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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April 07, 2026
NO GOOD LAW GOES UNPUNISHED

Posted on April 7, 2026 by Barry Zalma

Alleged No Fault Fraudsters Enjoined from Claims, Arbitration or Suit to Collect Benefits

Post number 5318

See the full video at https://lnkd.in/gDVBjCn7 and at https://lnkd.in/g-MYNe8b and at https://zalma.com/blog plus more than 5300 posts.

In Allstate Insurance Company, Allstate Indemnity Company, Allstate Property & Casualty Insurance Company, and Allstate Fire & Casualty Insurance Company v. Jonathan S. Landow, M.D., Viviane Etienne, M.D., Atlantic Medical & Diagnostic, P.C., Birch Medical & Diagnostic, P.C., Eastern Medical Practice, P.C., Empire Medical Services, P.C., Macintosh Medical, P.C. Paramount Medical Services, P.C., Preferred Medical, P.C., Sovereign Medical Services, P.C., Spruce Medical & Diagnostic, P.C., Summit Medical Services, P.C., Urban Medical, P.C., Roman Matatov, Uriyel Mirzakandov, and Ruben Levy a/k/a Ruben Leviyev, No. 24-CV-2010 (DLI) (JRC), United States District Court, E.D. New York (March 30, 2026) Plaintiffs filed a 187-page complaint, including dozens of pages of exhibits, detailing a scheme of kickbacks for patient referrals, operation of clinics by laypersons, lack of medical care provided by the M.D. Defendants, and predetermined and trumped up medical treatments.

FACTS

Allstate Insurance Company and related entities (“Plaintiffs”) sued multiple defendants, including physicians, medical professional corporations, and managerial individuals (“Defendants”). The Plaintiffs alleged that Defendants collectively participated in a scheme to defraud them by exploiting New York’s No Fault insurance system, submitting illegal or inflated medical costs through various medical professional corporations. The action involves claims of violations of the Federal RICO Act, common law fraud, and unjust enrichment.

Allstate sued Jonathan S. Landow and multiple (“M.D. Defendants”), Urban Medical, P.C. (collectively, “PC Defendants”), Roman Israilov a/k/a Roman Matatov, (collectively, “Managerial Defendants”)The suit alleged violations of the Federal Racketeer Influenced and Corrupt Organizations (“RICO”) Act, common law fraud, and unjust enrichment. Plaintiffs alleged that all Defendants collectively engaged in a scheme to defraud Plaintiffs via New York’s No Fault insurance statutory framework (“No Fault”).

LAW

The case centers on New York’s No Fault statutory framework, which is designed to provide prompt compensation for necessary medical expenses resulting from motor vehicle accidents, up to $50,000 per person. The laws allow claimants to assign benefits to licensed healthcare providers, who then submit claims to insurers for payment. Providers must be operated by licensed professionals, and any fraudulent activity — including submitting materially false claims or receiving kickbacks — is prohibited under relevant New York statutes. Failure to comply with licensing requirements renders providers ineligible for reimbursement.

DISCUSSION

Plaintiffs sought a preliminary injunction to stay all current No Fault arbitrations and prevent Defendants from filing new arbitrations or state court collection suits during the litigation. The court reviewed the statutory requirements and allegations, focusing on whether Defendants’ conduct violated the No Fault laws and related regulations.

ANALYSIS

A party seeking a preliminary injunction must show:

1. irreparable harm;
2. either a likelihood of success on the merits or both serious questions on the merits and a balance of hardships decidedly favoring the moving party; and
3. that a preliminary injunction is in the public interest.

The court examined the statutory prerequisites for medical providers to claim No Fault benefits, emphasizing the necessity of licensure and prohibition of fraudulent practices. Plaintiffs’ allegations that Defendants operated unlicensed or fraudulently managed medical corporations and submitted improper claims were found to raise serious questions under both federal and state law. The procedural history and unopposed motion supported granting the requested relief.

CONCLUSION

The court granted Plaintiffs’ motion for a preliminary injunction in its entirety, staying pending No Fault arbitrations and state court litigation against Plaintiffs and enjoining Defendants from initiating new proceedings during the pendency of the action. The decision underscores the importance of compliance with New York’s No Fault laws and the legal consequences for fraudulent or unlicensed conduct in the insurance and medical services context.

Plaintiffs’ motion for a preliminary injunction was granted.

ZALMA OPINION

The “No Fault Law” was created to avoid litigation, make benefits available promptly and avoid fraud. Unfortunately, it created a cottage industry for fraud perpetrators who created fake medical bills to obtain the maximum recovery for people who were uninjured and for health care providers who had no morals nor a willingness to follow the law. Allstate, and other insurers are using injunctions to take the profit out of the fraud since the authorities have failed to prosecute the scofflaws.

(c) 2026 Barry Zalma & ClaimSchool, Inc.

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00:07:08
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May 26, 2026
He Who Acts as His Own Lawyer Has an Idiot for a Client

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 ...

00:08:55
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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 ...

00:08:27
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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 ...

00:08:02
19 hours ago
Zalma’s Insurance Fraud Letter – June 15, 2026

THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL

Posted on June 15, 2026 by Barry Zalma

ZIFL – Volume 30, Issue 12

June 15, 2026

Post number 5372

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:

Go to Jail, Do Not Pass Go

Arsonist Who Tried to Defraud Insurer Failed to Avoid Jail

Arson is a Violent and Dangerous Crime Deserving Serious Punishment

The People of the State of New York v. Zef Gjurashaj, 2026 NY Slip Op 03320, No. 2023-03675, Ind. No. 70463/21, Supreme Court of New York, Second Department (May 27, 2026) the defendant owned a restaurant that was destroyed by fire on September 6, 2017. Prosecutors alleged that he and a codefendant conspired to intentionally set the fire in order ...

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19 hours ago
Zalma’s Insurance Fraud Letter – June 15, 2026

THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL

Posted on June 15, 2026 by Barry Zalma

ZIFL – Volume 30, Issue 12

June 15, 2026

Post number 5372

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:

Go to Jail, Do Not Pass Go

Arsonist Who Tried to Defraud Insurer Failed to Avoid Jail

Arson is a Violent and Dangerous Crime Deserving Serious Punishment

The People of the State of New York v. Zef Gjurashaj, 2026 NY Slip Op 03320, No. 2023-03675, Ind. No. 70463/21, Supreme Court of New York, Second Department (May 27, 2026) the defendant owned a restaurant that was destroyed by fire on September 6, 2017. Prosecutors alleged that he and a codefendant conspired to intentionally set the fire in order ...

post photo preview
20 hours ago
Physician’s Malpractice Insurance not Available When License Revoked

Applicant for Insurance is Obligated to Advise Insurer in Material Changes After Application Was Signed

Post number 5371

Read the full article at https://www.linkedin.com/pulse/physicians-malpractice-insurance-available-when-zalma-esq-cfe-fmpxc and https://zalma.com/blog.

Doctor Criminally Charged and License Suspended After Application Signed had Policy Rescinded for Failure to Advise Insurer of Change

In Xiang (Sean) Yuan, M.D. v. Positive Physicians Insurance Company, No. 1821 EDA 2025, No. J-A08033-26, Superior Court of Pennsylvania (May 29, 2026) Dr. Xiang (Sean) Yuan, a physician, sought renewal of his professional liability insurance policy with Positive Physicians Insurance Company (PPIC) in June 2020 and again in May 2021.

In the June 2020 renewal application, he answered “no” to questions asking whether he knew of any circumstances that might lead to a professional liability claim.

Two days after signing the 2020 renewal application, Dr. Yuan was charged with 36 criminal offenses, and...

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