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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August 27, 2026
Offer Made and Accepted Creates Enforceable Contract

Policy Limits Demand Accepted Settles Claim

Post 5434

Posted on August 26, 2026 by Barry Zalma

See the full video at https://lnkd.in/g-ZtsSgK and at https://lnkd.in/ghMBdYWR
A Contingent Offer Accepted Ends the Dispute

In Farmers Insurance Exchange, a California Reciprocal Insurance Exchange,  The Superior Court For The County Of San Bernardino, Kathleen Ann Wood, E087128, California Court of Appeals, (July 9, 2026) Farmers Insurance Exchange insured Doyle Archer under an automobile policy with bodily injury limits of $15,000 per person and $30,000 per accident.

FACTUAL BACKGROUND

Archer rear-ended Kathleen Ann Wood at a red light, causing Wood to assert a bodily injury claim against him. Wood’s counsel sent Farmers a pre-litigation settlement demand offering to resolve Wood’s claim for the available policy limits, stating that if the $100,000 demand exceeded the policy, the offer was for the policy limits.

Farmers timely responded in writing, agreed to pay Wood the $15,000 per-person policy limit, and provided the requested ...

00:08:28
August 26, 2026
Offer Made and Accepted Creates Enforceable Contract

Policy Limits Demand Accepted Settles Claim

Post 5434

Posted on August 26, 2026 by Barry Zalma

See the full video at https://lnkd.in/g-ZtsSgK and at https://lnkd.in/ghMBdYWR
A Contingent Offer Accepted Ends the Dispute

In Farmers Insurance Exchange, a California Reciprocal Insurance Exchange,  The Superior Court For The County Of San Bernardino, Kathleen Ann Wood, E087128, California Court of Appeals, (July 9, 2026) Farmers Insurance Exchange insured Doyle Archer under an automobile policy with bodily injury limits of $15,000 per person and $30,000 per accident.

FACTUAL BACKGROUND

Archer rear-ended Kathleen Ann Wood at a red light, causing Wood to assert a bodily injury claim against him. Wood’s counsel sent Farmers a pre-litigation settlement demand offering to resolve Wood’s claim for the available policy limits, stating that if the $100,000 demand exceeded the policy, the offer was for the policy limits.

Farmers timely responded in writing, agreed to pay Wood the $15,000 per-person policy limit, and provided the requested ...

00:08:28
July 22, 2026
The Real Cost of Fraud

The Largest Residential Burglary of All Time
Post 5407

Fraud & the Fear of Bad Faith Suits
Posted on July 22, 2026 by Barry Zalma

See the full video at https://lnkd.in/gWQQEySW and at https://lnkd.in/gyhdK6wv

This is a Fictionalized True Crime Story of Insurance Fraud explaining why Insurance Fraud is a “Heads I Win, Tails You Lose” situation for Insurers. The story is one of a collection designed to help 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.

This is a Fictionalized True Crime Story of Insurance Fraud explaining why Insurance Fraud is a “Heads I Win, Tails You Lose” situation for Insurers. The story is one of a collection designed to help 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.

After ...

00:12:33
4 hours ago
Failure to Plead a Facially Plausible Claim Requires Dismissal

Referral of Claims to its SIU Is Not Bad Faith

Post 5487

Posted on September 10, 2026 by Barry Zalma

In WIZ Collision, LLC, on behalf of itself and as assignee of Jawara Small, Chester Street LLC, and Aziz Brooks v. GEICO Corporation, No. 25-cv-4201 (KAM)(JAM), United States District Court, E.D. New York (August 28, 2026) Wiz Collision, a New York City auto-body shop, regularly repaired vehicles and submitted insurance claims for customers. It alleged that GEICO repeatedly approved claims and repairs, then referred certain claims to its Special Investigations Unit, stopped issuing payments, and delayed resolution despite ultimately finding no fraud.

Wiz Collision sued on its own behalf and as purported assignee of three customers, asserting contract, good-faith, consumer-protection, and injunctive claims. GEICO removed the case and moved to dismiss under Rule 12(b)(6).
LAW

Under Rule 12(b)(6), a complaint must plead facts supporting a facially plausible claim. Article III standing requires a concrete injury, ...

post photo preview
4 hours ago
Sentence Set by Extent of Crime

Crime Requires 121-151 Months of Imprisonment

Post 5486

Posted on September 9, 2026 by Barry Zalma

Mr. Baiyewu Is Liable For The Loss Resulting From Acts Directly Attributable To Him And For The Loss Resulting From The Reasonably Foreseeable Acts Of Others Taken In Furtherance of the Criminal Activity

In United States Of America v. Oluwasegun Baiyewu, CRIMINAL No. 21-395 (RAM), United States District Court, D. Puerto Rico (August 26, 2026) the court dealt with a case after on October 20, 2021, a grand jury in the District of Puerto Rico returned a single-count Indictment charging Mr. Baiyewu with conspiracy to commit money laundering, in violation of 18 U.S.C. § 1956(h). About a year and a half later, on March 31, 2023, a grand jury returned a single-count Superseding Indictment charging Mr. Baiyewu and four co-defendants with conspiracy to commit money laundering, in violation of 18 U.S.C.

CONVICTION

Baiyewu was convicted by a jury of conspiracy to commit money laundering under 18 U.S.C. § 1956(h). The charged conspiracy, ...

September 09, 2026
Sentence Set by Extent of Crime

Crime Requires 121-151 Months of Imprisonment

Post 5486

Posted on September 9, 2026 by Barry Zalma

Mr. Baiyewu Is Liable For The Loss Resulting From Acts Directly Attributable To Him And For The Loss Resulting From The Reasonably Foreseeable Acts Of Others Taken In Furtherance of the Criminal Activity

In United States Of America v. Oluwasegun Baiyewu, CRIMINAL No. 21-395 (RAM), United States District Court, D. Puerto Rico (August 26, 2026) the court dealt with a case after on October 20, 2021, a grand jury in the District of Puerto Rico returned a single-count Indictment charging Mr. Baiyewu with conspiracy to commit money laundering, in violation of 18 U.S.C. § 1956(h). About a year and a half later, on March 31, 2023, a grand jury returned a single-count Superseding Indictment charging Mr. Baiyewu and four co-defendants with conspiracy to commit money laundering, in violation of 18 U.S.C.

CONVICTION

Baiyewu was convicted by a jury of conspiracy to commit money laundering under 18 U.S.C. § 1956(h). The charged conspiracy, ...

post photo preview
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