STATE FARM HAIL-CLAIM LITIGATION
Oklahoma · Filed 2026-11-09 · 71 pages · Download the PDF
nant = . lw IN THE DISTRICT COURT OF OKLAHOMA STATE OF OKLAHOMA BILLY and LACY HURSH, Plaintiffs, v. FILED IN DISTRICT COURT COUNTYOKLAHOMA COUNTY oe NOV -9 2026 RICK 115 WARREN COURT CLERK Case No. CJ-2025-2626 STATE FARM FIRE AND CASUALTY COMPANY, MARK D. WELTY, and MARK D. WELTY INSURANCE AGENCY, INC., Judge Amy Palumbo mee _ Defendants. PLAINTIFFS’ RESPONSE IN OPPOSITION TO 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
deposition ×28 · protective order ×26 · FME ×23 · denial ×15 · indemnity ×15 · roof replacement ×9 · bad faith ×3 · Hail Focus ×2
PAGE 6 · Hail Focus, FME, denial, indemnity, bad faith
… s Indemnity-Reduction Scheme at the Center of This Case. The Hurshes allege State Farm’s denial of their roof claim resulted from a scheme born of State Farm’s Hail Focus Initiative, “which set out to reduce State Farm’s indemnity losses on wind and hailstorm claims-—most critically, total roof replacements.” Pet. § 4(f). They allege State Farm “established the goal of reducing its indemnity payments by denying full …
PAGE 5 · FME, indemnity, deposition
… rt to bar a corporate deposition on thirteen topics about one subject: the rewards State Farm paid to the people who built and ran the Fire Model Enhancement (“FME”) Scheme, and the metrics those rewards tracked. The subject comes from State Farm’s own documents. In November 2021, Nicole Manduca and Dana Jokerst proposed $27,250 in rewards to FME committee members and explained they ‘x with wind/hail 0 ees” Exhibit | …
PAGE 10 · deposition
II. A. ARGUMENT AND AUTHORITIES The Leave Requirement Does Not Bar This Deposition, and the Court Should Grant Leave Now. 1. The Court Has Already Ordered Further Corporate Testimony, and Plaintiffs Request Leave to the Extent the Court Requires It. State Farm’s lead argument rests on 12 O.S. § 3230(A)(2), which requires leave of court if, without the written stipulation of the parties, “the person to be examined alr …
Search every page of this and 59 other filings: full-text search · Context: Trial Watch calendar
← 20261109-1067130720-order-granting-plaintiffs-application-for-leave-to20261109-1067358641-plainitffs-application-leave-to-file-under-seal.pd →
The Hursh v. State Farm jury trial is set for December 7: follow it on Trial Watch Live. One email per development — filings and unsealed documents only, no marketing, unsubscribe in one click.
Your address is used only for these alerts and is never shared or added to any sales list.
Excerpts are verbatim OCR text from the public court record and may contain OCR errors; refer to the PDF for the authoritative text, or obtain certified copies from the court clerk for court use. Allegations in filings are claims made by parties in litigation, not findings of fact.
About the host: Allied Emergency Services is a licensed storm-damage restoration contractor serving Illinois, Wisconsin, Indiana and Michigan — not a law firm, insurance adjuster or public adjuster, and this page is not legal or insurance advice. We inspect, document, provide insurance-ready repair estimates and complete repairs; coverage decisions always belong to you and your insurer. 24/7: (800) 792-0212