ZIFL Volume 30, Issue 17
THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
Posted on September 1, 2026 by Barry Zalma
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:
Bad Faith Suit Fails
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.
Read the rest of the article and the full issue of ZIFL at http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-09-01-2026.pdf
AI-Enabled Fraud Tops List Of Emerging Claim Severity Risks, Survey Finds
AI-enabled fraud and data authenticity is the factor most likely to increase claim severity over the next three to five years, according to nearly a third, or 32%, of attendees surveyed at the 2026 RIMS conference by CorVel.
Read the rest of the article and the full issue of ZIFL http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-09-01-2026.pdf.
Department of Justice Announces Launch of National Fraud Detection Center
NFDC Opens with Widespread Collaboration with Inspectors General and Law Enforcement Agencies
Today, August 26, 2026, the U.S. Department of Justice announced the launch of the National Fraud Detection Center (NFDC), a prosecutor-led, multi-agency team designed to investigate the most harmful actors defrauding federal government programs, including illicit actors overseas and those operating fraud schemes across federal programs.
Read the rest of the article and the full issue of ZIFL here.
Health Insurance Fraud Convictions
Justice Department’s Fraud Division Announces Unprecedented Fraud Enforcement Actions
Press Release: Thursday, July 30, 2026
VP Vance’s Anti-Fraud Efforts are Going Strong: On April 7, the Department of Justice announced the creation of the National Fraud Enforcement Division (Fraud Division).
Read the rest of the article and the full issue of ZIFL http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-09-01-2026.pdf
A 23rd Person Has Been Sentenced To Prison for the $250 Million Feeding Our Future Scandal.
Abdinasir Mahamed Abshir, 34, of Lakeville, Minnesota, was sentenced to 78 months in prison for his role in a $250 million fraud scheme that exploited
Read the rest of the article and the full issue of ZIFL http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-09-01-2026.pdf.
Outstanding Refugee’ Award Winner Charged With Medicaid Fraud
Salman Ahmed Elmi, a Somali refugee who received Minnesota’s 2021 Outstanding Refugee Award for Entrepreneurship, has been charged with eight felonies tied to the operation of Reva Health.
Read the rest of the article and the full issue of ZIFL http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-09-01-2026.pdf
Phantom Pets, Real Fraud
On August 21, 2028 the City of London Police reported that it had arrested a man who fraudulently claimed more than £31,000 from multiple insurers by repeatedly reporting dogs as dead has been convicted following an investigation by the City of London Police’s Insurance Fraud Enforcement Department (IFED).
Robert Daniel Cretu, 40 from Liverpool was found guilty of fraud by 30 separate fraudulent pet insurance claims submitted to a number of insurers.
Read the rest of the article and the full issue of ZIFL http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-09-01-2026.pdf
Other Than Health Insurance Fraud Cases
Mississippi Man Pleads Guilty to Evading $2M in Taxes
Eric Brian Rosenberg, a Mississippi man, pleaded guilty August 19, 2026 to evading the payment of more than $2 million in federal income taxes.
Read the rest of the article and the full issue of ZIFL http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-09-01-2026.pdf
Auto Insurance Fraud Conviction Stands
Habeas Relief from an Insurance Fraud Conviction Based on an Incorrect Factual Determination Unavailable
In Bryce A. Nickelson v. Secretary, Department Of Corrections, No. 8:23-cv-1081-KKM-SPF, United States District Court, M.D. Florida, Tampa Division (August 17, 2026) Bryce Nickelson, a Florida prisoner, was convicted by a state jury of making a false and fraudulent insurance claim and sentenced to 92.55 months in prison.
Read the rest of the article and the full issue of ZIFL http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-09-01-2026.pdf
Department of Justice Announces Launch of National Fraud Detection Center
NFDC Opens with Widespread Collaboration with Inspectors General and Law Enforcement Agencies
Monday, August 24, 2026 a Press Release from the Office of Public Affairs
Read the rest of the article and the full issue of ZIFL http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-09-01-2026.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.
Read the full issue of ZIFL http://zalma.com/blog/wp-content/uploads/2026/08/ZIFL-09-01-2026.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 ...
Inadequately Briefed Issues Defeats Appeal
Post 4852
Issues on Appeal Must be Adequately Briefed
Posted on September 25, 2026 by Barry Zalma
In Emy Ojekwe v. Connecticut Transit District Consortium, No. AC 47389, Court of Appeals of Connecticut (September 22, 2026) Emy Ojekwe alleged that he was injured on September 24, 2020, while leaving a bus operated by Connecticut Transit District Consortium, doing business as Greater Bridgeport Transit Authority.
According to his complaint, the wheelchair ramp began to rise before he had fully exited, causing his wheelchair to fall backward and allegedly injuring several parts of his body and damaging the wheelchair. The defendant denied negligence and alleged comparative negligence. After a two-day jury trial in November 2023, the jury returned a defense verdict.
The trial court denied Ojekwe’s motion to set aside the verdict and for a new trial, and he appealed.
LAW
A trial court’s refusal to set aside a verdict because of counsel’s improper remarks is reviewed for abuse of ...
Inadequately Briefed Issues Defeats Appeal
Post 4852
Issues on Appeal Must be Adequately Briefed
Posted on September 25, 2026 by Barry Zalma
In Emy Ojekwe v. Connecticut Transit District Consortium, No. AC 47389, Court of Appeals of Connecticut (September 22, 2026) Emy Ojekwe alleged that he was injured on September 24, 2020, while leaving a bus operated by Connecticut Transit District Consortium, doing business as Greater Bridgeport Transit Authority.
According to his complaint, the wheelchair ramp began to rise before he had fully exited, causing his wheelchair to fall backward and allegedly injuring several parts of his body and damaging the wheelchair.
LAW
Refusal to set aside a verdict because of counsel’s improper remarks is reviewed for abuse of discretion.
Appellate claims receiving only cursory treatment, without record citations, supporting authority, or legal analysis, are inadequately briefed.
DISCUSSION
Improper opening remarks.
Defense counsel referred to Ojekwe’s national origin,...
Psychiatrist Who Was Convicted of Fraud Asked the First Circuit to Reduce his Punishment
Post 4851
Posted on September 24, 2026 by Barry Zalma
Fraud to Private and Public Health Insurers Doesn’t Pay
In United States v. Gustavo Kinrys, Nos. 24-1592, 24-1716, United States Court of Appeals, First Circuit (September 21, 2026) Gustavo Kinrys, a Massachusetts psychiatrist, submitted fraudulent claims to private and public health insurers from 2015 through 2018, including bills for more than 1,000 sessions when he or the purported patient was outside the country. When insurers requested supporting records, he delayed through a fictitious office manager and created false documentation.
A jury convicted Kinrys on fourteen counts. The district court imposed a 99-month sentence, calculated intended loss at slightly more than $19 million based on billed amounts, ordered $6,537,309.59 in restitution, and ordered $6,527,391.19 in forfeiture.
At sentencing, the district court calculated Kinrys’s base offense level to be ...
