STATE FARM HAIL-CLAIM LITIGATION
Oklahoma · Filed 2026-10-02 · 84 pages · Download the PDF
FILED IN DISTRICT COUR T TARRAIRUN | 11 pisrracr court oF oxzasiona comRRAROMA COUNTY TE OF OKLAHOMA BILLY & LACY OCT - 2 2006 RICK HURSH, Wz, courr PARREN 108 Plaintiffs, v. Case No. CJ-2025-2626 Honorable Amy Palumbo STATE FARM FIRE AND CASUALTY COMPANY; MARK WELTY; and MARK D. WELTY INSURANCE AGENCY, INC., D. Defendants. PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S AMENDED MOTION FOR PROTECTIVE ORDER AND TO QUASH DEPOSITION NOTICE OF MICHAEL KEATING AND COUNTER MOTION FOR RULE 4 ORDER
deposition ×45 · protective order ×41 · denial ×18 · bad faith ×14 · roof replacement ×5 · Hail Focus ×3 · FME ×2 · indemnity ×2
PAGE 6 · denial, protective order, deposition
… ) (“Absent extraordinary circumstances, it is rare for a court to disallow the taking of a deposition. .. [Aj strong showing is required before a party will be denied entirely the right to take a deposition. ... A party seeking to prevent a deposition carries a heavy burden to show why discovery should be denied. ... [I]t is very unusual for a court to prohibit the taking of a deposition altogether absent extraordina …
PAGE 2 · denial, indemnity, bad faith, protective order, deposition
… il or email.”). In support, Plaintiffs state as follows: I. INTRODUCTION Plaintiffs allege a broad-reaching and pervasive Scheme by State Farm to pre-textually deny wind and hail damage claims warranting total roof replacements through the development, implementation, and refinement of various bad faith claims-handling tactics. After the WHMET created these tactics, the Fix Profit Task Force—formerly known as the “Ke …
PAGE 5 · denial, protective order, deposition
… Apache Corp., 2025 WL 872531, at *3 (D.N.M. Mar. 20, 2025) (“A party seeking to prevent a deposition ... carries a heavy burden to show why discovery should be denied—and absent extraordinary circumstances—it is very unusual for a court to prohibit the taking of a deposition.”); Halley v. State of Oklahoma, 2016 WL 4995393, at *1 (E.D. Okla. Sept. 19, 2016) (“A party seeking to quash a deposition has a ‘heavy burden …
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