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WEST V. STATE FARM FIRE & CASUALTY CO.

Motion for Protective Order and to Quash (West v. State Farm, 2026-01-08)

Comanche County District Court, CJ-2025-135 · Filed 2026-01-08 · 14 pages · Download the PDF

What this document says (first page, verbatim)

FILED IN THE DISTRICT COURT OF COMANCHE STATE OF COUNTY OKLAHOMA DISTRICT COURT COMANCHE COUNTY, OKLAHOMA January 7, 2026 4:46 PM ROBERT MORALES, COURT CLERK Case Number CJ-2025-135 NEIL and LACY WEST, ) Plaintiffs, ) ) ) vs. Case No. CJ-2025-135 STATE FARM FIRE AND CASUALTY ) COMPANY and NANCY HOLCOMB INS. _ ) AGENCY, INC., ) Defendants. ) ) DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S MOTION FOR PROTECTIVE ORDER AND TO QUASH AND/OR STAY DEPOSITION NOTICE OF NICOLE MANDUCA AND BRIEF IN SUPPORT Defendant State Farm Fire and Casualty Company (“State Farm”), pursuant to 12 O,S. …

Key terms in this filing

deposition ×28 · FME ×4 · protective order ×4 · denial ×3 · bad faith ×1

Notable passages

PAGE 1 · protective order, deposition

… 5 STATE FARM FIRE AND CASUALTY ) COMPANY and NANCY HOLCOMB INS. _ ) AGENCY, INC., ) Defendants. ) ) DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S MOTION FOR PROTECTIVE ORDER AND TO QUASH AND/OR STAY DEPOSITION NOTICE OF NICOLE MANDUCA AND BRIEF IN SUPPORT Defendant State Farm Fire and Casualty Company (“State Farm”), pursuant to 12 O,S. §§ 3226(B)(2)(c), 3226(C), and 3226.1, respectfully moves for a protective ord …

PAGE 8 · FME, denial, deposition

… as any unique, relevant, or proportional information, taking her deposition is at the very least premature until and unless Plaintiffs can demonstrate that the FME is relevant to their claims. B. The Deposition of Ms. Manduca Is Not Proportional to the Needs of the Case. Even assuming Plaintiffs could satisfy their burden of showing relevance, the Court should quash the Manduca Notice because Ms. Manduca’s testimony …

PAGE 9 · protective order, deposition

… ion could be obtained from other sources without the depositions of the officers sought. /d. Accordingly, the Northern District granted Allstate’s motion for a protective order prohibiting the depositions of the officers. /d. Like the officers in Evans, Ms. Manduca has no unique personal knowledge of the facts and circumstances surrounding Plaintiffs’ insurance claim. Indeed, Ms. Manduca does not even manage those wh …

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Motion to Strike (West v. State Farm, 2025-12-31)Notice of Subpoena to Produce and Permit Inspection and Copying of Doc

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