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
Material Fact Not Proved Defeats Summary Judgment
Post number 5314
See the full video at https://lnkd.in/guT-87b6 and at https://lnkd.in/gEQrFndb and at https://zalma.com/blog, plus more than 5300 posts.
In Peleus Insurance Company, on its own behalf and on behalf of Bais Yaakov Dkal Adas Yereim and BT General Builders, Inc. v. United Specialty Insurance Company, No. 24 Civ. 1398 (KPF), United States District Court, S.D. New York (March 23, 2026) Peleus Insurance Company (“Peleus”), on behalf of itself and insureds Bais Yaakov Dkal Adas Yereim (“Bais”) and BT General Builders, Inc. (“BT”), initiated an action against United Specialty Insurance Company (“USIC”) in the United States District Court for the Southern District of New York. Peleus sought declaratory judgment regarding USIC’s obligations to defend and indemnify its insureds in connection with an underlying personal injury lawsuit pending in the Supreme Court of the State of New York, Kings County. Both parties cross-moved for summary ...
ABSOLUTE IMMUNITY FOR COMPLAINTS TO DMV
Complaints Filed By The Defendants With The Department Of Motor Vehicles Were Entitled To Absolute Immunity
Post number 5312
See the full video at https://lnkd.in/g8rhDh-Z and at https://lnkd.in/gkpfVfjb and at https://zalma.com/blog plus more than 5300 posts.
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.
LEGAL ISSUES
The central legal issue ...
DE FACTO PARTNERSHIP AFFIRMED
Implied In Fact Contract Can Only Exist However Where There Is No Express One
Post number 5311
Read the full article at https://lnkd.in/gPHyfRec, see the full video at https://lnkd.in/gRjMfgBj and at https://lnkd.in/gicdXhap, and at https://zalma.com/blog plus more than 5300 posts.
In Ronald Daigneault v. Danielle Kolashuk et al., No. AC 47259, Court of Appeals of Connecticut (March 24, 2026) Daigneault, owned and operated an auto repair business for approximately twenty-eight years. During this period, he and his daughter, the defendant D (Danielle Kolashuk), jointly operated the business. D’s husband owned Auto Magic, LLC (“A Co.”), which periodically stored towed vehicles on the business property. Disputes arose regarding the nature of the business relationship between the plaintiff and D, the use of business accounts, and payment for vehicle storage.
FACTUAL BACKGROUND
Ronald The plaintiff initiated an action seeking damages for, among other things, statutory theft and ...
Posted on March 30, 2026 by Barry Zalma
Insurance Fraud, a Way to Reduce Violent Crime
Post number 5313
A Fictionalized True Crime Story of Insurance Fraud from an Expert who explains why Insurance Fraud is a “Heads I Win, Tails You Lose” situation for Insurers. The story helps to Understand How Insurance Fraud in America is Costing Everyone who Buys Insurance Thousands of Dollars Every year and Why Insurance Fraud is Safer and More Profitable for the Perpetrators than any Other Crime.
She Taught Her Customers The Swoop And Squat:
Recently the California Insurance Department’s Fraud Division arrested a young woman in Los Angeles County for operating an insurance fraud school. She advertised her classes in the “Penny Saver” an advertising sheet distributed free to the public and a print version of Facebook, X Craig’s list. She had operated for several years teaching methods of committing automobile insurance fraud. Only after a police officer enrolled in one of her classes was she arrested.
Her defense ...
Posted on March 30, 2026 by Barry Zalma
Insurance Fraud, a Way to Reduce Violent Crime
Post number 5313
A Fictionalized True Crime Story of Insurance Fraud from an Expert who explains why Insurance Fraud is a “Heads I Win, Tails You Lose” situation for Insurers. The story helps to Understand How Insurance Fraud in America is Costing Everyone who Buys Insurance Thousands of Dollars Every year and Why Insurance Fraud is Safer and More Profitable for the Perpetrators than any Other Crime.
She Taught Her Customers The Swoop And Squat:
Recently the California Insurance Department’s Fraud Division arrested a young woman in Los Angeles County for operating an insurance fraud school. She advertised her classes in the “Penny Saver” an advertising sheet distributed free to the public and a print version of Facebook, X Craig’s list. She had operated for several years teaching methods of committing automobile insurance fraud. Only after a police officer enrolled in one of her classes was she arrested.
Her defense ...
Insurance Condition Requires Following the Intent of the Parties
Post number 5307
Principles of Contract Interpretation Compels Reading Contract as Written
Read the full article at https://www.linkedin.com/pulse/portable-storage-containers-buildings-barry-zalma-esq-cfe-fkg1c and at https://zalma.com/blog.
In Eastside Floor Supplies, Ltd. v. SCS Agency, Inc., Hanover Insurance Company, et al., No. 2024-01501, Index No. 609883/19, 2026 NY Slip Op 01488, Supreme Court of New York, Second Department (March 18, 2026)
In May 2019, a fire damaged business personal property belonging to the plaintiffs, which was stored in portable storage containers at their Manhattan premises. At the time of the fire, the plaintiffs were insured under a businessowners insurance policy (BOP) issued by the defendant Hanover Insurance Company which provided general coverage for business personal property, and which included a specific extension for “Business Personal Property Temporarily in Portable Storage Units” (the portable storage ...
