WEST V. STATE FARM FIRE & CASUALTY CO.
Comanche County District Court, CJ-2025-135 · Filed 2026-10-27 · 19 pages · Download the PDF
FILED DISTRICT COURT COMANCHE IN THE DISTRICT COURT STATE OF OF COMANCHE COUNTY, OKLAHOMA October 27, 2026 4:11 PM COUNTY ROBERT MORALES, COURT CLERK Case Number CJ-2025-135 OKLAHOMA NEIL and LACY WEST, Plaintiffs, V. STATE FARM FIRE AND CASUALTY CASE COMPANY NO. CJ-2025-135 and NANCY HOLCOMB AGENCY, INC., INS. Defendants. PLAINTIFFS’ RESPONSE TO DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S RENEWED MOTION TO COMPEL EXPERT DISCOVERY Plaintiffs Neil and Lacy West (“Plaintiffs”) file this Response to State Farm Fire and Casualty Company’s (“Defendant” Discovery filed October 9, 2026 or “State (Defendant’s Farm”) Renewed “Motion”). …
deposition ×14 · denial ×10 · indemnity ×5 · sanction ×5 · Hail Focus ×3 · bad faith ×3 · roof replacement ×3 · FME ×2
PAGE 12 · Hail Focus, denial, indemnity, bad faith, roof replacement
… the four corners of the Policy, inadequate. Mr. Romano will and its investigation further testify State was Farm’s Wind/Hail Fire Enhancement program and Wind/Hail Focus Initiative deviated from industry standards and resulted in the wrongful denial of valid claims, including Plaintiffs’ Claim, on a widespread basis. State Farm built its wind/hail program to reduce indemnity, identified roof replacements as an “oppo …
PAGE 11 · FME, indemnity, bad faith, deposition, roof replacement
… y accepted methods of economic and financial analysis, which may include comparing indemnity payments and claim outcomes before and after implementation of the FME, considering alternative explanations for observed changes, analyzing State Farm’s projected and realized savings, and reviewing State Farm’s publicly reported financial information, premiums, and profits. Dr. Young may also testify regarding recognized bu …
PAGE 4 · sanction, deposition
… the discovery process directly impeded Plaintiffs’ ability to prepare expert discovery. Even assuming some modicum of prejudice could be inferred, the extreme sanction of striking Plaintiffs’ experts still would not be justified. See, e.g., Pac. Indem. Co. v. Nidec Motor Corp., 203 F. Supp. 3d 1092, 1097 (D. Nev. 2016). To the extent the Court construes State Farm’s request as seeking a blanket “exclusion of any exp …
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