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WEST V. STATE FARM FIRE & CASUALTY CO.

Reply in Support of Motion for a Protective Order and to Quash (West v. State Farm, 2026-08-07)

Comanche County District Court, CJ-2025-135 · Filed 2026-08-07 · 7 pages · Download the PDF

What this document says (first page, verbatim)

IN THE DISTRICT COURT OF COMANCHE STATE OF OKLAHOMA COUNTY FILED NEIL and LACY WEST, DISTRICT COURT COMANCHE COUNTY, OKLAHOMA Plaintiffs, August 6, 2026 4:45 PM STATE FARM FIRE & CASUALTY COMPANY and NANCY HOLCOMB INS. AGENCY, INC., Defendants. Case No. CJ-2025-135 el Vv. Case Number CJ-2025-135 ee ee ROBERT MORALES, COURT CLERK. DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S REPLY IN SUPPORT OF MOTION FOR A PROTECTIVE ORDER AND TO QUASH PLAINTIFFS’ DEPOSITION NOTICE OF STATE FARM’S CHIEF EXECUTIVE OFFICER JON FARNEY

Key terms in this filing

deposition ×27 · FME ×13 · bad faith ×4 · protective order ×3

Notable passages

PAGE 3 · FME, protective order, deposition

… med specific adjusting tasks on Plaintiffs’ Claim.”).) B. Plaintiffs Concede—By Their Silence—That Mr. Farney Has No Unique, Relevant Information Regarding The FME. In their transmittal letter accompanying the Farney Notice, Plaintiffs initially contended that Mr. Farney’s testimony was relevant because he was copied on unidentified “emails back in 2019” supposedly related to the FME. (See Mot. at Ex. 3, Letter from …

PAGE 4 · FME, bad faith, deposition

mention the FME once, in introductory filler unrelated to Mr. Farney. (See Pls.’ Resp. at 1-2.) While Plaintiffs argue generally that “pattern and practice” evidence is relevant to bad faith claims (see id. at 11-12), they provide no connection between Mr. Farney and any “pattern and practice” regarding the FME or anything else alleged to apply to Plaintiffs’ claim.* As such, they concede that Mr. Farney has no uniqu …

PAGE 2 · FME, deposition

… three emails (out of over 700,000 documents State Farm has produced) which show de minimis reference to Mr. Farney—and nothing relevant to this claim or to the FME. Certainly, there is nothing relevant that has not been or could not have been covered with other State Farm employees who are included on those emails, including Ms. Manduca (who has already been deposed) and Mr. Welsh (whose deposition has been ordered). …

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

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