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STATE FARM HAIL-CLAIM LITIGATION

20261020-1067185039-defendant-s-motion-for-a-protective-order-and-to-quash-plaintiffs.pdf

Oklahoma · Filed 2026-10-20 · 48 pages · Download the PDF

What this document says (first page, verbatim)

IN THE DISTRICT COURT OF OKLAHOMA STATE BILLY and LACY COUNTY FILED DISTRICT COURT OF OKLAHOMA HURSH, ) Plaintiffs, V. COUNTY, October 20, 2026 4:43 PM ) RICK WARREN, COURT CLERK ) Case Number CJ-2025-2626 Case No. CJ-2025-2626 Hon. Amy Palumbo ) D._) ) ) Defendants. ) DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S MOTION FOR A PROTECTIVE ORDER AND TO QUASH PLAINTIFFS’ DEPOSITION NOTICE OF STATE FARM’S CORPORATE REPRESENTATIVE, AND BRIEF IN SUPPORT Defendant State Farm Fire and Casualty Company (‘State Farm’), pursuant to 12 O.S. …

Key terms in this filing

roof replacement ×81 · deposition ×73 · FME ×41 · indemnity ×31 · Hail Focus ×12 · denial ×5 · bad faith ×5 · protective order ×5

Notable passages

PAGE 37 · Hail Focus, indemnity, deposition, roof replacement

… ing of certain all states in the United States and implementation 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 similarly named initiatives or programs, including but not limited to: a. Your testing and/or pilot initiatives conducted in states to test loss reduction and/or quality strategies related to wind/hail …

PAGE 38 · Hail Focus, indemnity, deposition, roof replacement

… PIC NO.5. The targeting of Oklahoma as a state and implementation 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 similarly named initiatives or programs after implementation in Texas, including: a. Your testing and/or pilot initiatives conducted in Oklahoma to test loss reduction and/or quality strategies related …

PAGE 36 · Hail Focus, indemnity, deposition, roof replacement

… ndard and/or to a related benchmark. TOPIC NO. 3. Your Wind/Hail Kickoff, The Fire Model Enhancement -Wind/Hail, the Wind and Hail Fire Model Enhancement Team, Hail Focus Initiative and/or Hail Initiative and/or any hail quality focus initiative for the kickoff in Dallas County, Texas, including (but not limited to): a. Your testing and/or pilot initiatives conducted in Texas to test loss reduction or quality strateg …

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