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WEST V. STATE FARM FIRE & CASUALTY CO.

20261002-1067062790-defendant-state-farm-fire-and-casualty-company-s-opposition-to.pdf

Comanche County District Court, CJ-2025-135 · Filed 2026-10-02 · 61 pages · Download the PDF

What this document says (first page, verbatim)

FILED DISTRICT COURT IN THE DISTRICT COURT OF COMANCHE COUNTY COMANCHE COUNTY, OKLAHOMA STATE OF OKLAHOMA ROBERT MORALES, COURT CLERK seco Kr Case Number CJ-2025-135 ene Plaintiffs, Nee gee nee NEIL and LACY WEST, Defendants. Ne er Nee Nee eee STATE FARM FIRE & CASUALTY COMPANY and NANCY HOLCOMB INS. AGENCY, INC., Case No. CJ-2025-135 Nee Nene Vv. DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S OPPOSITION TO PLAINTIFFS’ EMERGENCY MOTION FOR EXPEDITED RULING, WITHOUT HEARING, ON PLAINTIFFS’ PENDING MOTION FOR DISCOVERY SANCTIONS AND FOR AN ORDER COMPELLING THE RESUMED DEPOSITION OF NICOLE MANDUCA, OR IN THE ALTERNATIVE FOR AN EMERGENCY HEARING

Key terms in this filing

bad faith ×55 · sanction ×52 · deposition ×43 · denial ×16 · protective order ×2 · summary judgment ×2

Notable passages

PAGE 2 · sanction, deposition

Plaintiffs’ motion for an expedited ruling on their pending discovery sanctions motion or, alternatively, an emergency hearing (the “Emergency Motion”) is not well taken. At the September 24 hearing, Plaintiffs’ counsel prioritized a premature motion on consolidation issues over their pending discovery sanctions motion (“Motion for Sanctions”) they now seek to expedite, and rebuffed counsel for State Farm’s effort to …

PAGE 4 · sanction, deposition

… ) The Court reporter provided the parties the final transcript for Ms. Manduca’s deposition on July 7, 2026. (See Exhibit 2.) Plaintiffs filed their Motion for Sanctions three weeks afterwards on July 28, 2026, seeking additional deposition time to depose Ms. Manduca. They did so only after State Farm filed the Motion for Deposition Protocol. The Court set a hearing on September 24, 2026, to hear six motions. At the …

PAGE 5 · bad faith, sanction, deposition

… go back and we’re going to file a brief. I’m going to ask for a sanction that you’re -- that the Court instruct the jury that you have now -- you have to admit bad faith because you will not respond

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