STATE FARM HAIL-CLAIM LITIGATION
Oklahoma · Filed 2026-10-21 · 14 pages · Download the PDF
FILED DISTRICT COURT OKLAHOMA IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA COUNTY, OKLAHOMA = ©“tober 21, 2026 5:21 PM RICK WARREN, COURT CLERK Case Number CJ-2025-2626 BILLY & LACY HURSH, Plaintiffs, V. STATE FARM FIRE AND CASUALTY COMPANY; Case No. CJ-2025-2626 Honorable Amy Palumbo MARK D. WELTY; and MARK D. WELTY INSURANCE AGENCY, INC., Defendants. PLAINTIFFS’ REPLY IN SUPPORT OF THEIR MOTION TO COMPEL REPRODUCTION OF ELECTRONICALLY STORED INFORMATION IN THE FORM DEFENDANT STATE FARM ELECTED
denial ×2 · deposition ×2 · bad faith ×1 · protective order ×1 · sanction ×1
PAGE 4 · denial, bad faith, protective order
… n a good cause showing for substantial need,” because “there is no other method to precisely determine the facts upon which [the insurer] based its decision to deny the claim.” Jd. § 13, 775 P.2d at 296. The burden of showing work-product protection rests with the party asserting it. Jd. at 295 n.7. See Mot. at 13. State Farm’s authorities establish relevance. The Response quotes Aguilar v. Immigration & Customs Enfo …
PAGE 6 · denial, sanction
… ata intact while permitting removal of “the metadata directly corresponding to the redacted information.” 230 F.R.D. at 656. The request for expenses should be denied. In National Jewish Health the prevailing producing party sought its fees and was refused: “reasonable minds could—and often do—differ with regard to ESI.” 305 F.R.D. at 256. Plaintiffs respectfully request that the Court order State Farm to produce the …
PAGE 13 · deposition
… ORDS NOW HOUSED IN WORKDAY 16. — I submit the following to identify a separate production deficiency that Plaintiffs expect to raise with the Court. I took the deposition of State Farm’s corporate representative Wayne Stewart on September 29, 2026. Mr. Stewart was designated to testify on Topic 25H, the use of a State Farm system identified as MyBlock. 17. system. Documents State Farm has produced identify MyBlock as …
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