WEST V. STATE FARM FIRE & CASUALTY CO.
Comanche County District Court, CJ-2025-135 · Filed 2026-01-28 · 179 pages · Download the PDF
FILED IN THE DISTRICT COURT OF COMANCHE COUNTY DISTRICT COURT oy. cue OUNTY. OKLAHOMA STATE OF OKLAHOMA January 27, 2026 5:03 PM ROBERT MORALES, COURT CLERK aga! Case Number CJ-2025-135 Plaintiffs, Defendants. Seaaatae”—a ieee Newer See STATE FARM FIRE AND CASUALTY COMPANY, and NANCY HOLCOMB INSURANCE AGENCY, INC., Case No. CJ- 2025-135 Honorable Grant Sheperd aate ett cat! Vv. tag mat! NEIL and LACY WEST DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S RESPONSE TO PLAINTIFFS’ MOTION TO COMPEL
roof replacement ×152 · indemnity ×55 · Hail Focus ×53 · denial ×42 · protective order ×27 · FME ×16 · bad faith ×11 · deposition ×11
PAGE 115 · Hail Focus, denial, roof replacement
… bjections, denied. REOUEST FOR ADMISSION 18: NO. Admit You developed the Fire Model Enhancement - Wind/Hail, the Wind and Hail Fire Model Enhancement Team, the Hail Focus Initiative and/or Hail Initiative and/or other initiatives or programs to apply on first-party claims to seek a reduction in the amount You spent each year on total roof replacements, lower the ratio of total or full roof replacements to partial roo …
PAGE 13 · FME, OG 75-160, indemnity, protective order, roof replacement
… odel Enhancement Requests (Rogs 6, 7, 9, 13, 28, and 29; RFPs 14, 15, 21-24, 27, 29, 33, 35-39, and 43). Numerous requests concern the Fire Model Enhancement (“FME”; the “FME Requests”)}—an effort State Farm first undertook in 2020 to improve the accuracy of claim handling, one that is neither sinister nor surprising but part of corporate responsibility. As part of the FME, State Farm identified potential ways to imp …
PAGE 17 · indemnity, deposition, roof replacement
… aim. As such, the Quality Plans Requests are overbroad, irrelevant, and disproportionate to the needs of this case in contravention of 12 O.S. § 3226(B)(1)¢a). Indemnity Requests (Rogs 11, 12, 14, 20, 21, and 24-27; RFPs 7, 13, 16-20, and 28). Plaintiffs broadly seek information about State Farm’s alleged efforts to reduce indemnity payments on wind/hail claims, including cost/benefit analyses, data tracking, and met …
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