WEST V. STATE FARM FIRE & CASUALTY CO.
Comanche County District Court, CJ-2025-135 · Filed 2026-03-02 · 13 pages · Download the PDF
IN THE DISTRICT COURT OF COMANCHE COUNTY STATE OF OKLAHOMA Senet Seren” Case Number CJ-2025-135 Case No, CJ-2025-135 Defendants. nae” Sua” Sena Saar! STATE FARM FIRE & CASUALTY COMPANY and NANCY HOLCOMB INS. AGENCY, INC., February 27, 2026 4:18 PM ROBERT MORALES, COURT CLERK Neue v. COMANCHE COUNTY, OKLAHOMA Snare Near? Sema Plaintiffs, FILED DISTRICT COURT Nema NEIL and LACY WEST, DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S REPLY IN SUPPORT OF MOTION FOR PROTECTIVE ORDER AND TO QUASH AND/OR STAY DEPOSITION NOTICE OF NICOLE MANDUCA
deposition ×14 · Xactimate ×8 · indemnity ×7 · FME ×4 · denial ×2 · protective order ×2 · roof replacement ×2 · bad faith ×1
PAGE 3 · FME, indemnity, roof replacement
… .) Plaintiffs also distort the testimony of former Claim Consultant Tom Moss in Barnett v. State Farm, CJ-2020-141 (Grady Co. Okla. April 8, 2024) to argue the FME “worked with State Farm’s Enterprise Technology division to create rules within State Farm’s Xactware software” and that “State Farm uses these rules to accomplish pre-determined objectives”—including “total roof replacement.” (Resp. at 7-8.) But Mr. Moss …
PAGE 4 · denial, bad faith, deposition
“scheme” and speculating the scheme “includes Plaintiffs’ claim denial” (Resp. at 13) does not support an order compelling the testimony. IE. Plaintiffs’ Notice is Not Proportional to the Needs of the Case. Likewise, Plaintiffs’ bald contention that Ms. Manduca’s testimony “meets the requisite proportionality factors” is not based on applicable law or fact. (Resp. at 14.) Plaintiffs’ conclusory argument that Ms. Mand …
PAGE 6 · protective order, deposition
… ts the declarant to a full deposition on the merits in a different case.° IV. CONCLUSION State Farm respectfully requests that the Court grant its Motion for a Protective Order and to Quash Plaintiffs’ Deposition Notice of Nicole Man uca and enter the “oe PY ed therein. LA \ - ~Timila S.Niu Mt OBA #14310 Paige A. Masters, OBA #31142 Amanda M. Finch, OBA #34650 CROWE & DUNLEVY A Professional Corporation Braniff Buildi …
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