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WEST V. STATE FARM FIRE & CASUALTY CO.

Response (West v. State Farm, 2026-07-28)

Comanche County District Court, CJ-2025-135 · Filed 2026-07-28 · 12 pages · Download the PDF

What this document says (first page, verbatim)

IN THE DISTRICT COURT OF COMANCHE COUNTY STATE OF OKLAHOMA FILED al Sarat ROBERT MORALES, COURT CLERK Case Number CJ-2025-135 Case No, CJ-2025-135 Defendants. Sygate Ne STATE FARM FIRE & CASUALTY COMPANY and NANCY HOLCOMB INS. AGENCY, INC., tt! et Samet Vv. COUNTY, OKLAHOMA July 27, 2026 4:54 PM Saat Plaintiffs, COMANCHE Saat NEIL & LACY WEST, DISTRICT COURT DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S RESPONSE TO PLAINTIFFS’ RENEWED MOTION TO ENFORCE AND REQUEST FOR DISCOVERY SANCTIONS

Key terms in this filing

sanction ×24 · FME ×6 · deposition ×5 · denial ×4 · indemnity ×3 · roof replacement ×3 · bad faith ×2 · protective order ×1

Notable passages

PAGE 3 · FME, denial, indemnity, protective order, sanction

… ve nothing to do with the claim decision they are challenging, but that Plaintiffs allege are necessary to prove their theory around the served State Farm with FME. Specifically, during discovery, Plaintiffs 123 written discovery requests (including 34 interrogatories, 59 document requests, and 30 requests for admission), and the Court’s April 22 Order granted many of these requests, though it denied others. Among ot …

PAGE 7 · FME, denial, sanction, deposition

… rrogatories the Court ordered supplemented were, as noted, requests to identify certain documents (Rogs 5, 9-12, 14, 19-21, 24) or questions specifically about FME (Rogs Rogs 6, 7, 13, 28, 29), as is evidenced by the focus of their motion. That is all information Plaintiffs could have and, in most instances, did ask of Ms. Manduca when they deposed her on June 23, 2026. Thus, Plaintiffs had access to the person they …

PAGE 8 · FME, sanction, deposition

… es used as follows: (1) adverse jury instructions as to State Farm’s purported violation of Court orders and alleged withholding of information relating to the FME; (2) orders from the Court allowing certain discovery and depositions following receipt of such interrogatory responses to be determined by the Plaintiffs; and (3) any other sanction the Court deems appropriate. In the rare cases where sanctions are even a …

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Motion for Entry of a Protective Order and Deposition Protocol GoverniEntry of Appearance (West v. State Farm, 2026-07-29)

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