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STATE FARM HAIL-CLAIM LITIGATION

20261019-1067142063-plaintiffs-corrected-emergency-motion-to-compel-re-production-of.pdf

Oklahoma · Filed 2026-10-19 · 295 pages · Download the PDF

What this document says (first page, verbatim)

IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA FILED DISTRICT COURT OKLAHOMA BILLY & LACY HURSH, Plaintiffs, Vv. COUNTY, OKLAHOMA October 19, 2026 10:24 AM RICK WARREN, COURT CLERK Case Number CJ-2025-2626 STATE FARM FIRE AND CASUALTY MARK D. WELTY; and Honorable Amy Palumbo MARK D. WELTY INSURANCE AGENCY, INC., Defendants. REDACTED PLAINTIFFS’ CORRECTED! EMERGENCY MOTION TO COMPEL REPRODUCTION OF ELECTRONICALLY STORED INFORMATION IN THE FORM DEFENDANT STATE FARM ELECTED, AND BRIEF IN SUPPORT ' Plaintiffs’ only correction is to include ‘Emergency’ in the title. Exhibits and brief remain the same.

Key terms in this filing

roof replacement ×148 · denial ×78 · FME ×58 · Hail Focus ×54 · protective order ×53 · indemnity ×49 · deposition ×43 · bad faith ×14

Notable passages

PAGE 78 · FME, denial, indemnity, deposition, roof replacement

… ition of any State Farm employee who actually handled Plaintiffs’ insurance claim. Plaintiffs justified those requests with the same “pattern and practice” and FME-related allegations they advance here. On December 31, 2025, this Court denied State Farm’s motions to quash the deposition notices for the corporate representative and individual employees. State Farm then pursued its right to seek appellate review of the …

PAGE 90 · deposition

… to ignore the requirements of [Fed. R. Civ. P.] 33(a)(1), which contains an unambiguous limitation on the number of interrogatories which can be propounded”). Deposition Transcripts (RFPs 53-57). Plaintiffs seek the deposition transcripts and exhibits for the following current and former State Farm employees from five unrelated lawsuits involving different insureds, coverage issues, claim handling personnel, weather …

PAGE 144 · FME, OG 75-160, indemnity, protective order, roof replacement

documentation, conducting additional training, and increasing management involvement.!° The FME prepared guidelines in 2020 and 2021 (the “Wind/Hail Guidelines”), which State Farm incorporated into Operation Guide (“OG”) 75-160 by February 2022, more than one-and-a-halfyears before Plaintiffs’ purported dates of losses. Upon the entry of an approved protective order, State Farm is willing to produce the versions of O …

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