WEST V. STATE FARM FIRE & CASUALTY CO.
Comanche County District Court, CJ-2025-135 · Filed 2026-04-24 · 8 pages · Download the PDF
IN THE DISTRICT COURT OF COMANCHE COUNTY STATE OF OKLAHOMA FILED DISTRICT COURT COMANCHE COUNTY, OKLAHOM. April 23, 2026 3:23 PM ROBERT MORALES, COURT CLERI NEIL and LACY WEST, Plaintiffs, Case Number CJ-2025-135 Vv. Case No. CJ-2025-135 STATE FARM FIRE AND CASUALTY COMPANY and NANCY HOLCOMB INS. AGENCY, INC., JUDGE SHEPERD Defendants. DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S REPLY IN SUPPORT OF MOTION FOR ENTRY OF PROTECTIVE ORDER
protective order ×23 · bad faith ×1 · deposition ×1
PAGE 5 · protective order, deposition
deposition. Reed v. Bennett, 193 F.R.D. 689 (D. Kan. 2000)—a twenty-five-year-old case from Kansas—is equally distinguishable because the disputed protective order in that case allowed for designation of anything that a party “reasonably contends contain[s] proprietary and confidential information” rather than a good faith limitation tied to the 3226(C) standard like the one in the Proposed PO. Reed, 193 F.R.D. at 69 …
PAGE 4 · bad faith, protective order
… n on the Producing Party.” Proposed PO, 411 (emphasis added), As such, Plaintiffs can easily defeat State Farm’s alleged ability to over-designate documents in bad faith without check; if Plaintiffs are so confident of over-designation, then they should prevail in court. Requiring the parties to meet and confer before a motion is filed does nothing to shift this explicit burden and directly aligns with the goal of re …
PAGE 6 · protective order
… evention of the abuse that can attend the coerced production of information under a State’s discovery rule is sufficient justification for the authorization of protective orders.”); Micron Technology, at 683 (“Protective orders facilitate production. Corporations are quicker to release their documents if they know the information will not be revealed in the Wall Street Journal or in the local paper’s business section …
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