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Federal court gavel with no-fault insurance billing documents — Yan Moshe RICO injunction and hospital closure timeline
No-Fault

Yan Moshe's RICO Paper Trail: No-Fault Fraud, Hospital Collapse, and the Cannabis Factory

By Jason Tenenbaum 8 min read

Key Takeaway

Yan Moshe has been sued nine times under federal RICO, obtained a 2020 GEICO injunction, collapsed a 152-year-old NJ hospital in 2025, and is now pursuing a cannabis grow facility. Full 2026 analysis.

This article is part of our ongoing no-fault coverage, with 290 published articles analyzing no-fault issues across New York State. Attorney Jason Tenenbaum brings 24+ years of hands-on experience to this analysis, drawing from his work on more than 1,000 appeals, over 100,000 no-fault cases, and recovery of over $100 million for clients throughout Nassau County, Suffolk County, Queens, Brooklyn, Manhattan, and the Bronx. For personalized legal advice about how these principles apply to your specific situation, contact our Long Island office at (516) 750-0595 for a free consultation.

Key Takeaways — Updated June 2026

  • 2020: GEICO obtained a federal RICO preliminary injunction against Yan Moshe in the Eastern District of New York. At the time of the ruling, Moshe had already been sued seven times by insurers for similar fraudulent billing schemes.
  • The injunction rested on eight specific court findings: straw ownership of medical facilities, identical treatment for patients with differing conditions, billing for out-of-state services, and facility fee overcharges in violation of the New Jersey fee schedule — among others.
  • The pattern compounds: By 2025-2026, major insurers had sued Moshe nine times under the federal RICO Act — for fraudulent billing, kickbacks, and using front owners to conceal his unlicensed control of medical practices.
  • 2018 surgical center shutdown: One of Moshe’s surgical centers was shut down by state inspectors after they found sterilization lapses that exposed hundreds of patients to infection risk.
  • January 2025: Moshe’s Hudson Regional Health (HRH) “rescued” 152-year-old Christ Hospital in Jersey City, rebranding it Heights University Hospital — assuring a bankruptcy court it had the funds to keep it running, promising $75–100 million in upgrades.
  • November 2025: HRH abruptly shut down most services, displacing tens of thousands of patients and leaving 699 employees facing layoffs without required WARN Act notice. HRH’s own certificate of need filing revealed the plan: redevelop the hospital land as residential and commercial space.
  • November 2025 (Secaucus): Moshe applied to rezone the former Channel 9/WWOR-TV building at 43 Meadowlands Parkway into a cannabis grow facility. The NJSEA approved the zoning change 15-0.
  • June 2026: The Secaucus Local Cannabis Control Board has not yet approved the final application. The pattern is ongoing.
  • Federal RICO is the sharpest tool in the no-fault defense arsenal. Treble damages, asset freezes, and enterprise-level reach make it the only remedy that actually threatens the business model. New York has no equivalent Civil RICO statute.

This article is part of our ongoing no-fault insurance coverage, with 273 published articles analyzing no-fault issues across New York State. Attorney Jason Tenenbaum brings 24+ years of hands-on experience to this analysis, including work on more than 1,000 appeals and over 100,000 no-fault cases. For a free consultation, call (516) 750-0595.

Quick Answer: Who Is Yan Moshe?

Yan Moshe is a New Jersey-based real estate developer and healthcare entrepreneur who became one of the largest players in the New York/New Jersey no-fault insurance ecosystem. Between 2007 and 2025, major insurers sued him nine times under the federal RICO Act for fraudulent billing schemes, kickbacks, and using straw licensees to conceal his unlicensed control of medical facilities. In 2020, GEICO obtained a federal RICO preliminary injunction against him in Geico v. Moshe, 20-cv-1098 (EDNY). In 2025, his hospital network collapsed a 152-year-old Jersey City institution in what investigators and community members say was a premeditated real estate play. In 2026, he is pursuing a large-scale cannabis grow facility in Secaucus, New Jersey. If you are dealing with no-fault billing from any entity connected to Moshe’s network, contact our office at (516) 750-0595.

The 2020 GEICO Injunction: Where the Federal Record Starts

Geico v. Moshe, 20-cv-1098 (EDNY 2020) is the anchor case — at least for those of us who watch the no-fault dockets. If you practice in this space, you already know what a preliminary injunction in a federal RICO case means. It is not a routine win. A federal court ordering a medical provider network to stop collecting on pending claims while litigation proceeds is the legal equivalent of a complete shutdown. It is the nuclear option.

This probably has to be every medical practice’s worst nightmare: provide services, send bills to the largest insurance payor in the market, and find yourself hit with a RICO complaint and a preliminary injunction. What makes it worse in the Moshe scenario is context the court felt compelled to put on the record: at the time of the 2020 injunction, Moshe had already been sued seven times by insurers alleging the exact same type of conduct. Seven times. This was not a first-time mistake. This was a documented pattern.

What the no-fault defense bar needs to understand about cases like this is the stakes on both sides. On the plaintiff’s side (GEICO here), the preliminary injunction froze millions in pending claims. On the defendant’s side, any network built on high-volume, cookie-cutter billing to auto insurers faces total collapse the moment a federal court freezes receivables. The 85/50 settlement dynamic — where the insurer takes 85 cents on the dollar and the provider keeps 50 — evaporates instantly. There is nothing to negotiate when the money is frozen and a RICO verdict threatens treble damages on the full amount of the scheme.

Eight Findings That Built the Injunction

The opinion in Geico v. Moshe is short, direct, and devastating. Here are the eight specific findings the court identified in granting the preliminary injunction:

1. Prior RICO exposure. Yan Moshe had already been sued seven times by insurers alleging he previously engaged in similar fraudulent billing activities.

2. Straw ownership. Moshe conspired with individuals — including defendants Leonid Shapiro and Nizar Kifaieh — to run his facilities “on paper,” while Moshe controlled the facilities without a medical degree. The complaint was supported by specific examples and by Kifaieh’s testimony from prior litigation that he did not pay for ownership of Premier and that Moshe provided him with equipment.

3. Regulatory violations. Moshe’s facilities, particularly those directed by Shapiro, were repeatedly cited by the New Jersey Department of Health for regulatory violations. In fact, one facility was temporarily closed due to unsanitary conditions.

4. Unnecessary services and undisclosed referrals. Defendants unlawfully referred patients to Moshe’s facilities for unnecessary services, often without disclosing Moshe’s ownership interest. Those facilities then billed GEICO for the unnecessary services.

5. Cookie-cutter treatment protocols. Defendants prescribed identical treatment for people involved in a single accident — regardless of varying ages and health conditions. The complaint provided 10 detailed examples.

6. Cross-border billing. Regina and Citimedical billed GEICO for services provided in New Jersey even though Citimedical could not lawfully provide services outside New York. The complaint provided 15 detailed examples.

7. Fee schedule violations. Yan Moshe and Hudson Regional unlawfully requested reimbursement for facility fees that exceeded the limits set by the NJ fee schedule.

8. False certifications. Defendants submitted bills purporting that they were in compliance with all laws and regulations while engaging in all of the above activities.

This is textbook RICO in the no-fault context: a coordinated enterprise, concealed ownership, financial benefit flowing to the hidden principal, and systematic billing fraud. The straw-ownership theory — an unlicensed person controlling licensed facilities through front licensees — is the same mechanism at the heart of the Mallela doctrine in New York. Whether you are in federal RICO litigation or a no-fault arbitration, fraudulent incorporation is fraudulent incorporation.

Federal RICO: Why It Is the Only Tool That Threatens the Business Model

The Federal RICO statute (18 U.S.C. §§ 1961–1968) is the sharpest instrument in the no-fault defense arsenal when confronting coordinated billing fraud rings. There is nothing in the New York State arsenal of common law remedies that comes anywhere close.

Treble damages. Under 18 U.S.C. §1964(c), a civil RICO plaintiff that proves its case recovers three times its actual damages, plus attorney fees. A $10 million fraud scheme becomes a $30 million judgment. That math reaches the people running the enterprise — not just the straw entities that processed the bills.

Asset freezes via preliminary injunction. Because RICO allows courts to freeze assets acquired or maintained through racketeering activity, a successful preliminary injunction motion can freeze the defendant’s entire receivable book — stopping new billing and preventing dissipation of proceeds while the case proceeds. That is what happened in Geico v. Moshe in 2020.

Pattern requirement as a feature, not a bug. RICO requires a “pattern” of racketeering activity — at least two predicate acts within a ten-year period, connected to an enterprise. For a provider network that has been submitting fraudulent bills across thousands of accident claims over years, the pattern requirement is easily met and becomes devastating proof of systematic, not accidental, fraud. Nine prior RICO suits is not a pattern — it is a catalog.

Straw ownership as a predicate act. Under New York’s and New Jersey’s healthcare licensing laws, medical facilities must be owned and controlled by licensed physicians. Using straw licensees to circumvent this requirement is itself a predicate act. Claims submitted by an unlawfully-owned facility are per se fraudulent for RICO purposes — no medical necessity argument changes that. This is the core of what the Mallela doctrine established in New York, and it applies with equal force in federal RICO proceedings in New Jersey.

What NY state law cannot do. New York has not enacted a Civil RICO statute. State-court fraud claims are governed by common law fraud, which provides no treble damages, no asset freeze mechanism, and no enterprise-level reach. This is why the most significant no-fault fraud actions — Geico v. Moshe, the State Farm Mallela line, Progressive’s network cases — are brought in federal court. Anyone who tells you state court is the right venue for a major billing fraud network is telling you they have not read the statute.

Timeline: The Full Yan Moshe Record, 2007–2026

The GEICO injunction did not come from nowhere. Here is the complete documented record.

2007 onward

First RICO Lawsuit Filed — of Nine

The first of nine RICO lawsuits against Moshe is filed by a major insurer, alleging fraudulent billing schemes, kickbacks, and the use of front licensees to conceal his control of medical facilities he ran without a medical degree.

2018

Surgical Center Shut Down for Sterilization Failures

New Jersey state inspectors shut down one of Moshe's surgical centers after finding sterilization lapses that exposed hundreds of patients to potential infection risk. This is not a billing irregularity — it is a patient safety failure in a facility Moshe allegedly controlled without a medical license.

July 2020

GEICO Wins Federal RICO Preliminary Injunction

GEICO files Geico v. Moshe, 20-cv-1098, in the Eastern District of New York. The court grants a preliminary RICO injunction, freezing Moshe's ability to collect on pending claims. The opinion documents seven prior insurer RICO suits against Moshe at the time of the ruling — eight specific findings support the injunction.

January 2025

Moshe "Rescues" 152-Year-Old Christ Hospital

Moshe's Hudson Regional Health (HRH) network takes over Christ Hospital in Jersey City, rebranding it Heights University Hospital (HUH). HRH assures a bankruptcy court and state regulators it has the funds to keep the facility running. A ribbon-cutting with state and local officials announces a $75–100 million investment in "transformative upgrades to services, technology and infrastructure." No upgrades will follow.

October 14, 2025

HRH Files for Closure — Before Announcing a Crisis

HRH files a certificate of need requesting a staged, full hospital closure — weeks before it publicly claims a funding crisis. In the same filing, HRH (which owns the land beneath the hospital) describes plans to develop the property as residential and commercial space, with a vague mention of a "future hospital" elsewhere. The real estate play is documented in writing.

October 2025

State Sends $2M Emergency Grant — Payroll Still Not Funded

The New Jersey state government sends HRH a $2 million emergency grant specifically to stabilize payroll and prevent service disruptions. Workers' paychecks for a prior pay period are not issued. Services are not preserved.

November 2025

Hospital Collapses — 699 Employees, Tens of Thousands of Patients Displaced

HRH lays off staff without legally required WARN Act notice. Most services shut down — inpatient, surgical, maternity, imaging. Of 699 employees, roughly 100 are "absorbed" into the HRH network; most face unemployment. Healthcare workers later report seeing zero evidence of the promised $75–100M upgrades during HRH's entire tenure: no contractors, no construction, no renovations. The NJ Department of Health admits in writing that HRH "failed to fund their payroll … failed to fully perform as it represented."

November 2025 — Secaucus

NJSEA Approves Cannabis Factory Rezoning, 15-0

The New Jersey Sports & Exposition Authority votes 15-0 to approve Moshe's application — filed under LLC "NJ Highlands" — to rezone the former Channel 9/WWOR-TV building at 43 Meadowlands Parkway in Secaucus from commercial to light industrial use for a large-scale indoor cannabis grow and processing facility.

June 2026

Cannabis Board Approval Pending — Nine RICO Suits Total

The Secaucus Local Cannabis Control Board has not yet acted on Moshe's cannabis facility application. By this point, major insurers have sued Yan Moshe under the federal RICO Act a total of nine times — two more than the seven documented at the time of the 2020 GEICO injunction.

By The Numbers

Sued Under Federal RICO

699

Hospital Employees Displaced

$400K+

Donated to Mayor Fulop

15-0

NJSEA Cannabis Vote

$2M

State Grant Before Closure

152 yrs

Age of Shuttered Hospital

Christ Hospital: The Real Estate Play That Left 699 People Jobless

The Heights University Hospital story is, in retrospect, exactly what Moshe’s prior history should have predicted for anyone reading the dockets. The pattern is the same: acquire control of an institution through structures that obscure who actually holds the decision-making authority, extract value from the enterprise, and depart before regulators can respond effectively.

A healthcare worker at Heights University Hospital described the supposed “transformative upgrades” to reporters after the closure: “I’ve worked at several hospitals. There’s no way you can miss improvements. People are talking about them. Contractors are walking around; they stand out. There are areas closed off temporarily, employees being shifted around. That never happened here.” After HRH took over, one floor was permanently shut down. Then a second. These changes happened long before HRH announced its sudden “financial crisis.”

The certificate of need filing was where the intent became unambiguous: HRH owns the land beneath Heights University Hospital. The plan described in that filing was not to fix the hospital — it was to develop the property as residential and commercial space. The “future hospital” mentioned in the filing was non-specific and geographically vague. There was no commitment, no location, no timeline.

The political dimension is impossible to ignore. Moshe donated more than $400,000 to Jersey City Mayor Steven Fulop, who publicly backed HRH’s takeover of Christ Hospital. Under outgoing New Jersey Governor Phil Murphy, the Department of Health approved HRH’s takeover despite Moshe’s documented RICO history. After the closure, the Department acknowledged in correspondence that HRH had “failed to fund their payroll … failed to fully perform as it represented.” That is regulatory understatement. What actually happened was that a century-and-a-half-old community hospital that served tens of thousands of patients was used as a real estate acquisition vehicle, operated at minimum cost while the development plan was assembled, and then liquidated.

For tens of thousands of patients in Jersey City’s Heights neighborhood, this means traveling to Hoboken or Bayonne for inpatient care, surgeries, maternity services, imaging, and routine treatment — services they had access to walking distance from their homes.

The Cannabis Factory: Next Act in Secaucus

Moshe purchased the former Channel 9/WWOR-TV studio building at 43 Meadowlands Parkway in Secaucus from Hartz Mountain Industries. Through an LLC called NJ Highlands, he applied to the New Jersey Sports & Exposition Authority to rezone the property from commercial to light industrial use for a large-scale indoor cannabis grow and processing facility.

The November 2025 NJSEA meeting approved the rezoning 15-0. Hartz Mountain Industries, which owns the adjacent Osprey Cove apartment complex, raised concerns about air quality and whether cannabis odor would affect neighboring residential tenants. Secaucus town administrator Gary Jeffas indicated the town had no objection to the zoning change. The approval moves the project forward — but the final hurdle is the Secaucus Local Cannabis Control Board, composed of the police chief, the town administrator, and the town attorney.

As of June 2026, that board has not yet acted.

From a purely business perspective, the vertical indoor grow facility model is capital-intensive, permit-dependent, and requires the kind of multi-jurisdictional regulatory navigation that someone who has spent decades operating in healthcare licensing gray areas in New Jersey presumably understands better than most. Whether that history helps or hurts with the Cannabis Control Board is a question only the board can answer.

What is clear is that the same fundamental move — acquire a physical asset, apply for a change in use authorization, build a revenue-generating operation inside a regulatory framework — is the throughline from the no-fault billing network to the hospital acquisition to the cannabis facility.

June 2026 Status Tracker

June 2026 — Active Proceedings

Four open fronts across Moshe's documented history, as of this update. The no-fault litigation predates the hospital play by nearly two decades — both tracks run simultaneously.

Front 1 — EDNY

Geico v. Moshe

Status: Federal RICO preliminary injunction entered 2020. Core federal civil RICO case in the Eastern District of New York. Part of the nine-lawsuit RICO pattern that spans 2007–2025.

What to watch: Whether GEICO's RICO case produces a trial verdict or settlement — treble damages on the proven billing fraud amount would be the headline number.

Front 2 — NJ Regulatory

Heights University Hospital

Status: Closed November 2025. NJ Department of Health admitted HRH failed its commitments. 699 employees displaced. WARN Act violations alleged.

What to watch: Any NJ DOH enforcement action, employee WARN Act litigation, and whether the planned residential/commercial redevelopment of the hospital land moves forward.

Front 3 — Secaucus

Cannabis Facility Application

Status: NJSEA approved 15-0 in November 2025. Application pending before Secaucus Local Cannabis Control Board (police chief, town administrator, town attorney).

What to watch: Whether the Cannabis Control Board approves the application and whether Hartz Mountain Industries' air-quality objections carry weight in the local review.

Front 4 — No-Fault Bar

Mallela / Network Defenses

Status: Claims from Moshe-affiliated entities (Citimedical, Premier, HRH affiliates) remain subject to Mallela-based fraudulent incorporation defenses in NY no-fault proceedings.

What to watch: Whether the nine-RICO-suit pattern and the hospital collapse create additional discovery leverage in pending no-fault arbitrations involving network-connected billing.

Status as of June 3, 2026. We update this tracker as proceedings develop.

What This Means for the No-Fault Defense Bar

I have been writing about the no-fault dockets for years. The Moshe pattern — from the 2020 GEICO injunction through the 2025 hospital collapse — illustrates something the defense bar already knows but the public rarely sees documented in one place.

No-fault billing fraud is not random. It is organized, systematic, and run by people who have calculated that the volume of billing will outrun litigation costs. The 85/50 settlement dynamic — where the insurer takes 85 cents and the provider keeps 50 cents — works financially for the fraud network as long as no one federalizes it.

Federal RICO changes that math. Treble damages, asset freezes, and the ability to reach the actual controlling principal (not just the straw licensee) are the only levers that actually threaten the business model. Geico v. Moshe should be required reading in any no-fault defense seminar.

The Mallela doctrine is the state-law analog. In New York arbitrations and court proceedings, the fraudulent incorporation defense under State Farm Mutual v. Mallela, 4 N.Y.3d 313 (2005) does what federal RICO does at the enterprise level: it renders all claims from an unlawfully-owned facility fraudulent at inception. No medical necessity argument. No fee schedule nuance. No coverage analysis. Fraudulent from the first bill. The Mallela-based discovery framework that New York courts have developed over the past twenty years exists precisely because networks like Moshe’s are not unusual — they are the rule in certain high-volume billing corridors.

If you are dealing with billing from any Moshe-connected entity — Citimedical, Premier, Hudson Regional affiliates, or any facility with ownership structures that trace back through the network — document the ownership chain. The federal record is public. Nine RICO suits, one preliminary injunction, a surgical center shutdown, a hospital collapse, and a cannabis factory application are not the biography of a borderline case.

Frequently Asked Questions

Q: What was Geico v. Moshe about?

A: Geico v. Moshe, 20-cv-1098 (EDNY 2020) was a federal civil RICO lawsuit filed by GEICO against Yan Moshe and associated entities, alleging a coordinated scheme to defraud GEICO through fraudulent no-fault billing. The court granted GEICO a preliminary injunction, freezing the defendants’ ability to collect on pending claims while the litigation proceeded. The court’s opinion identified eight specific grounds for the injunction: Moshe’s history of seven prior insurer RICO suits, straw ownership of medical facilities, identical treatment protocols regardless of patient condition, billing for out-of-state services through entities not licensed to practice in New Jersey, fee schedule overcharges, and false certifications of regulatory compliance.

Q: How many times has Yan Moshe been sued under RICO?

A: As of 2025-2026, major insurers have sued Yan Moshe under the federal RICO Act nine times. The Geico v. Moshe court noted seven prior insurer RICO suits at the time of the 2020 injunction. Two additional suits have been documented in subsequent reporting. The suits allege patterns of fraudulent billing schemes, kickbacks, and the use of straw owners to conceal his control of medical facilities.

Q: What happened to Christ Hospital / Heights University Hospital?

A: Moshe’s Hudson Regional Health (HRH) network took over the 152-year-old Christ Hospital in Jersey City in January 2025, rebranding it Heights University Hospital. After receiving a $2 million state emergency grant, HRH filed for closure in October 2025 and abruptly shut down most services in November 2025 — leaving 699 employees facing layoffs without legally required WARN Act notice and tens of thousands of patients displaced. HRH’s certificate of need filing revealed that the company, which owns the land beneath the hospital, planned to redevelop the property as residential and commercial space. The NJ Department of Health ultimately admitted in its own correspondence that HRH “failed to fund their payroll … failed to fully perform as it represented” and “has not followed through on its commitments to the community it serves and to the state.”

Q: What is Moshe’s cannabis facility plan?

A: Through an LLC called NJ Highlands, Moshe purchased the former Channel 9/WWOR-TV building at 43 Meadowlands Parkway in Secaucus. He applied to the NJSEA to rezone the property from commercial to light industrial use for a large-scale indoor cannabis grow and processing facility, with a stated long-term goal of establishing a medical marijuana research center. The NJSEA approved the zoning change 15-0 in November 2025. The application still requires approval from the Secaucus Local Cannabis Control Board, which as of June 2026 has not yet acted.

Q: What is the Mallela doctrine and how does it apply to Moshe’s network?

A: The Mallela doctrine — from State Farm Mutual Automobile Insurance Co. v. Mallela, 4 N.Y.3d 313 (2005) — holds that a medical professional corporation that is fraudulently incorporated (i.e., controlled by a non-physician through a licensed straw owner) has no right to reimbursement under New York’s no-fault law. Claims submitted by such entities are fraudulent at inception: no medical necessity argument, no fee schedule dispute, no coverage analysis changes that result. The doctrine applies directly to straw-ownership networks like those alleged in Geico v. Moshe. New Jersey has analogous healthcare licensing requirements that produce the same result in federal RICO proceedings. For Mallela-based discovery issues in NY no-fault cases, the framework is well-developed — the Moshe network illustrates exactly why courts have built it.

Q: Why doesn’t New York have a Civil RICO statute?

A: New York has not enacted a state-level Civil RICO statute equivalent to 18 U.S.C. §§ 1961-1968. State-court fraud claims in New York are governed by common law fraud, which provides no treble damages, no asset freeze mechanism at inception, and no enterprise-level reach. This is why the most significant no-fault fraud prosecutions are brought in federal court under 18 U.S.C. §1964(c). Some practitioners have attempted to analogize certain state remedies to RICO-style claims, but there is no true Civil RICO in New York state court — and the 85/50 settlement dynamic persists in part because the state-level consequences of billing fraud, in isolation, rarely threaten the business model the way a federal RICO preliminary injunction does.

Q: What should no-fault defense practitioners do if they encounter billing from Moshe-connected entities?

A: Document the ownership structure. The federal record on the Moshe network is extensive and public. Nine RICO suits across two decades, a 2020 preliminary injunction, a 2018 surgical center shutdown, and the 2025 hospital collapse create a pattern that supports Mallela-based defenses at the arbitration level and a roadmap for federal RICO discovery at the litigation level. Look for connections to Citimedical, Premier, and Hudson Regional affiliates. Request corporate ownership documents early. The straw-licensee structure is the key — once you establish that the controlling person lacks a medical license, every claim from that facility is vulnerable. Call (516) 750-0595 if you want to discuss the specifics of a pending case.

Q: What options do Heights University Hospital employees have after the closure?

A: Employees who were laid off without required WARN Act notice may have federal and state claims. The federal WARN Act (29 U.S.C. §§ 2101-2109) requires 60 days advance written notice of a plant closing or mass layoff affecting 50 or more employees — violations entitle affected workers to back pay and benefits for the notice period. New Jersey’s mini-WARN Act (N.J.S.A. 34:21-1 et seq.) separately requires notice and severance pay. If your paychecks were withheld, New Jersey wage payment law provides additional remedies. Patients requiring ongoing care should contact the New Jersey Department of Health for records access and continuity of care resources. Contact our office at (516) 750-0595 for a free consultation — we handle employment and personal injury claims across New York and New Jersey.

Q: What is the 85/50 settlement dynamic in no-fault, and why does RICO disrupt it?

A: “85/50” refers to a common settlement posture in high-volume no-fault dispute dockets: the provider accepts 85 cents on the dollar of the amount billed, and the insurer pays 50 cents on the dollar of what is owed under the fee schedule (the exact ratio varies by negotiation). The model works in a fraudulent billing scheme because it is cheaper for the insurer to settle individual claims than to litigate each one — and the provider builds the settlement discount into the volume. A federal RICO preliminary injunction breaks this dynamic entirely: it freezes the receivables, removes the economic incentive to settle individually, and threads the enterprise with the threat of treble damages on the full amount of the scheme. That is the real story of Geico v. Moshe — not a single injunction, but the moment the insurer changed the math.

Legal Context

Why This Matters for Your Case

New York's no-fault insurance system, established under Insurance Law Article 51, is one of the most complex insurance frameworks in the country. Every motorist must carry Personal Injury Protection coverage that pays medical expenses and lost wages regardless of fault, up to $50,000 per person.

But insurers routinely deny valid claims using peer reviews, EUO scheduling tactics, fee schedule reductions, and coverage defenses. The Law Office of Jason Tenenbaum has handled over 100,000 no-fault cases since 2002 — from initial claim submissions through arbitration before the American Arbitration Association, trials in Civil Court and Supreme Court, and appeals to the Appellate Term and Appellate Division. Jason Tenenbaum is one of the few attorneys in the state who both writes his own appellate briefs and tries his own cases.

His 2,353+ published legal articles on no-fault practice are cited by attorneys throughout New York. Whether you are dealing with a medical necessity denial, an EUO no-show defense, a fee schedule dispute, or a coverage question, this article provides the kind of detailed case-law analysis that helps practitioners and claimants understand exactly where the law stands.

About This Topic

New York No-Fault Insurance Law

New York's no-fault insurance system requires every driver to carry Personal Injury Protection (PIP) coverage that pays medical expenses and lost wages regardless of who caused the accident. But insurers routinely deny, delay, and underpay valid claims — using peer reviews, IME no-shows, and fee schedule defenses to avoid paying providers and injured claimants. Attorney Jason Tenenbaum has litigated thousands of no-fault arbitrations and court cases since 2002.

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Frequently Asked Questions

Common Questions About This Topic

7 answers from the firm's New York personal-injury and employment-law practice. Click any question to expand.

Q: How many times has Yan Moshe been sued under RICO?

A: As of 2025-2026, major insurers have sued Yan Moshe under the federal RICO Act nine times. The *Geico v. Moshe* court noted seven prior insurer RICO suits at the time of the 2020 injunction. Two additional suits have been documented in subsequent reporting. The suits allege patterns of fraudulent billing schemes, kickbacks, and the use of straw owners to conceal his control of medical facilities.

Q: What happened to Christ Hospital / Heights University Hospital?

A: Moshe's Hudson Regional Health (HRH) network took over the 152-year-old Christ Hospital in Jersey City in January 2025, rebranding it Heights University Hospital. After receiving a $2 million state emergency grant, HRH filed for closure in October 2025 and abruptly shut down most services in November 2025 — leaving 699 employees facing layoffs without legally required WARN Act notice and tens of thousands of patients displaced. HRH's certificate of need filing revealed that the company, which owns the land beneath the hospital, planned to redevelop the property as residential and commercial space. The NJ Department of Health ultimately admitted in its own correspondence that HRH "failed to fund their payroll … failed to fully perform as it represented" and "has not followed through on its commitments to the community it serves and to the state."

Q: What is Moshe's cannabis facility plan?

A: Through an LLC called NJ Highlands, Moshe purchased the former Channel 9/WWOR-TV building at 43 Meadowlands Parkway in Secaucus. He applied to the NJSEA to rezone the property from commercial to light industrial use for a large-scale indoor cannabis grow and processing facility, with a stated long-term goal of establishing a medical marijuana research center. The NJSEA approved the zoning change 15-0 in November 2025. The application still requires approval from the Secaucus Local Cannabis Control Board, which as of June 2026 has not yet acted. Q: What is the *Mallela* doctrine and how does it apply to Moshe's network? A: The *Mallela* doctrine — from *State Farm Mutual Automobile Insurance Co. v. Mallela*, 4 N.Y.3d 313 (2005) — holds that a medical professional corporation that is fraudulently incorporated (i.e., controlled by a non-physician through a licensed straw owner) has no right to reimbursement under New York's no-fault law. Claims submitted by such entities are fraudulent at inception: no medical necessity argument, no fee schedule dispute, no coverage analysis changes that result. The doctrine applies directly to straw-ownership networks like those alleged in *Geico v. Moshe*. New Jersey has analogous healthcare licensing requirements that produce the same result in federal RICO proceedings. For *Mallela*-based discovery issues in NY no-fault cases, the framework is well-developed — the Moshe network illustrates exactly why courts have built it.

Q: Why doesn't New York have a Civil RICO statute?

A: New York has not enacted a state-level Civil RICO statute equivalent to 18 U.S.C. §§ 1961-1968. State-court fraud claims in New York are governed by common law fraud, which provides no treble damages, no asset freeze mechanism at inception, and no enterprise-level reach. This is why the most significant no-fault fraud prosecutions are brought in federal court under 18 U.S.C. §1964(c). Some practitioners have attempted to analogize certain state remedies to RICO-style claims, but there is no true Civil RICO in New York state court — and the 85/50 settlement dynamic persists in part because the state-level consequences of billing fraud, in isolation, rarely threaten the business model the way a federal RICO preliminary injunction does.

Q: What should no-fault defense practitioners do if they encounter billing from Moshe-connected entities?

A: Document the ownership structure. The federal record on the Moshe network is extensive and public. Nine RICO suits across two decades, a 2020 preliminary injunction, a 2018 surgical center shutdown, and the 2025 hospital collapse create a pattern that supports *Mallela*-based defenses at the arbitration level and a roadmap for federal RICO discovery at the litigation level. Look for connections to Citimedical, Premier, and Hudson Regional affiliates. Request corporate ownership documents early. The straw-licensee structure is the key — once you establish that the controlling person lacks a medical license, every claim from that facility is vulnerable. Call (516) 750-0595 if you want to discuss the specifics of a pending case.

Q: What options do Heights University Hospital employees have after the closure?

A: Employees who were laid off without required WARN Act notice may have federal and state claims. The federal WARN Act (29 U.S.C. §§ 2101-2109) requires 60 days advance written notice of a plant closing or mass layoff affecting 50 or more employees — violations entitle affected workers to back pay and benefits for the notice period. New Jersey's mini-WARN Act (N.J.S.A. 34:21-1 et seq.) separately requires notice and severance pay. If your paychecks were withheld, New Jersey wage payment law provides additional remedies. Patients requiring ongoing care should contact the New Jersey Department of Health for records access and continuity of care resources. Contact our office at (516) 750-0595 for a free consultation — we handle employment and personal injury claims across New York and New Jersey.

Q: What is the 85/50 settlement dynamic in no-fault, and why does RICO disrupt it?

A: "85/50" refers to a common settlement posture in high-volume no-fault dispute dockets: the provider accepts 85 cents on the dollar of the amount billed, and the insurer pays 50 cents on the dollar of what is owed under the fee schedule (the exact ratio varies by negotiation). The model works in a fraudulent billing scheme because it is cheaper for the insurer to settle individual claims than to litigate each one — and the provider builds the settlement discount into the volume. A federal RICO preliminary injunction breaks this dynamic entirely: it freezes the receivables, removes the economic incentive to settle individually, and threads the enterprise with the threat of treble damages on the full amount of the scheme. That is the real story of *Geico v. Moshe* — not a single injunction, but the moment the insurer changed the math.

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Attorney Jason Tenenbaum

About the Author

Jason Tenenbaum, Esq.

Jason Tenenbaum is the founding attorney of the Law Office of Jason Tenenbaum, P.C., headquartered at 326 Walt Whitman Road, Suite C, Huntington Station, New York 11746. With over 24 years of experience since founding the firm in 2002, Jason has written more than 1,000 appeals, handled over 100,000 no-fault insurance cases, and recovered over $100 million for clients across Long Island, Nassau County, Suffolk County, Queens, Brooklyn, Manhattan, the Bronx, and Staten Island. He is one of the few attorneys in the state who both writes his own appellate briefs and tries his own cases.

Jason is admitted to practice in New York, New Jersey, Florida, Texas, Georgia, and Michigan state courts, as well as multiple federal courts. His 2,353+ published legal articles analyzing New York case law, procedural developments, and litigation strategy make him one of the most prolific legal commentators in the state. He earned his Juris Doctor from Syracuse University College of Law.

24+ years in practice 1,000+ appeals written 100K+ no-fault cases $100M+ recovered

Disclaimer: This article is published by the Law Office of Jason Tenenbaum, P.C. for informational and educational purposes only. It does not constitute legal advice, and no attorney-client relationship is formed by reading this content. The legal principles discussed may not apply to your specific situation, and the law may have changed since this article was last updated.

New York law varies by jurisdiction — court decisions in one Appellate Division department may not be followed in another, and local court rules in Nassau County Supreme Court differ from those in Suffolk County Supreme Court, Kings County Civil Court, or Queens County Supreme Court. The Appellate Division, Second Department (which covers Long Island, Brooklyn, Queens, and Staten Island) and the Appellate Term (which hears appeals from lower courts) each have distinct procedural requirements and precedents that affect litigation strategy.

If you need legal help with a no-fault matter, contact our office at (516) 750-0595 for a free consultation. We serve clients throughout Long Island (Huntington, Babylon, Islip, Brookhaven, Smithtown, Riverhead, Southampton, East Hampton), Nassau County (Hempstead, Garden City, Mineola, Great Neck, Manhasset, Freeport, Long Beach, Rockville Centre, Valley Stream, Westbury, Hicksville, Massapequa), Suffolk County (Hauppauge, Deer Park, Bay Shore, Central Islip, Patchogue, Brentwood), Queens, Brooklyn, Manhattan, the Bronx, Staten Island, and Westchester County. Prior results do not guarantee a similar outcome.

Jason Tenenbaum, Personal Injury Attorney serving Long Island, Nassau County and Suffolk County

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Jason Tenenbaum, Esq.

Jason Tenenbaum is a personal injury attorney serving Long Island, Nassau & Suffolk Counties, and New York City. Admitted to practice in NY, NJ, FL, TX, GA, MI, and Federal courts, Jason is one of the few attorneys who writes his own appeals and tries his own cases. Since 2002, he has authored over 2,353 articles on no-fault insurance law, personal injury, and employment law — a resource other attorneys rely on to stay current on New York appellate decisions.

Education
Syracuse University College of Law
Experience
24+ Years
Articles
2,353+ Published
Licensed In
7 States + Federal

Legal Resources

Understanding New York No-Fault Law

New York has a unique legal landscape that affects how no-fault cases are litigated and resolved. The state's court system includes the Civil Court (for claims up to $25,000), the Supreme Court (the primary trial court for unlimited jurisdiction), the Appellate Term (which hears appeals from lower courts), the Appellate Division (divided into four Departments, with the Second Department covering Long Island, Brooklyn, Queens, Staten Island, and several upstate counties), and the Court of Appeals (the state's highest court). Each court has its own procedural requirements, local rules, and case-assignment practices that can significantly impact the outcome of your case.

For no-fault matters on Long Island, cases are typically filed in Nassau County Supreme Court (at the courthouse in Mineola) or Suffolk County Supreme Court (in Riverhead). No-fault arbitrations are heard through the American Arbitration Association, which assigns arbitrators throughout the metropolitan area. Workers' compensation claims go to the Workers' Compensation Board, with hearings at district offices across the state. Understanding which forum is appropriate for your case — and the specific procedural rules that apply — is essential for a successful outcome.

The procedural landscape in New York also includes important timing requirements that can affect your case. Most civil actions are subject to statutes of limitations ranging from one year (for intentional torts and claims against municipalities) to six years (for contract actions). Personal injury cases generally have a three-year deadline under CPLR 214(5), while medical malpractice claims must be filed within two and a half years under CPLR 214-a. No-fault insurance claims have their own regulatory deadlines, including 30-day filing requirements for applications and 45-day deadlines for provider claims. Understanding and complying with these deadlines is critical — missing a filing deadline can permanently bar your claim, regardless of how strong your case may be on the merits.

Attorney Jason Tenenbaum regularly practices in all of these venues. His office at 326 Walt Whitman Road, Suite C, Huntington Station, NY 11746, is centrally located on Long Island, providing convenient access to courts and offices throughout Nassau County, Suffolk County, and New York City. Whether you need representation in a no-fault arbitration, a personal injury trial, an employment discrimination hearing, or an appeal to the Appellate Division, the Law Office of Jason Tenenbaum, P.C. brings $24+ years of real courtroom experience to your case. If you have questions about the legal issues discussed in this article, call (516) 750-0595 for a free, no-obligation consultation.

New York's substantive law also presents distinct challenges. In motor vehicle cases, the no-fault system under Insurance Law Article 51 provides first-party benefits regardless of fault, but limits the right to sue for non-economic damages unless the plaintiff establishes a "serious injury" under one of nine statutory categories. This threshold — codified at Insurance Law Section 5102(d) — requires medical evidence showing more than a minor or subjective injury, and courts have developed detailed standards for each category. Fractures must be documented through imaging studies. Claims of permanent consequential limitation or significant limitation of use require quantified range-of-motion testing with comparison to norms. The 90/180-day category demands proof that the plaintiff was unable to perform substantially all of their usual daily activities for at least 90 of the 180 days following the accident.

In employment discrimination cases, the legal standards vary depending on whether the claim arises under state or local law. The New York State Human Rights Law employs a burden-shifting framework: the plaintiff must first establish a prima facie case by showing membership in a protected class, qualification for the position, an adverse employment action, and circumstances giving rise to an inference of discrimination. The burden then shifts to the employer to articulate a legitimate, non-discriminatory reason for its decision. If the employer meets this burden, the plaintiff must demonstrate that the stated reason is pretextual. The New York City Human Rights Law, by contrast, applies a broader standard, asking whether the plaintiff was treated less well than other employees because of a protected characteristic.

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