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WEST V. STATE FARM FIRE & CASUALTY CO.

20260914-1066829569-state-farm-reply-deposition-protocol-west-ress-excerpts.pdf

Comanche County District Court, CJ-2025-135 · Filed date not stated · 35 pages · Download the PDF

What this document says (first page, verbatim)

FILED DISTRICT COURT COMANCHE COUNTY, OKLAHOMA September 14, 2026 4:44 PM IN THE DISTRICT COURT OF COMANCHE COUNTY STATE OF OKLAHOMA NEIL and LACY WEST, = “OOPRECaseMORALES, COURT CLERK Number CJ-2025-135 ) ) Plaintiffs, ) ) v. ) Case No. CJ-2025-135 ) STATE FARM FIRE & CASUALTY COMPANY and NANCY HOLCOMB INS. AGENCY, INC., ) ) ) ) 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

Key terms in this filing

deposition ×70 · sanction ×18 · protective order ×2 · FME ×1 · bad faith ×1

Notable passages

PAGE 3 · sanction, deposition

… ent further disputes over counsel’s misconduct 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 9-12)—is basel …

PAGE 5 · deposition

IU. PLAINTIFFS’ UNSUPPORTED ACCUSATIONS OF MISCONDUCT AT OTHER DEPOSITIONS AND CONTINUED TRANSGRESSIONS FURTHER SUPPORT ENTRY OF A DEPOSITION PROTOCOL. Plaintiffs argue that any protocol would be “pointless” because State Farm’s counsel purportedly committed “blatant violations” of the Protocol in other depositions. makes no sense. That argument The proposed Protocol would bind all counsel, including State Farm’s. If …

PAGE 4 · protective order, sanction, deposition

… pite Plaintiffs’ overwrought rhetoric, there is nothing “self-serving” or “weaponized” about the proposed Protocol. (See Pls.’ Resp. at 12.) State Farm seeks a protective order and deposition protocol—rather than sanctions or a bar complaint—to lower the already heated temperature created by Ms. Manduca’s deposition, and to avoid further disputes and discourteous and abusive treatment of witnesses caused by counsel’s …

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