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August 04, 2026
Insurance Fraud is a Violent Crime

Disbarment of Defendant Admissible as Intrinsic Evidence of Fraud Case

Murder of Witness to Staged Auto Accident is Inadmissible in Fraud Case
Posted on August 4, 2026 by Barry Zalma

Post 5416

In United States Of America v. Ryan Harris, et al., Criminal Action No. 24-105, United States District Court, E.D. Louisiana (July 23, 2026) the defendants were charged in connection with an alleged staged-automobile-collision insurance fraud scheme in the New Orleans area and later crimes arising from the murder of cooperating witness Cornelius Garrison.

LAW:

Federal Rule of Evidence 404(b) generally bars other-act evidence offered to prove propensity but allows such evidence for non-character purposes if admissible.

DISCUSSION/ANALYSIS:

The Court held that Alfortish’s disbarment was intrinsic because it explained why he allegedly funneled staged-accident clients to Vanessa Motta rather than litigating the cases himself, thereby illuminating the structure of the mail-and-wire-fraud conspiracy.

CONCLUSION:

The Court ruled that evidence of Alfortish’s 2011 conviction and Parker’s 2010 arrest for a 2005 murder and arson is not admissible at trial.

Applying the same law as above, the Court agreed. The Court found that evidence of Alfortish’s disbarment is intrinsic to the charged offenses because it explains why Alfortish did not litigate the staged collision cases and instead gave them to his fiancé and co-conspirator, Vanessa Motta. It is “part and parcel” with the conspiracy.

For the foregoing reasons evidence regarding Sean Alfortish’s 2011 conviction and evidence regarding Parker’s 2010 arrest for a 2005 murder and arson are not admissible at trial as intrinsic evidence while that evidence regarding Alfortish’s disbarment and evidence that Leon Parker physically abused the mother of co-conspirator, Ryan Harris, are admissible at trial as intrinsic evidence.

ZALMA OPINION

I am disgusted by people who claim insurance fraud is not a violent crime. It is, and this case makes it clear, that to protect their staged accident scheme the criminal participants in the scheme conspired to a murdered a witness. The intrinsic evidence of the staged accident crime is admissible as it the murder, a crime that is the most violent of all crimes in the penal codes and should be prosecuted separately rather than as part of an insurance fraud case.

(c) 2026 Barry Zalma & ClaimSchool, Inc.
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September 18, 2026
Expert May Only Testify to What Experience Supports

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...

00:03:10
September 17, 2026
Convicted on 29 Tax-Refund-Fraud Counts

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 ...

00:05:23
September 14, 2026
Court Enforces Fifth Amendment & Refuses to Compel Answers

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 ...

00:05:14
39 minutes ago
Habeas Relief Requires Cognizable Responses to State Defenses

Claims of Res Judicata and Procedural Default Defeats Habeas

Post 5543

Posted on November 13, 2026 by Barry Zalma

A Health Insurance Fraud Conviction Rested On Knowingly Submitting Materially False Or Misleading Claim Information With Specific Intent To Defraud.

A Health Insurance Fraud Conviction Rested On Knowingly Submitting Materially False Or Misleading Claim Information With Specific Intent To Defraud.

In Tariq Mustafa Abdulaziz v. Commissioner Of Correction, No. CV 26-5002432-S, Superior Court of Connecticut, Judicial District of Tolland, Habeas Docket (October 29, 2026) Tariq Mustafa Abdulaziz submitted 114 claims for in-home, face-to-face services purportedly provided to thirty program participants during four one-week periods. The department paid Neurostrategies, Inc., $13,650.

FACTS

The defendant waived his right to a jury trial and elected a trial to the court, D'Addabbo, J. Trial occurred over the course of eight days in August, 2022. The state presented testimony from ten witnesses and introduced thirty-three exhibits into ...

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November 12, 2026
Common Interest Doctrine Protects Confidentiality

Theft of Confidential Information

Post 4581

Posted on November 12, 2026 by Barry Zalma

In People Center, Inc. v. Deel, Inc., et al., No. 25-cv-02576-CRB (LJC), United States District Court, N.D. California (November 7, 2026) People Center, doing business as Rippling, and Deel compete in payroll and human-resource management software. Rippling alleges that Deel and its executives recruited Rippling employee Keith O’Brien, based in Ireland, to disclose confidential information and trade secrets.
THE IRISH SUIT

Rippling sued O’Brien in Ireland and Deel in the United States. O’Brien subsequently retained separate counsel, supplied an affidavit describing the alleged espionage, and entered into a Cooperation Agreement with Rippling. In exchange for his cooperation, Rippling agreed to provide financial assistance, indemnification, and conditional dismissal of the Irish proceedings. The agreement also permitted renewed proceedings or a monetary judgment upon a material breach.

The Irish proceedings against O’Brien were dismissed...

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November 11, 2026
After Dismissal Fraud Victim May Amend Complaint After Dismissal

A Proposed Amended Complaint That Includes New Factual Allegations to Remedy Pleading Deficiencies

Posted on November 11, 2026 by Barry Zalma
After Dismissal Fraud Victim May Amend Complaint After Dismissal
Post 4580

If A Proposed Amendment Is Not Clearly Futile, Then Denial Of Leave To Amend Is Improper

In John Hancock Life & Health Insurance Company v. Caring Connections LLC, Arthur Feldheim, and Blime a/k/a Vera Feldheim, Civ. No. 25-7574 (MAS)(JBD), United States District Court, D. New Jersey (November 6, 2026) John Hancock sued Caring Connections LLC, Arthur Feldheim, and Blime a/k/a Vera Feldheim on June 5, 2025, asserting thirteen claims, including fraud, breach of contract, and aiding and abetting fraud.

On March 26, 2026, this Court entered an order granting Caring Connections’ motion to dismiss and granting in part and denying in part the Feldheims’ motion to dismiss. The dismissed claims were dismissed without prejudice, and John Hancock timely sought leave to amend.

They also argued that the New ...

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