati Insurance Company v. Zachary M. Zeltzer, Civil Action No. 25-2687, United States District Court, D. New Jersey (March 11, 2026) Plaintiff The Cincinnati Insurance Company issued an insurance policy to Defendant Zachary M. Zeltzer covering, among other things, jewelry. On September 3, 2021, Defendant submitted a claim reporting the loss of four jewelry items while vacationing in Italy.
Read the following article and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
Health Insurance Fraud Convictions
Arizona Cardiology Group Paying $4.75M Over Unnecessary Vein Procedure Allegations
Tri-City Cardiology, P.C., a physician group based in the metro area of Phoenix, and three physicians are paying the sum to resolve allegations that they violated the False Claims Act by performing the procedures.
The cardiology business and three physicians in Arizona were ordered to pay $4.75 million to resolve allegations they performed medically unnecessary vein ablations.
Read the following article and dozens more convictions and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
SPECULATION ABOUNDS ABOUT JAIL TIME THE LOUISIANA STAGED TRUCK ACCIDENT ATTORNEYS WILL RECEIVE AFTER A GUILTY VERDICT
Some Suggest The Maximum Is Possible As Federal Judge Expresses Serious Concerns About Defendants’ Actions
Sentencing of the two attorneys convicted in Operation Sideswipe is set for July.
Attorneys Vanessa Motta and Jason Giles were convicted in the U.S. District Court for the Eastern District of Louisiana on a variety of mail fraud, wire fraud and witness tampering charges connected to the scheme where a car full of passengers would slam into a truck in an effort to reap insurance payouts.
Read the following article and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
Other Than Health Insurance Fraud Cases
Oklahoma Insurance Producer Has License Revoked Following Investigation
Leslie Clark, a resident insurance producer from Stigler, Oklahoma, following an investigation led by its Anti-Fraud Uni was fined and her license was revoked by the Oklahoma Insurance Department (OID) announced it has
On Feb. 11, 2026, a show-cause hearing was held at OID’s offices before an independent examiner, at which Clark failed to appear. Clark was found to have improperly withheld and misappropriated 18 cash receipts totaling $7,269.38 from consumer premium payments.
Read the following article and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
The Three Laws of Robotics
From Iassac Asimov’s book, I Robot
Dr. Asimov presented the laws in his fictional “Handbook of Robotics, 56th Edition, 2058 A.D.” are:
1. A robot may not injure a human being or, through inaction, allow a human being to come to harm.
2. A robot must obey the orders given it by human beings except where such orders would conflict with the First Law.
3. A robot must protect its own existence as long as such protection does not conflict with the First or Second Law.
Hopefully to be understood by those using Artificial Intelligence in the insurance industry replacing the words “human beings” with the “insureds.”
Read the following article and the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
LITIGATION PRIVILEGE DEFEATS DEFAMATION SUITS
ABSOLUTE IMMUNITY FOR COMPLAINTS TO DMV
Complaints Filed By The Defendants With The Department Of Motor Vehicles Were Entitled To Absolute Immunity
In Modzelewski’s Towing & Storage, Inc., et al. v. Government Employees Insurance Company et al., No. AC 47933, Court of Appeals of Connecticut (March 24, 2026) Modzelewski’s Towing & Storage, Inc., Chris’ Auto Clinic, LLC, MyHoopty.com, LLC, and Farmington Auto Park, LLC, initiated an action seeking damages for tortious interference with business expectancies and other relief. The dispute arose after complaints were filed against them by Government Employees Insurance Company (GEICO) and individual defendants John P. Vaz and Patrick Capri with the Connecticut Department of Motor Vehicles. The plaintiffs alleged that these complaints interfered with their business relationships.
Barry Zalma
Barry Zalma, Inc., 4441 Sepulveda Boulevard, CULVER CITY CA 90230-4847, 310-390-4455.
Subscribe to Excellence in Claims Handling at https://barryzalma.substack.com/welcome.
Read the full issue of ZIFL at https://zalma.com/blog/wp-content/uploads/2026/03/ZIFL-04-01-2026-1.pdf
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 ...
Payment of Fines & Completion of Probation Reinstates Right to Vote
Post 4576
Posted on November 5, 2026 by Barry Zalma
To Restore Voting Rights The Felon Must Pay Fines of $546.00
In Florida Supreme Court Mediator Ethics Advisory Committee, ETH F-26-377, No. F-26-377 (October 29, 2026) citizen unnamed and to Ron Desantis Governor, Cord Byrd the Secretary of State Florida Division of Elections provided an advisory opinion to a convicted felon about his right to vote:
To: [redacted] We received your request for an advisory opinion. You indicate that you have one or more felony convictions and request whether you are eligible to vote, including whether you have any outstanding legal financial obligations under section 98.0751, Florida Statutes, and, if so, a statement of the amount that must be paid to make you eligible to vote, and an explanation of how the amount was calculated.
The Division hereby responds to your request pursuant to its legal authority under section 106.23(2), Florida Statutes, and Florida ...
Administrative Review Permits the Agency to Apply its Expertise
Post 4574
In Erwin Jordan Castro Valdez v. Warden, Otay Mesa Detention Center, No. 26-cv-06147-BAS-JLB, United States District Court, S.D. California (October 30, 2026) Castro Valdez, a Cuban national paroled into the United States, was arrested on June 23, 2026, for alleged insurance fraud, grand theft, and making a false report to law enforcement. In his first habeas action, the district court ordered a bond hearing within fourteen days to determine whether the changed circumstances justified revoking his parole.
An Immigration Judge subsequently denied bond because of his pending state criminal case. Castro Valdez filed a second petition under 28 U.S.C. § 2241, challenging that determination and requesting immediate release without first appealing to the Board of Immigration Appeals (BIA).
LAW
According to the supplied text, § 2241 does not expressly require administrative exhaustion, but courts impose exhaustion as a prudential requirement. ...
Insured’s Ordered to Pay Insurer for Fraud by the Insureds
Post 4573
Posted on November 3, 2026 by Barry Zalma
In The Prudential Insurance Company Of America v. Carol Gardina and George Gardina, No. 6:23-cv-1125-JSS-DCI, United States District Court, M.D. Florida, Orlando Division (October 22, 2026).
THE JURY TRIAL AND VERDICT
Plaintiff sued Defendants for numerous causes of action stemming from its allegations that Defendants fraudulently collected benefits under their long-term care insurance policies. Plaintiff's case proceeded to a nine-day jury trial, after which the jury found Defendants liable for fraudulent misrepresentation, fraudulent concealment, and civil conspiracy.
The jury also found Defendant Carol Gardina liable to Plaintiff for $1,930,129 in compensatory damages and Defendant George Gardina liable to Plaintiff for $12,496 in compensatory damages and $20 in punitive damages. Thereafter, the court entered judgment in Plaintiff's favor and awarded Plaintiff $1,930,129 in compensatory damages from...
