Barry Zalma, Inc.

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11/10/2026

Represent Yourself – Even With Help from the Court – You Will Fail

Self Represented Insureds Should Never Attempt to Get a Court to Assist an Attempted Fraud Post 4579 Financial Records May Reasonably Be Requested When The Insurer Has A Good-Faith Concern About Possible Fraud. In Ousmane Diouf and Bouya Dieye v. Liberty Mutual Personal Insurance Company, Civil Action No. 26-2572-TDC, United States District Court, D. Maryland (October 28, 2026) a fire damaged the plaintiffs’ home and personal property on or about December 12, 2025....

Self Represented Insureds Should Never Attempt to Get a Court to Assist an Attempted Fraud Post 4579 Financial Records May Reasonably Be Requested When The Insurer Has A Good-Faith Concern About Po…

11/09/2026

Excess Insurers May Face Declaratory Relief and Bad Faith Claims Before Coverage Attaches

Is Exhaustion Required to Seek Declaratory Relief From an Excess Insurer? Post 4578 In Fox Paine & Company, LLC, et al. v. Twin City Fire Insurance Company et al., S287404, 593 P.3d 832, 593 P.3d 838, 346 Cal.Rptr.3d 541, Supreme Court of California, (July 27, 2026) the Supreme Court noted that Insurance is sometimes procured in a series of layers, with an insured acquiring a primary insurance policy that provides an initial layer of coverage for loss or liability and an excess insurance policy or policies that provide additional coverage in the event the underlying coverage is exhausted....

Is Exhaustion Required to Seek Declaratory Relief From an Excess Insurer? Post 4578 In Fox Paine & Company, LLC, et al. v. Twin City Fire Insurance Company et al., S287404, 593 P.3d 832, 593 P.…

11/06/2026

When Judgment not Complete Appellate Jurisdiction Fails

When the District Court Dismissed the Counterclaims all of GEICO's Claims Remained So No Appellate Jurisdiction Post 4577 In Government Employees Insurance Company, et al v. Colin Clarke, M.D., No. 24-1611, United States Court of Appeals, Second Circuit (October 29, 2026) GEICO alleged that Colin Clarke, M.D., and Colin Clarke MD P.C. participated in a scheme to obtain fraudulent payments under New York’s no-fault automobile insurance system....

When the District Court Dismissed the Counterclaims all of GEICO’s Claims Remained So No Appellate Jurisdiction Post 4577 In Government Employees Insurance Company, et al v. Colin Clarke, M.…

11/05/2026

Convicted of Felony Fraud You Lose the Right to Vote

Payment of Fines & Completion of Probation Reinstates Right to Vote Post 4576 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:...

Payment of Fines & Completion of Probation Reinstates Right to Vote Post 4576 To Restore Voting Rights The Felon Must Pay Fines of $546.00 In Florida Supreme Court Mediator Ethics Advisory Comm…

11/04/2026

Failure of Immigrant to Exhaust Remedies Denies Bond

Castro Valdez Had an Available Administrative Appeal and Failed to Establish a Ground for Excusing Post 4574 Administrative Review Permits the Agency to Apply its Expertise 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....

Castro Valdez Had an Available Administrative Appeal and Failed to Establish a Ground for Excusing Post 4574 Administrative Review Permits the Agency to Apply its Expertise In Erwin Jordan Castro …

11/03/2026

Jury Found Prudential to be the Victim of Fraud

Insured's Ordered to Pay Insurer for Fraud by the Insureds Post 4573 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. ...

Insured’s Ordered to Pay Insurer for Fraud by the Insureds Post 4573 In The Prudential Insurance Company Of America v. Carol Gardina and George Gardina, No. 6:23-cv-1125-JSS-DCI, United State…

11/02/2026

Tales From the Fraud Files

A Virtual Lunch with Barry Zalma A Webinar "Tales From the Fraud Files" Join us on Tuesday, November 17, 2026, from 12:30 to 1:30 PM ET for a lively, informal lunch and learn during International Fraud Awareness Week (November 15-21). Veteran insurance claims expert Barry Zalma will share some of the wildest fraudulent claims from his long career, including schemes so brazen (and so badly planned) you’ll hardly believe they’re true....

A Virtual Lunch with Barry Zalma A Webinar “Tales From the Fraud Files” Join us on Tuesday, November 17, 2026, from 12:30 to 1:30 PM ET for a lively, informal lunch and learn during I…

11/02/2026

Zalma’s Insurance Fraud Letter – November 1, 2026

ZIFL – Volume 30, Issue 21 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 reducing 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…...

ZIFL – Volume 30, Issue 21 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 inv…

10/30/2026

A Place to find everything you need about insurance claims

The Insurance Claims Library for You If you need an Insurance Claims Consultant or Expert Witness: (c) 2026 Barry Zalma & ClaimSchool, Inc. Please tell your friends and colleagues about this blog and the videos and let them subscribe to the blog and the videos. Subscribe to my substack at Go to X ; Go to Barry Zalma videos at Rumble.com at Go to Barry Zalma on YouTube-

https://zalma.com/blog/a-place-to-find-everything-you-need-about-insurance-claims/

10/30/2026

A Place to Learn Everything You Need to Understand Insurance Claims

If you need an insurance Claims Consultant or Expert Witness Contact

If you need an insurance Claims Consultant or Expert Witness Contact

Address

4441 Sepulveda Boulevard
Culver City, CA
90230

Telephone

(310) 390-4455

Website

http://www.zalma.com/

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