STATE FARM HAIL-CLAIM LITIGATION
Oklahoma · Filed 2026-10-16 · 54 pages · Download the PDF
wR IN THE DISTRICT COURT OF CLEVELAND COUNTY STATE OF OKLAHOMA STATE OF OKLAHOMA, ex rel. GENTNER DRUMMOND, OKLAHOMA ATTORNEY| GENERAL ? o, F OKcouoMA Ss. CLSTATE EVELAND FIL Ep Plaintiff, . Case No. CJ-2026-1066 OCT IG agg = Hon. Jeff Virgin v. In the STATE FARM FIRE AND CASUS#4Glerk MakicS Of the COMPANY, YN WILLIAMS Defendant. PLAINTIFF STATE OF OKLAHOMA’S RESPONSE IN OPPOSITION TO. DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S MOTION TO DISQUALIFY WHITTEN BURRAGE AS COUNSEL FOR PLAINTIFF
deposition ×6 · denial ×4 · protective order ×4 · Hail Focus ×2 · indemnity ×1 · bad faith ×1
PAGE 31 · deposition
… rring fees for investigative services and expert witness fees or before incurring any unusual or extraordinary expense, including but not limited to electronic deposition transcript costs, expedited deposition transcript costs, videotape deposition costs, real time deposition and court proceeding transcript costs, court reporter out-of-town travel expenses, court room technology costs, and travel costs related to sen …
PAGE 7 · Hail Focus, denial, indemnity
… insureds, or putative class of private claimants,” id. { 54. The Petition alleges that State Farm implemented an internal program “commonly referred to as the ‘Hail Focus Initiative’ to drastically reduce aggregate roof indemnity payments in Oklahoma.” Id. 1; see id. JJ 17-26. The remedies it seeks—“injunctive relief to dismantle the scheme, civil penalties to deter future violations, disgorgement of ill-gotten gains …
PAGE 23 · protective order
… consent. Jd. § 1415(B) (quoted at Mot. at 17). Neither provision addresses discovery in a pending civil action, which proceeds under the ordinary rules and any protective order the Court enters. No § 1415 subpoenas have issued in this matter (Exhibit 4 (Capps Decl.) | 10; see also Exhibit 5 (Whitten Decl.) ¥ 8; Exhibit 6 (Burrage Decl.) § 8) and State Farm knows this. The Open Records Act provision permits the Attorn …
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