STATE FARM HAIL-CLAIM LITIGATION
Oklahoma · Filed date not stated · 60 pages · Download the PDF
FILED IN DISTRICT COURT TEMAS ON AIONA COUNTY IN THE DISTRICT COURT OF OKLAHOMA COUNTYWAUG BILLY & LACY HURSH, 2 6 2026 3 _cotRY CES re Plaintiffs, vy. Case No. CJ-2025-2626 STATE FARM FIRE AND Honorable Amy Palumbo CASUALTY COMPANY; MARK D. WELTY; and MARK D. WELTY INSURANCE AGENCY, INC., Defendants. PLAINTIFFS’ REPLY IN SUPPORT OF THEIR MOTION TO (1) STRIKE DEFENDANT STATE FARM’S BLANKET CONFIDENTIALITY ASSERTION, (2) AND DE-DESIGNATE DOCUMENTS PRODUCED FOR GOOD CAUSE BASED ON STATE FARM’S FAILURE TO ENGAGE IN GOOD FAITH AS REQUIRED
deposition ×181 · protective order ×76 · FME ×11 · denial ×9 · sanction ×7 · indemnity ×5 · summary judgment ×4 · roof replacement ×3
PAGE 40 · protective order, deposition
… of the cases where the parties agree to consolidate Ms. Manduca’s deposition, except in Stafford v. State Farm where discovery has closed, provided that: (1) a protective order is entered in each of the respective cases that adequately covers Ms. Manduca’s deposition testimony and exhibits; and (2) use of the transcripts is limited to the cases where we agree to consolidate Ms. Manduca’s deposition. 25 of 31
PAGE 41 · FME, protective order, deposition
… stances. ° With respect to your suggestion that “Plaintiff will be able to schedule additional depositions following production of any documents related to the FME Wind Hail Initiative as ordered by any Court,” we will not agree if you intend to include Ms. Manduca in this group of persons who can be produced after such production., if it occurs. Repeated depositions of Ms. Manduca would defeat the purpose of State F …
PAGE 43 · FME, deposition
… transcript is public record and on oscn.net. 4. Plaintiff will be able to schedule additional depositions following production of any documents related to the FME Wind Hail Initiative as ordered by any Court (and currently the subject of the writ after being ordered to be produced by Judge Palumbo in 5. Hursh). The parties will work together to identify those depositions in good faith. No agreement will impact any s …
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