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September 16, 2026
Zalma’s Insurance Fraud Letter –September 15, 2026

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:

Long Island Rep. Laura Gillen Is Taking Aim At Criminals Who Have Been Caught Staging Car Accidents.
Time for a Federal Crime of Insurance Fraud

The accidents may be shams, but the felonies would be real. On Thursday, Gillen (D-NY) introduced the Stop Auto Fraud Act of 2026, which would make the “crash for cash” practice a federal offense punishable by up to 10 years behind bars, with sentence enhancements for smash-ups causing injury or death.

Rep. Laura Gillen is hoping her bipartisan bill will become law to give prosecutors a federal crime to prosecute cash for crash perpetrators.

Sam Whitfield, APCIA's senior vice president of federal government relations, tied the bill directly to rising premiums.

Read the full article and the full issue of ZIFL in pdf format here.

A Charge of Insurance Fraud is not Grounds for Deportation

HABEAS CORPUS PETITION GRANTED

Over Staying Visa & Charge of Insurance Fraud Still Entitled to Habeas Relief and a Bond Hearing

In Hernan Guillermo Palomino-Crespo v. Warden, Glades County Detention Center et al., No. 2:26-cv-02322-SPC-NPM, United States District Court, M.D. Florida, Fort Myers Division (August 26, 2026) Hernan Guillermo Palomino-Crespo’s Amended Petition for Writ of Habeas Corpus, the government’s response and Palomino-Crespo’s reply.

Read the full article and the full issue of ZIFL in pdf format here.

Sentence Set by Extent of Crime

Crime Requires 121-151 Months of Imprisonment 

Mr. Baiyewu Is Liable For The Loss Resulting From Acts Directly Attributable To Him And For The Loss Resulting From The Reasonably Foreseeable Acts Of Others Taken In Furtherance of the Criminal Activity

In United States Of America v. Oluwasegun Baiyewu, CRIMINAL No. 21-395 (RAM), United States District Court, D. Puerto Rico (August 26, 2026) the court dealt with a case after on October 20, 2021, a grand jury in the District of Puerto Rico returned a single-count Indictment charging Mr. Baiyewu with conspiracy to commit money laundering, in violation of 18 U.S.C. § 1956(h). About a year and a half later, on March 31, 2023, a grand jury returned a single-count Superseding Indictment charging Mr. Baiyewu and four co-defendants with conspiracy to commit money laundering, in violation of 18 U.S.C.

Read the full article and the full issue of ZIFL in pdf format here.

I Remember 25 Years Ago

Why I Will Never Forget

If My Daughter Started School a Week Later I Would Have Been the Falling Man on September 11, 2001

My youngest daughter had signed up for a semester at the University of New York in the small town of Plattsburgh, New York. My wife, my daughter and I decided to make the trip to New York to be a holiday starting in Washington D.C. and drive up the East Coast to show her the country.

Read the full article and the full issue of ZIFL in pdf format here.

Health Insurance Fraud Convictions

Ohio State University Agrees to $2.1M Settlement to Resolve Allegations that it Failed to Disclose Employees’ Ties to the People’s Republic of China in Applications for Federal Research Funding

Ohio State University (OSU), a public university in Columbus, Ohio, agreed to pay a total of $2,100,000 to resolve civil allegations that it failed to disclose OSU employees’ affiliations with and support from the People’s Republic of China (PRC) in connection with federal research funding.

Read the full article and the full issue of ZIFL in pdf format here.

The Fight Against Fraud Continues to Grow

U.S. Attorneys and Department of Justice Join Departments of Transportation and Homeland Security and White House Fraud Task Force to Launch Historic Interagency Effort to Crack Down on Fraud in Trucking Industry

Read the full article and the full issue of ZIFL in pdf format here.

Other Than Health Insurance Fraud Cases

Michigan Man Pleads Guilty in $7M Tax Fraud Scheme

Rodney Underwood, of Detroit, prepared and filed with the IRS more than 200 nearly identically false tax returns on behalf of clients from various locations in Detroit. Underwood, a Michigan man pleaded guilty to filing a false claim in connection with his $7 million scheme to defraud the IRS.

Read the full article and the full issue of ZIFL in pdf format here.

NC Roofers Caught in Farm Bureau’s Sting Sentenced to Probation, Restitution

Two brothers caught in a sting operation orchestrated by North Carolina Farm Bureau Insurance and state regulators have been sentenced to restitution and community service after pleading guilty to deliberately damaging roofs in North Carolina.

Read the full article and the full issue of ZIFL in pdf format here.

McClenny Moseley & Associates Former Attorney Charged In Alleged Ida Insurance Scheme Exposed By WWL

Five Years After Ida, the First Arrest in the McClenney, Mosely & Associates Scheme, A Former New Orleans Attorney Faces A Federal Charge Tied To An Alleged Scheme Involving Storm Insurance Claims.

Litigation Finance Disclosure Rule In Louisiana Expands Transparency Push In Us Courts

Read the full article and the full issue of ZIFL in pdf format here.

2026 California Fraud Investigation

The 2026 California fraud investigation refers to a federal probe initiated by the Trump administration into alleged fraud, waste, and abuse in California's social services and child care programs under Governor Gavin Newsom, publicly announced by President Donald Trump on social media on January 6, 2026.[1][2] Trump described the effort as targeting a state "more corrupt than Minnesota," drawing parallels to recent scandals uncovered in that state involving similar programs.[3][1] In conjunction with the announcement, the Department of Health and Human Services froze approximately $10 billion in federal child care funding to California and four other Democratic-led states, citing evidence of fraudulent activities in program administration.[4][5] The investigation builds on prior federal scrutiny of California's spending practices and has prompted responses from state officials, who have challenged the moves while welcoming probes into potential irregularities.

Barry Zalma, Esq., CFE

Barry Zalma, Inc., 4441 Sepulveda Boulevard, CULVER CITY CA 90230-4847, 310-390-4455, http://zalma.com/blog/wp-content/uploads/2026/09/ZIFL-09-15-2026.pdf

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Videos
Posts
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
September 25, 2026
Unwise for a Appellant to Represent Himself.

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 ...

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September 25, 2026
Unwise for a Appellant to Represent Himself.

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,...

September 24, 2026
Restitution Sentence Affirmed

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 ...

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