STATE FARM HAIL-CLAIM LITIGATION
Oklahoma · Filed 2026-10-02 · 159 pages · Download the PDF
CURATION crate pisteicr court oF OKLAHOMA COUNTED IN DISTRICT COURT OKLABOMA STATE OF OKLAHOMA OCT - 2 2026 BILLY & LACY HURSH Pia Vv. 108 STATE FARM FIRE AND CASUALTY COMPANY; MARK D. WELTY; and Teta Ne Case No. CJ-2025-2626 Honorable Amy Palumbo MARK D. WELTY INSURANCE AGENCY, INC., Defendants. COUNTY REDACTED PLAINTIFFS’ MOTION TO COMPEL RE-PRODUCTION OF DEFENDANT ELECTRONICALLY STORED INFORMATION IN THE FORM STATE FARM ELECTED, AND BRIEF IN SUPPORT
FME ×51 · roof replacement ×44 · deposition ×34 · denial ×30 · protective order ×29 · indemnity ×17 · bad faith ×12 · Hail Focus ×4
PAGE 83 · FME, denial, indemnity, deposition, roof replacement
… ition of any State Farm employee who actually handled Plaintiffs’ insurance claim. Plaintiffs justified those requests with the same “pattern and practice” and FME-related allegations they advance here. On December 31, 2025, this Court denied State Farm’s motions to quash the deposition notices for the corporate representative and individual employees. State Farm then pursued its right to seek appellate review of the …
PAGE 95 · deposition
… to ignore the requirements of [Fed. R. Civ. P.] 33(a)(1), which contains an unambiguous limitation on the number of interrogatories which can be propounded”). Deposition Transcripts (RFPs 53-57). Plaintiffs seek the deposition transcripts and exhibits for the following current and former State Farm employees from five unrelated lawsuits involving different insureds, coverage issues, claim handling personnel, weather …
PAGE 157 · FME, OG 75-160, indemnity, protective order, roof replacement
documentation, conducting additional training, and increasing management involvement.'® The FME prepared guidelines in 2020 and 2021 (the “Wind/Hail Guidelines”), which State Farm incorporated into Operation Guide (“OG”) 75-160 by February 2022, more than one-and-a-halfyears before Plaintiffs’ purported dates of losses. Upon the entry of an approved protective order, State Farm is willing to produce the versions of O …
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