WEST V. STATE FARM FIRE & CASUALTY CO.
Comanche County District Court, CJ-2025-135 · Filed 2026-10-08 · 20 pages · Download the PDF
IN THE DISTRICT COURT OF OKLAHOMA STATE OF OKLAHOMA mgt! FILED DISTRICT COURT agit! NEIL AND LACY WEST, COUNTY mage October 8, 2026 4:57 PM ROBERT MORALES, COURT CLERK agit Plaintiffs, COMANCHE COUNTY, OKLAHOMA Case Number CJ-2025-135 Case No. CJ-2025-135 Defendants. Senet Senet” Nm Nena STATE FARM FIRE AND CASUALTY COMPANY and NANCY HOLCOMB INS. AGENCY, INC., aa engi! one V. DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S RESPONSE AND OPPOSITION TO (1) PLAINTIFFS’ MOTION TO RECONSIDER THE ENTRY OF A DEPOSITION PROTOCOL AND (2) PLAINTIFES’ SUPPLEMENTAL BRIEF REGARDING THE SEPTEMBER 24, 2026 PROTECTIVE ORDER AND DEPOSITION PROTOCOL
deposition ×127 · sanction ×20 · bad faith ×13 · protective order ×8 · denial ×5 · indemnity ×1
PAGE 3 · bad faith, protective order, deposition
… opportunity to rebut—that their counsel’s violations of the Local Rules and the OBA’s Standards of Professionalism show that a deposition is being conducted in bad faith. State Farm does not anticipate suspending any deposition without following the Court’s Order and following the established process set forth in 12 O.S. § 3230(E)(2). Nonetheless, Plaintiffs’ insistence on deleting the Deposition Protocol’s sole enfo …
PAGE 15 · bad faith, protective order, deposition
… lously filed to “frustrate[] the fair examination of the deponent.” See 12 O.S. § 32330(E)(1). Further, courts considering a motion to suspend a deposition for bad faith already consider the “subjective” 99 66 “tone and degree” of counsel’s questioning (see Supp. Br. at 4) in determining bad faith. Courts have found a deposition to be harassing and in bad faith where examining counsel asked irrelevant questions!” and …
PAGE 13 · bad faith, sanction, deposition
… l center on paragraphs B(4) and C(6), which merely provide that violations of the Protocol will be prima facie evidence that a deposition is being conducted in bad faith under 12 O.S. § 3230(E)(2).’ Plaintiffs mischaracterize these provisions as allowing “any remaining deposition [to] be halted on an assertion of discourtesy.” page Motion for Discovery Sanctions (along with over 150 pages of exhibits) against State F …
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