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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August 18, 2026
Attempted Fraud on a Court to Avoid a Ticket Failed

Not Proper To Present False Evidence to a District Judge

Posted on August 18, 2026 by Barry Zalma

Post 5427
Lie to a Judge to Avoid a Fine Can Find You in Jail

In United States Of America v. Gary Rains, Criminal No. 1:26po25, United States District Court, W.D. Virginia, Abingdon Division (August 14, 2026) Gary Rains, (“Rains”), appeared before the court for an initial appearance on a petty offense violation on April 1, 2026.

At that time, Rains pleaded guilty to a violation of 36 C.F.R. § 4.2(b), incorporating Kentucky Revised Statute § 304.99-060, for having no vehicle insurance at the time of a traffic stop on December 21, 2025.

The USDC convicted Rains of the offense and imposed a fine of $500.00 and a mandatory special assessment of $10.00. Rains moved to Vacate Judgment.

In his Motion, Rains states that he now has found his insurance card showing that he did, in fact, have insurance coverage on the date the violation notice was issued. In support of his Motion, Rains attached a State Farm Mutual Automobile Insurance Company, insurance card.

Brooks provided Ranger Shepherd information showing that Rains had automobile insurance on a 2004 Toyota Prerunner with an inception date of August 29, 2025. However, Brooks provided further information that this insurance was subsequently terminated on November 27, 2025.

Given Rains’s action of purchasing insurance on the same vehicle with a different insurance company, which would overlap the State Farm policy by approximately two months, the court was unable to find credible Rains’s claim that he had insurance with State Farm on the date of the violation.

Based on Rains’s knowing and voluntary guilty plea, the information provided by State Farm representative Brooks that Rains’s coverage was terminated on November 27, 2025.

It was ORDERED that Rains’s Motion to Vacate Judgment, was DENIED.

ZALMA OPINION

This is not a major case. That it was reported at all was amazing. To avoid a $500.00 fine Mr. Raines created false insurance records to set aside the $500 fine to which he had pleaded guilty. What he did was attempt a fraud on the court. That attempt was a criminal act and should have been referred to the DOJ. States require people to have automobile insurance to operate on the roads. Raines failed to do so, was cited, convicted and fined. He then created false documents to reverse the judgment and with false documents. The judge recognized the fraud and denied his motion.

(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
October 19, 2026
Plaintiff’s Reading of the Policy is Plaintiff’s Reasonable Allegations Posted on October 19, 2026 by Barry Zalma CLASS ACTION THAT STATES A SIMPLE CLEAR AND PLAUSIBLE CAUSE OF ACTION SURVIVES Post 4868 In Sheila Marino v. Farmers New World Life Insura

Plaintiff’s Reading of the Policy is Plaintiff’s Reasonable Allegations

Posted on October 19, 2026 by Barry Zalma

Post 4868

CLASS ACTION THAT STATES A SIMPLE CLEAR AND PLAUSIBLE CAUSE OF ACTION SURVIVES

In Sheila Marino v. Farmers New World Life Insurance Company, No. 2:25-cv-02200-JNW, United States District Court, W.D. Washington, Seattle (October 13, 2026) defendant Farmers New World Life Insurance Company’s (“FNWL”) moved to dismiss Plaintiff Sheila Marino’s putative class action involving flexible universal life insurance.

Marino filed a putative class action in King County Superior Court alleging: (1) breach of contract, (2) breach of the implied covenant of good faith and fair dealing, and (3) violation of the Washington Consumer Protection Act (CPA).

She pleaded two theories: an “overcharge” theory and an “underpayment of interest” theory asked the Court to take judicial notice of historical Federal Funds Effective Rates.

THE LAW

Pleading Standard.

To survive a Rule 12(b)(6) motion, a ...

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October 22, 2026
John Madden and The US Patent and Trademark Office

Blockchain Fraud Detection Loses Protection

Posted on October 22, 2026 by Barry Zalma

John Earl Madden (April 10, 1936 – December 28, 2021) was an American Professional Football Coach and Sports Commentator in the National Football League Seeking Patent & Trademark Protection

BLOCKCHAIN FRAUD

Mr. Madden was more than football. He was working to establish a program called “Fraud Protection Systems, Methods, and Computer Programs for Blockchain Financial Transactions.”

In Ex parte John Madden, Appeal 2026-001497, Application 18/495,506, Technology Center 3600, United States Patent and Trademark Office, Patent Trial and Appeal Board (October 14, 2026)

The Examiner rejected claims several numbered claims under 35 U.S.C. § 101 as directed to an abstract idea without significantly more.

THE LAW

Section 101 makes patentable any new and useful process, machine, manufacture, or composition of matter.Laws of nature, natural phenomena, and abstract ideas are implicitly excluded.

THE PATENT TRIAL AND ...

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October 21, 2026
Supervisory Officials are not Individually Liable

Sovereign Immunity Defeats Suit Against Police Officers

Post 4866

Posted on October 21, 2026 by Barry Zalma

In Chad Lightfoot, et al. v. Progressive Direct Insurance Company, et al., Civil Action No. 26-434, United States District Court, E.D. Louisiana (October 9, 2026) Chad Lightfoot was involved in an Orleans Parish automobile accident in 2011 and filed claims with several insurers, including Progressive.

After a related civil dispute, Progressive counsel allegedly submitted a false affidavit stating that Lightfoot had fraudulently received a $50,000 payment. A New Orleans police detective relied on the affidavit to obtain an arrest warrant, and Louisiana State Police Lieutenant Alan Arcana allegedly reported that Lightfoot had received the payment. Lightfoot was arrested in 2015 and charged with theft, insurance fraud, and perjury.

Plaintiffs alleged that no record of the payment existed and that the criminal charges were dismissed on October 15, 2024.

Lightfoot and Geralyn Hawkins filed suit in October 2025 and ...

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