WEST V. STATE FARM FIRE & CASUALTY CO.
Comanche County District Court, CJ-2025-135 · Filed 2026-06-12 · 40 pages · Download the PDF
FILED DISTRICT COURT IN THE DISTRICT COURT OF COMANCHE COUNTY STATE OF OKLAHOMA COMANCHE COUNTY, OKLAHOMA June 11, 2026 4:13 PM ROBERT MORALES, COURT CLERK Case Number CJ-2025-135 NEIL and LACY WEST, ) ) Plaintiffs, ) ) V. )} STATE FARM FIRE & CASUALTY COMPANY and NANCY HOLCOMB INS. AGENCY, INC., Defendants. Case No, CJ-2025-135 Hon. Grant Sheperd ) ) ) ) ) ) DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S MOTION FORA PROTECTIVE ORDER AND TO QUASH AND/OR STAY PLAINTIFFS’ DEPOSITION NOTICES OF KATHY RESS, WENSLEY HERBERT, THOMAS MOSS, AND SCOTT WELSH Before even taking the deposition this Court has ordered on Plaintiffs’ theory of institutional bad faith, and before deposing anyone with case …
deposition ×113 · FME ×16 · denial ×8 · protective order ×6 · bad faith ×4 · indemnity ×1 · summary judgment ×1
PAGE 6 · FME, denial, protective order, deposition
describe her as the “ringleader” of the FME. See Pls.’ Resp. in Opp. to Motion to Quash Deposition of N. Manduca at 3. This Court denied State Farm’s Motion to Quash Ms. Manduca’s deposition, ® stating Plaintiffs had sufficiently “authorized/created by Manduca.” pled a scheme and cost-savings measures that were See Court Order re Mot. to Quash (April 10, 2026), That deposition is scheduled for June 23, 2026.” 7. As o …
PAGE 1 · bad faith, protective order, deposition
… ES OF KATHY RESS, WENSLEY HERBERT, THOMAS MOSS, AND SCOTT WELSH Before even taking the deposition this Court has ordered on Plaintiffs’ theory of institutional bad faith, and before deposing anyone with case specific knowledge, Plaintiffs have noticed the depositions of four more current or former senior leadership personnel which are at best cumulative and not proportional. Thus, Defendant State Farm Fire and Casual …
PAGE 2 · FME, denial, indemnity, deposition
… ffs’ counsel persistently (and incorrectly) allege State Farm developed, implemented, and/or monitored through the Fire Model Enhancement quality program (the “FME”).°> But the Court has already ordered State Farm to provide extensive FME-related discovery, and Plaintiffs cannot explain how the depositions of these individuals would not be cumulative and/or duplicative of this ordered discovery, and certainly they do …
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