WEST V. STATE FARM FIRE & CASUALTY CO.
Comanche County District Court, CJ-2025-135 · Filed 2026-08-18 · 70 pages · Download the PDF
IN THE DISTRICT COURT OF COMANCHE COUNTY STATE OF OKLAHOMA FILED DISTRICT COURT COMANCHE COUNTY, OKLAHOMA August 18, 2026 9:57 AM ROBERT MORALES, COURT CLERK NEIL and LACY WEST, ) Case Number CJ-2025-135 ) Plaintiffs, ) Case No. CJ-2025-135 ) V. ) STATE FARM FIRE & CASUALTY COMPANY and NANCY HOLCOMB AGENCY, INC., ) ) ) Hon. Grant Sheperd ) INS. ) Defendants. ) DEFENDANT NANCY HOLCOMB INSURANCE AGENCY, INC.’S RESPONSE IN OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL NANCY HOLCOMB’S COMPLIANCE WITH 12 O.S. § 3230(C) VOLUME I
roof replacement ×23 · deposition ×17 · bad faith ×15 · Hail Focus ×13 · protective order ×11 · FME ×8 · denial ×8 · indemnity ×5
PAGE 6 · Hail Focus, denial, bad faith, deposition
… luding State Farm’s internal rules, policies, procedures, processes, and practices on wind/hail claims that operated to deny Plaintiffs’ claim (i.e., the ‘Wind/Hail Focus Initiative’). . .”), As set forth below, the Holcomb Agency is not required to educate itself regarding information only known to State Farm. ARGUMENT AND AUTHORITY I. There Is No Cause of Action Against the Agency for Bad Faith Nor Is State Farm’s …
PAGE 4 · FME, indemnity, deposition, roof replacement
… s produced nearly 800,000 documents including (a) voluminous claims training materials; (b) voluminous agency training materials; (c) information regarding the FME and other “wind/hail initiatives,” including purported tracking of roof replacements, indemnity savings, and payment volumes and similarly-described initiatives; (d) documents and communications relating to managerial approval requirements for full roof re …
PAGE 3 · FME, denial, bad faith
… nstructive fraud claim is premised, in part, on the notion that the Agency knew ofa plan by State Farm to deny roof claims through the Fire Model Enhancement (“FME”) or other initiatives and failed to inform the Plaintiffs! The Holcomb Agency, however, has no knowledge of either the FME or other claim handling initiatives. Thus, Plaintiffs are now trying to force the Agency to undertake a litigation-driven investigat …
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