WEST V. STATE FARM FIRE & CASUALTY CO.
Comanche County District Court, CJ-2025-135 · Filed 2026-08-10 · 26 pages · Download the PDF
IN THE DISTRICT COURT OF COMANCHE COUNTY STATE OF OKLAHOMA FILED DISTRICT COURT NEIL and LACY WEST, Plaintiffs, ) COMANCHE COUNTY, OKLAHOMA ) ) August 10, 2026 1:18 PM ROBERT MORALES, COURT CLERK ) Case Number CJ-2025-135 v. ) STATE FARM FIRE & CASUALTY ) Case No. CJ-2025-135 ) COMPANY and NANCY HOLCOMB INS. ) AGENCY, INC., ) ) Defendants. ) DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S MOTION FOR A PROTECTIVE ORDER CONSOLIDATING THE DEPOSITIONS OF WENSLEY HERBERT, THOMAS MOSS, KATHY RESS, AND SCOTT WELSH AND BRIEF IN SUPPORT Defendant State Farm Fire and Casualty Company (“State Farm”), pursuant to 12 O.S. §§ 3226(B)(2)(c), 3226(C), and 3226.1 and 12 O.S. …
deposition ×127 · protective order ×14 · FME ×12 · denial ×10 · indemnity ×4 · bad faith ×3
PAGE 8 · deposition
… ts of discovery. See, e.g., Rowe v. Heritage Auto. Grp., Inc., No. 5:17-cv-38, 2018 WL 3458356, at *1-2 (D. Vt. July 18, 2018) (granting request to consolidate deposition of common witnesses across cases because “[a]n order which results in one deposition rather than two in cases which share factual and legal elements is a sound exercise of the discretion and responsibility the civil rules extend to trial judges”); B …
PAGE 3 · FME, denial, indemnity, bad faith, deposition
… gh none of the State Farm Deponents had any connection to the insurance claim at issue—each of these individuals could provide relevant testimony regarding the FME initiative. (See, e.g., June 26, 2026 West Pls.’ Resp. to State Farm’s Mot. to Quash.) Based on the arguments of counsel relating to FME, on July 23, 2026, the Court denied State Farm’s motion to quash the depositions of the State Farm Deponents. The Hursh …
PAGE 4 · FME, denial, protective order, deposition
… eason to require the State Farm Deponents to appear for multiple, 6-hour depositions regarding the same subject matter—i.e., their purported involvement in the FME quality initiative. It is undisputed that none of the State Farm Deponents has specific knowledge regarding the insurance claims of Plaintiffs herein or the Hursh’s. As such, any deposition—conducted by the same counsel in both cases—will be duplicative. T …
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