Zalma’s Insurance Fraud Letter – August 15, 2026
Posted on August 17, 2026 by Barry Zalma
ZIFL Volume 30, Issue 15, Subscribe to ZIFL Here
THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
Zalma’s Insurance Fraud Letter (ZIFL) continues its 30th year of publication dedicated to those involved in educing 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:
New Charges and Rewards Announced for the Capture and/or Conviction of Senior Leaders of Notorious Mexican Cartel
More than $100 Million Offered for Information Leading to the Arrests and/or Convictions of Eight CJNG Fugitives
Reward some photos below were taken from wanted posters of the eight CJNG fugitives that can be found here
Read the full article and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-08-15-2026.pdf
Health Insurance Fraud Convictions
New Mexico Woman Pleads Guilty to $4M Medicaid Fraud
Dorothea Irving, 47, of Farmington, New Mexico, woman pleaded guilty to working with a non-emergency medical transport (NEMT) company to submit millions of dollars in false and fraudulent claims to New Mexico Medicaid for ineligible and non-existent trips to medical appointments.
Read the full article and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-08-15-2026.pdf
Bad Faith Suit Fails After Insurer Declares Policy Void
State Farm Must Try Breach of Contract Claim Only
Breach of Condition is Ground to Deny Claim and Void Policy
In Arutyun Darakchyan v. State Fann General Insurance Company et al., No. 2:25-cv-03880-CAS-AJRx, United States District Court, C.D. California (August 11, 2026) Plaintiff Arutyun Darakchyan sued State Farm General Insurance Company after State Farm denied his homeowners burglary claim for losses allegedly sustained at his Tarzana residence.
Plaintiff reported that burglars entered through a kitchen window while he and his family were away, claimed stolen property totaling more than $83,000, and submitted proof-of-loss materials, inventory lists, photos, alarm records, phone records, and later appeared for an examination under oath.
Read the full article and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-08-15-2026.pdf
Guilty of Misprison of a Felony Admitted by Owner of Insurers
Second Trial of Coram Nobis Relief Fails
Coram Nobis is an Extraordinary Remedy
In United States Of America v. David Judd Disiere, Criminal Action No. 99-151-SDD-SDJ, United States District Court, M.D. Louisiana (August 10, 2026 David Judd Disiere was convicted in 2000 after pleading guilty to misprision of a felony under 18 U.S.C. § 4 in connection with allegations involving a scheme to influence the resolution of an investigation into insurance companies he owned.
Read the full article and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-08-15-2026.pdf
Other Than Health Insurance Fraud Cases
Canadian Man Pleads Guilty to Hacking U.S. Cloud Storage Provider and Extorting Its Customers for Millions
Connor Riley Moucka, 26, of Kitchener, Ontario, pleaded guilty to a widespread computer hacking conspiracy that resulted in the compromise of over 165 victim organizations, the theft of billions of sensitive customer records and the extortion of numerous victims.
Read the full article and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-08-15-2026.pdf
It Doesn’t Pay to Lie in an Application for Insurance
Rescission for Material Misrepresentation
An Insurer May Rescind An Insurance Policy Where The Applicant Made A Material Misrepresentation In The Application.
In Union Mutual Fire Insurance Company v. 844 Knickerbocker, LLC, et al. No. 2024-10359, Index No. 602824/22, 2026 NY Slip Op 04789, Supreme Court of New York, Second Department (July 29, 2026) Union Mutual Fire Insurance Company issued commercial insurance policies to 844 Knickerbocker, LLC, and Sanjaya Mallick based on applications stating that the insured property contained two apartment units. After an underlying personal injury action was filed, Union Mutual determined that the property actually contained three apartment units and rescinded the policies on the ground that the defendants had made a material misrepresentation in the applications.
Read the full article and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-08-15-2026.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.
[email protected], http://www.zalma.com, http://zalma.com/blog Subscribe to “Excellence in Claims Handling” at href=”https://barryzalma.substack.com/subscribe.”>
Read the full article and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-08-15-2026.pdf
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...
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 ...
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 ...
Payment of Fines & Completion of Probation Reinstates Right to Vote
Post 4576
Posted on November 5, 2026 by Barry Zalma
To Restore Voting Rights The Felon Must Pay Fines of $546.00
In Florida Supreme Court Mediator Ethics Advisory Committee, ETH F-26-377, No. F-26-377 (October 29, 2026) citizen unnamed and to Ron Desantis Governor, Cord Byrd the Secretary of State Florida Division of Elections provided an advisory opinion to a convicted felon about his right to vote:
To: [redacted] We received your request for an advisory opinion. You indicate that you have one or more felony convictions and request whether you are eligible to vote, including whether you have any outstanding legal financial obligations under section 98.0751, Florida Statutes, and, if so, a statement of the amount that must be paid to make you eligible to vote, and an explanation of how the amount was calculated.
The Division hereby responds to your request pursuant to its legal authority under section 106.23(2), Florida Statutes, and Florida ...
Administrative Review Permits the Agency to Apply its Expertise
Post 4574
In Erwin Jordan Castro Valdez v. Warden, Otay Mesa Detention Center, No. 26-cv-06147-BAS-JLB, United States District Court, S.D. California (October 30, 2026) Castro Valdez, a Cuban national paroled into the United States, was arrested on June 23, 2026, for alleged insurance fraud, grand theft, and making a false report to law enforcement. In his first habeas action, the district court ordered a bond hearing within fourteen days to determine whether the changed circumstances justified revoking his parole.
An Immigration Judge subsequently denied bond because of his pending state criminal case. Castro Valdez filed a second petition under 28 U.S.C. § 2241, challenging that determination and requesting immediate release without first appealing to the Board of Immigration Appeals (BIA).
LAW
According to the supplied text, § 2241 does not expressly require administrative exhaustion, but courts impose exhaustion as a prudential requirement. ...
Insured’s Ordered to Pay Insurer for Fraud by the Insureds
Post 4573
Posted on November 3, 2026 by Barry Zalma
In The Prudential Insurance Company Of America v. Carol Gardina and George Gardina, No. 6:23-cv-1125-JSS-DCI, United States District Court, M.D. Florida, Orlando Division (October 22, 2026).
THE JURY TRIAL AND VERDICT
Plaintiff sued Defendants for numerous causes of action stemming from its allegations that Defendants fraudulently collected benefits under their long-term care insurance policies. Plaintiff's case proceeded to a nine-day jury trial, after which the jury found Defendants liable for fraudulent misrepresentation, fraudulent concealment, and civil conspiracy.
The jury also found Defendant Carol Gardina liable to Plaintiff for $1,930,129 in compensatory damages and Defendant George Gardina liable to Plaintiff for $12,496 in compensatory damages and $20 in punitive damages. Thereafter, the court entered judgment in Plaintiff's favor and awarded Plaintiff $1,930,129 in compensatory damages from...