WEST V. STATE FARM FIRE & CASUALTY CO.
Comanche County District Court, CJ-2025-135 · Filed 2026-08-18 · 58 pages · Download the PDF
IN THE DISTRICT COURT OF COMANCHE COUNTY OST eenopr STATE OF OKLAHOMA COMANCHE COUNTY, OKLAHOMA August 18, 2026 9:57 AM NEIL and LACY WEST, ROBERT MORALES, COURT CLERK Case Number CJ-2025-135 ) ) Plaintiffs, ) Case No. CJ-2025-135 ) V. ) Hon. Grant Sheperd ) STATE FARM FIRE & CASUALTY COMPANY and NANCY HOLCOMB AGENCY, INC., 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 ×51 · denial ×26 · Hail Focus ×24 · indemnity ×9 · protective order ×8 · FME ×1
PAGE 50 · Hail Focus, denial, roof replacement
… bjections, denied. REQUEST FOR ADMISSION 18: NO. Admit You developed the Fire Model Enhancement - Wind/Hail, the Wind and Hail Fire Model Enhancement Team, the Hail Focus Initiative and/or Hail Initiative and/or other initiatives or programs to apply on first-party claims to seek a reduction in the amount You spent each year on total roof replacements, lower the ratio of total or full roof replacements to partial roo …
PAGE 52 · Hail Focus, denial, roof replacement
Enhancement Team, the Hail Focus Initiative and/or Hail Initiative and/or other similarly named initiatives or programs after implementation in Texas. RESPONSE TO REQUEST NO. 22: State Farm objects to this Request because it is vague and ambiguous. State Farm further objects to this Request because it seeks information that is not relevant to the claims or defenses or proportional to the needs of the case. Subject to …
PAGE 37 · Hail Focus, indemnity, roof replacement
… r rules used related to such initiatives or plans”; therefore, it may be unduly burdensome depending on its interpretation, especially as to the terms/phrases “Hail Focus Initiative and/or Hail Initiative and/or any hail quality focus initiatives” and “claims handling tactics or rules used related to such initiatives or plans.” Moreover, confidential, proprietary business State Farm objects to this Request to the ext …
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