THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
Posted on June 1, 2026 by Barry Zalma
ZIFL – Volume 30, Issue 11 – June 1, 2026
Post number 5361
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:
Arson for Profit is a Violent Crime
Court Reporter’s Failure Causes Challenge to Conviction
Conviction for Murder by Arson Survives
In The People v. Joseph A. Meyers, 2026 NY Slip Op 03261, No. 44, New York Court of Appeals (May 26, 2026) both Mr. and Mrs. Meyers were indicted on multiple charges of murder, arson and fraud.
Read the full article and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-06-01-2026.pdf
He Who Acts as His Own Lawyer Has an Idiot for a Client
Arsonist Tried To Represent Himself, Failed, and Sought Habeas Relief
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.
Read the full article and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-06-01-2026.pdf
MORE MCCLENNY MOSELEY & ASSOCIATES ISSUES
This is ZIFL’s forty-fifth installment of the saga of McClenny, Moseley & Associates and its problems with the federal courts in the State of Louisiana and what appears to be an effort to profit from what some Magistrate and District judges indicate may be criminal conduct to profit from insurance claims relating to hurricane damage to the public of the state of Louisiana. This is truly becoming a never-ending story.
Note that the attorneys for the plaintiffs are the plaintiffs Jason Joy & Associates, PLLC d/b/a Jason.
Read the full article and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-06-01-2026.pdf
Proactive Insurer Makes a Fraudster Pay
Defaulting Fraud Perpetrator Lets Insurer Defeat Fraud
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)
Read the full article and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-06-01-2026.pdf.
Health Insurance Fraud Convictions
Pharmacy Technician Pleads Guilty to $5.6M Health Care Fraud Scheme and Illegal Distribution of Oxycodone
Ali Naserdean, 32, of Dearborn Heights, Michigan pleaded guilty yesterday to defrauding health care benefit programs, including Medicare and Medicaid, by billing for prescription medications that he never dispensed and providing unlawful prescriptions of oxycodone to drug traffickers in exchange for cash.
Naserdean pleaded guilty to conspiracy to commit health care fraud and possession with intent to illegally distribute oxycodone.
Read the full article, dozens of convictions, and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-06-01-2026.pdf.
Jury Sides With Insurers, Finding Takeda Pharmaceutical Liable for $885 Million in Damages
Takeda Pharmaceutical was found liable for causing about $885 million in damages by delaying a generic version of its constipation drug Amitiza through an anticompetitive scheme.
Read the full article and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-06-01-2026.pdf
Insurers & The Government Work Together to Defeat Fraud
Insurer Fights Back Against No-Fault Clinic Mills
Fraud Doesn’t Pay When Insurers Fight Back
Other Than Health Insurance Fraud Cases
Utah Jury Convicts Business Owners of Fraud after Victims Were Scammed More than $30M
After a five-week trial, a federal jury in Salt Lake City returned a guilty verdict against multiple defendants for their participation in a nationwide scheme to defraud victims out of more than $30,000,000 by inducing them to invest in Noah’s Event Centers.
Read the full article plus multiple convictions and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-06-01-2026.pdf
Insurance Attorneys Turn the Defense of a $1M Hail Claim into Nearly $2M Suit for Contractor Interference
What began as an appraisal controlled by a contractor working against Church Mutual Insurance Company on a $1 million-plus claim dispute turned into an award of $115,000 for the church, $282,000 for fraud to the carrier and awarded $823,000 in punitive damages. against a contractor because a jury found the contractor intentionally interfered with the insurance contract and caused the litigation.
Read the full article and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/05/ZIFL-06-01-2026.pdf
Barry Zalma, Barry Zalma, Inc., 4441 Sepulveda Boulevard, CULVER CITY CA 90230-4847, 310-390-4455.
Barry Zalma, Esq., CFE, now limits his practice to service as an insurance consultant specializing in insurance coverage, insurance claims handling, insurance bad faith and insurance fraud almost equally for insurers and policyholders. He also serves as an arbitrator or mediator for insurance related disputes. Subscribe to Excellence in Claims Handling at https://barryzalma.substack.com/welcome.
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 ...
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 ...
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 ...
Competing Inferences About Intent or Falsity Defeats Summary Judgment
Post number 5360
Dispute Over Material Facts Makes Summary Judgment Impossible
Read the full article at https://www.linkedin.com/pulse/dispute-over-two-claims-must-go-trial-barry-zalma-esq-cfe-ds59c and at https://zalma.com/blog plus more than 5350 posts.
In Darlene Mendoza Gonzales v. Safeco Insurance Company Of America, No. 2:24-cv-01832-RAJ, United States District Court, W.D. Washington, Seattle (May 22, 2026) Plaintiff Darlene Mendoza Gonzales owned a home in Tacoma, Washington insured under a Safeco homeowner’s policy.
FACTUAL BACKGROUND
For the second loss, Gonzales retained Pacific Public Adjusters (PPA), which submitted repair estimates substantially higher than Safeco’s estimate.
LAW – SUMMARY JUDGMENT STANDARD
Summary judgment is appropriate only where there is no genuine dispute of material fact and the moving party is entitled to judgment as a matter of law under Rule 56. Courts do not weigh evidence or resolve credibility ...
Was Insurance Fraud Attempted to Avoid Paying Child Support
No Matter How Contentious Divorce Seldom Charges the Parties with Fraud
Post number 5358
In Katherine Jane Macdonald v. Bryce Inglis Macdonald v. Mckenzie Cronk, LLC, and Denison Cronk, LLC, No. COA24-759, Court of Appeals of North Carolina (May 6, 2026).
The marital estate included multiple real properties, safe deposit boxes, insurance proceeds, rental income, retirement accounts, and two LLCs — Denison Cronk, LLC and McKenzie Cronk, LLC (Patio Playground).
FACTS
The court concluded that Wife’s actions “were undertaken knowingly and voluntarily to conceal income for the Patio Playground and in an effort to conceal potential insurance fraud.”
On the insurance proceeds, she claimed that because the checks were deposited into marital accounts, the court could not find she personally “received” them.
Law
Equitable distribution orders are reviewed to determine whether the findings are supported by competent evidence and whether ...
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 ...