WEST V. STATE FARM FIRE & CASUALTY CO.
Comanche County District Court, CJ-2025-135 · Filed date not stated · 39 pages · Download the PDF
IN THE DISTRICT COURT OF COMANCHE COUNTY STATE OF OKLAHOMA FILED COMANCHE COUNTY, OKLAHOMA ROBERT MORALES, COURT CLERK September 10, 2026 9:04 AM Case Number CJ-2025-135 Smaate” Plaintiffs, easel NEIL & LACY WEST, Sattar” DISTRICT COURT Case No, CJ-2025-135 Defendants. Senet apie Neve Nese” STATE FARM FIRE & CASUALTY COMPANY and NANCY HOLCOMB INS. AGENCY, INC., Senet merit Natt? ve STATE FARM’S REPLY IN SUPPORT OF ITS MOTION FOR A PROTECTIVE ORDER CONSOLIDATING THE DEPOSITIONS OF WENSLEY HERBERT, THOMAS MOSS, KATHY RESS, AND SCOTT WELSH AND RESPONSE TO PLAINTIFFS’ COUNTER MOTION FOR RULE 4 ORDER THAT THIS CASE IS NOT TO BE CONSOLIDATED WITH ANY OTHER CASE
deposition ×100 · FME ×32 · denial ×7 · sanction ×7 · protective order ×5 · bad faith ×1
PAGE 11 · FME, sanction, deposition
… sitions. The need to limit the deposition of Ms. Ress is particularly acute given her testimony in Hursh revealed that she has virtually no knowledge about the FME — the topic on which Plaintiffs insisted her deposition. Indeed, Ms. Ress’s first deposition should not have lasted even 6 hours, let alone the 12 total Plaintiffs now pursue. During her Hursh deposition, Plaintiffs’ counsel questioned her repeatedly about …
PAGE 2 · FME, denial, protective order, deposition
… rsh have repeatedly argued, the testimony they seek from the State Farm Deponents is non-claim-specific knowledge about the Fire Model Enhancement initiative (“FME”). While all the State Farm Deponents, except Mr. Moss (see footnote 1), have since been deposed in Hursh, rendering consolidation moot, the crux of the issue remains the same: it would be duplicative for the State Farm Deponents to sit for full deposition …
PAGE 4 · FME, protective order, deposition
… r testimony here, which was the same reason Plaintiffs’ counsel sought their testimony in Hursh, is to inquire as to the State Farm Deponents’ knowledge of the FME. Indeed, Ms. Manduca, whom Plaintiffs’ counsel has already deposed, is the person with the most specific knowledge on the FME topics pursued by Plaintiffs. Nonetheless, Plaintiffs’ counsel already—and extensively—covered the FME with the State Farm Deponen …
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