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STATE FARM HAIL-CLAIM LITIGATION

20260929-1066970697-defendant-state-farm-fire-and-casualty-company-s-amended-motion-for.pdf

Oklahoma · Filed 2026-09-29 · 70 pages · Download the PDF

What this document says (first page, verbatim)

IN THE DISTRICT COURT OF OKLAHOMA STATE OF OKLAHOMA BILLY and LACY HURSH, Plaintiffs, v. STATE FARM FIRE & CASUALTY COMPANY; MARK D. WELTY; and MARK D._ WELTY INS. AGENCY, INC., ) COUNTY FILED DISTRICT COURT OKLAHOMA COUNTY, OKLAHOMA ) September 29, 2026 2:59 PM ) RICK WARREN, COURT CLERK ) Case Number CJ-2025-2626 ) Case No. CJ-2025-2626 ) Hon. Amy Palumbo ) ) ) ) Defendants. ) DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S AMENDED MOTION FOR A PROTECTIVE ORDER AND TO QUASH PLAINTIFFS’ DEPOSITION NOTICE OF STATE FARM’S OPERATIONS VICE PRESIDENT MICHAEL KEATING, AND BRIEF IN SUPPORT Defendant State Farm Fire and Casualty Company (‘State Farm”), pursuant to 12 O.S. …

Key terms in this filing

deposition ×97 · FME ×47 · protective order ×11 · indemnity ×8 · denial ×7 · roof replacement ×5 · bad faith ×2

Notable passages

PAGE 48 · FME, denial, indemnity, deposition

… hed the Notice of Deposition for Jon Farney for July 20, 2026, former State Farm Sr. VP, Treasurer, and CFO as well as current CEO. Farney’s involvement in the FME, P&C tactics and Wind/Hail success, his knowledge of indemnity reductions on FME Wind/Hail as well as his direct involvement in State Farm’s Fix Profit Task Force, which directly involved Wind/Hail claims are all directly related to State Farm’s FME and co …

PAGE 3 · FME, denial, indemnity, deposition, roof replacement

theories of the FME’s influence on claim handling generally. State Farm has produced over a thousand documents related to Plaintiffs’ claims, including Plaintiffs’ policy, their Claim File, three years of financial and annual statements, underwriting guidelines in effect when Plaintiffs’ policy was issued, applicable claim-handling guidelines in place at the time of the alleged loss, Wind and Hail Guidelines, perform …

PAGE 4 · FME, denial, deposition, roof replacement

testimony and documents on 30 topics with 101 subparts, spanning 15 years of corporate operations (including multiple topics regarding the FME), and noticed the depositions of eight current and former employees. Over State Farm’s objections, the Court denied State Farm’s motions to quash the corporate representative notice and Plaintiffs’ notices of deposition to: Jon Farney, State Farm’s CEO, whom Plaintiffs contend …

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