WEST V. STATE FARM FIRE & CASUALTY CO.
Comanche County District Court, CJ-2025-135 · Filed 2026-06-09 · 78 pages · Download the PDF
IN THE DISTRICT COURT OF COMANCHE COUNTY STATE FILED DISTRICT COURT COMANCHE COUNTY, OKLAHOMA OF OKLAHOMA June 8, 2026 4:55 PM ROBERT NEIL & LACY WEST, ) ) Plaintiffs, ) ) v. ) STATE FARM FIRE & CASUALTY COMPANY and NANCY HOLCOMB INS. ) ) AGENCY, INC., ) MORALES, COURT CLERK Case Number CJ-2025-135 Case No. CJ-2025-135 ) ) Defendants. DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S RESPONSE TO PLAINTIFFS’ SECOND MOTION TO COMPEL
deposition ×56 · denial ×49 · roof replacement ×34 · FME ×32 · protective order ×26 · Hail Focus ×14 · bad faith ×12 · indemnity ×7
PAGE 4 · FME, denial, indemnity, bad faith, protective order
… t, on June 1, 2026, State Farm produced almost 50,000 documents and expects to produce over 700,000 documents total? The production encompasses vast amounts of FME information that would subsume many of the requests at issue and yet Plaintiffs filed this second MTC in which they seek’: e “Industry Standards” and Benchmarks” Requests (Rogs 31-34; RFPs 45-52). These requests seek production and identification of any wi …
PAGE 16 · denial, deposition
… ail to show that Accenture’s work for State Farm, or any analysis of “industry standards,” played any part in the handling of their claim. The Motion should be denied on that basis alone. Deposition Transcripts (RFPs 53-57). Plaintiffs seek the deposition transcripts and exhibits for the following current and former State Farm employees from five unrelated lawsuits involving different insureds, coverage issues, claim …
PAGE 26 · Hail Focus, indemnity, roof replacement
No. Discovery Requests Enhancement -Wind/Hail, the Wind and Hail Fire Model Enhancement Team, Hail Focus Initiative and/or Hail Initiative and/or any hail quality focus initiatives in Texas; (iv) implementation of Fire Model Enhancement -Wind/Hail, the Wind and Hail Fire Model Enhancement Team, Hail Focus Initiative and/or Hail Initiative and/or any hail quality focus initiatives in Oklahoma; (v) claims handling tact …
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