STATE FARM HAIL-CLAIM LITIGATION
Oklahoma · Filed 2026-10-23 · 66 pages · Download the PDF
: FILED IN DISTRICT COURT OKLAMOMA COUNTY -« IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA OCT 28 2026 TO. —_ BILLY & LACY HURSH, Plaintiffs, v. Case No. CJ-2025-2626 STATE FARM FIRE AND CASUALTY COMPANY; MARK D. WELTY; and MARK D. WELTY INSURANCE AGENCY, INC., Honorable Amy Palumbo Defendants. PLAINTIFFS’ RESPONSE AND OBJECTION TO DEFENDANT STATE FARM’S BRIEF IN SUPPORT OF APPLICATION OF ATTORNEY-CLIENT PRIVELEDGE AND WORK PRODUCT PROTECTIONS TO HUR00158701-19
protective order ×27 · roof replacement ×24 · deposition ×22 · FME ×19 · denial ×17 · indemnity ×7 · Hail Focus ×4 · sanction ×2
PAGE 47 · 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-half- years before Plaintiffs’ purported dates of losses. Upon the entry of an approved protective order, State Farm is willing to produce the versions of …
PAGE 43 · Hail Focus, denial, roof replacement
… vant to the claims or defenses or proportional to the needs of the case. State Farm also objects to this Request as vague and ambiguous as to what is meant by “Hail Focus Initiative,’ “Hail Initiative,” “other similarly named initiatives or programs,” “targeted Oklahoma as a state to implement,” and “after implementation in Texas.” The Request is an overly broad, incomplete hypothetical irrelevant to the Plaintiffs’ …
PAGE 44 · denial, roof replacement
… this Request because it is irrelevant, improperly assumes facts and is vague and ambiguous. Subject to these objections and State Farm’s Universal Objections, denied. REQUEST FOR ADMISSION NO. 26: Admit that since J anuary 1, 2019, You review and/or track the percentages of total or full roof replacements by individual adjusters and managers on wind/hail claims. RESPONSE TO REQUEST NO. 26: State Farm objects to this …
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