STATE FARM HAIL-CLAIM LITIGATION
Oklahoma · Filed 2026-10-02 · 150 pages · Download the PDF
STONE 69071% they are not relevant to the issues in Plaintiffs’ claims or this lawsuit. Despite the lack of relevance and proportionality, upon entry of an approved protective order, State Farm will produce OG 75-160, which describes the small subset of wind/hail claims under specific low recommendations intensity weather is required. Any conditions additional managerial in which production of information review of total roof in response to the Managerial Approval Requests is neither relevant nor proportional. G. State Farm’s Enterprise Rules (RFP 25) Plaintiffs’ actual RFP No. 25 seeks documents “memorializing any enterprise-wide rule ... …
roof replacement ×97 · denial ×48 · Hail Focus ×47 · indemnity ×32 · protective order ×25 · deposition ×9 · FME ×7 · bad faith ×2
PAGE 99 · Hail Focus, denial, roof replacement
… s Universal Objections, denied. ADMISSION NO.18: Admit You developed the Fire Model Enhancement - Wind/Hail, the Wind and Hail Fire Model Enhancement Team, the Hail Focus Initiative and/or Hail Initiative and/or other initiatives or programs to apply on first-party claims to seek a reduction in the amount You spent each year on total roof replacements, lower the ratio of total or full roof replacements to partial roo …
PAGE 100 · Hail Focus, denial, roof replacement
FOR ADMISSION NO.19: Admit You tracked the results of the Fire Model Enhancement - Wind/Hail, the Wind and Hail Fire Model Enhancement Team, the Hail Focus Initiative and/or Hail Initiative and/or other initiatives or programs in the amount You spent each year on total roof replacements, the ratio of total or full roof replacements to partial roof replacements, the full roof replacement approval percentage, and/or na …
PAGE 102 · Hail Focus, denial, roof replacement
… vant to the claims or defenses or proportional to the needs of the case. State Farm also objects to this Request as vague and ambiguous as to what is meant by “Hail Focus Initiative,’ “Hail Initiative,” “other similarly named initiatives or programs,” “targeted Oklahoma as a state to implement,” and “after implementation in Texas.” The Request is an overly broad, incomplete hypothetical irrelevant to the Plaintiffs’ …
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