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STATE FARM HAIL-CLAIM LITIGATION

20260825-1066534272-state-farm-reply-protective-order-deposition-protocol.pdf

Oklahoma · Filed date not stated · 8 pages · Download the PDF

What this document says (first page, verbatim)

LINER FILED IN DiSTRICT COURT OKLAHOMA COUNTY IN THE DISTRICT COURT OF OKLAHOMA STATE OF OKLAHOMA COUNTY AUG 25 2006 RICK BILLY & LACY HURSH, a WankeN 5 COURT CLERK Plaintiffs, v. Case No. CJ-2025-2626 STATE FARM FIRE & CASUALTY COMPANY, MARK D. WELTY, and MARK WELTY INSURANCE AGENCY, INC., D. Defendants. DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S REPLY IN SUPPORT OF MOTION FOR ENTRY OF A PROTECTIVE ORDER AND DEPOSITION PROTOCOL GOVERNING COUNSEL’S CONDUCT AT DEPOSITIONS Carrie B. McNeer, OBA No. 22235 Nathan A. Miramontes, OBA No. 36212 GABLEGOTWALS 110 N. …

Key terms in this filing

deposition ×31 · sanction ×7 · protective order ×3

Notable passages

PAGE 3 · sanction, deposition

… revent further disputes over counsel’s conduct in any additional depositions in this matter. II. STATE FARM IS NOT REQUIRED TO FILE A BAR COMPLAINT OR MOVE FOR SANCTIONS BEFORE REQUESTING A PROTOCOL. Plaintiffs’ “legal” argument—that State Farm cannot ask the Court to enter a Deposition Protocol unless it first files a bar complaint or moves for sanctions against Plaintiffs’ counsel (see Pls.’ Resp. at 10-13)—is base …

PAGE 5 · deposition

temperature Ms. Manduca’s deposition created and avoid further disputes over counsel’s conduct. Like protocols that courts across the country have entered, the proposed Protocol simply requires counsel to comply with existing law governing witness questioning, deposition instructions, and the use of exhibits. Plaintiffs’ apparent belief that those requirements somehow advantage State Farm only confirms why the Protoc …

PAGE 4 · protective order, sanction, deposition

… the discovery may be had only on specified terms and conditions.” also 12 O.S. § 3226.1. 12 0.S. § 3226(C) (emphasis added); see There is no requirement that a protective order must first be justified by a violation of the Code: indeed, if that were the case, no court could enter an order protecting a defendant’s trade secrets until the plaintiff affirmatively disclosed the critical information to a competitor; or an …

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