WEST V. STATE FARM FIRE & CASUALTY CO.
Comanche County District Court, CJ-2025-135 · Filed 2026-08-17 · 20 pages · Download the PDF
PIN THE DISTRICT COURT OF COMANCHE COUNTY STATE OF OKLAHOMA NEIL and LACY WEST, COMANCHE COUNTY, OKLAHOMA ) August 17, 2026 3:24 PM ) Plaintiffs, ROBERT MORALES, COURT CLERK Case Number CJ-2025-135 ) ) v. )} Case No. CJ-2025-135 ) STATE FARM FIRE & CASUALTY COMPANY and NANCY HOLCOMB INS. AGENCY, INC., ) ) ) ) Defendants. FILED DISTRICT COURT ) DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S RESPONSE AND OPPOSITION TO PLAINTIFFS’ MOTION FOR DISCOVERY SANCTIONS
deposition ×47 · sanction ×43 · denial ×15 · bad faith ×5 · indemnity ×1 · roof replacement ×1
PAGE 8 · sanction, deposition
For example, in R. W. International, the trial court improperly awarded a dismissal sanction under Federal Rule of Civil Procedure 37(b)(2)° against plaintiffs for, inter alia, plaintiff’s sole shareholder’s “refus[al] to answer certain questions that were asked [at his deposition] regarding the tax-exempt status of plaintiff.” R.W. Int’l Corp. v. Welch Foods, Inc., 937 F.2d 11, 14 (1st Cir. 1991). The First Circuit …
PAGE 14 · denial, sanction, deposition
… failure to answer by Ms. Manduca—and certainly nothing that rises to the level of sanctionable misconduct.!° IV. IN THE ALTERNATIVE, THE COURT SHOULD SUMMARILY DENY PLAINTIFFS’ MOTION BECAUSE PLAINTIFFS FAILED TO MEET AND CONFER OR SUBMIT A CERTIFICATION IN ACCORDANCE WITH 12 OS. § 3237. Finally, and in the alternative, the Court should deny Plaintiffs’ Motion outright because Plaintiffs failed to meet or confer with …
PAGE 2 · denial, sanction, deposition
… annot now seek sanctions premised on Ms. Manduca’s supposed noncompliance with a nonexistent Court order on that nonexistent motion to compel. The Court should deny Plaintiffs’ Motion. ! Plaintiffs’ counsel knew State Farm’s Protocol Motion was imminent. Counsel for State Farm emailed Plaintiffs’ counsel with a request to confer about its Protocol Motion on Friday, July 24, attaching the draft protocol, but was advis …
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