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WEST V. STATE FARM FIRE & CASUALTY CO.

Amended Motion for Summary Judgment on ALL Claims and Brief in Support (West v. State Farm, 2026-08-26)

Comanche County District Court, CJ-2025-135 · Filed 2026-08-26 · 446 pages · Download the PDF

What this document says (first page, verbatim)

IN THE DISTRICT COURT OF COMANCHE COUNTY FILED DISTRICT COURT STATE OF OKLAHOMA COMANCHE COUNTY, OKLAHOMA mat! August 24, 2026 4:15 PM ROBERT MORALES, COURT CLERK tl NEIL and LACY WEST, mgt Case Number CJ-2025-135 aaa Plaintiffs, Defendants. Se” Nm See ee COMPANY and NANCY HOLCOMB INS. AGENCY, INC., CJ-2025-135 Some STATE FARM FIRE AND CASUALTY Case No.: Se mal Vv. DEFENDANT STATE FARM FIRE AND CASUALTY COMPANY’S AMENDED MOTION FOR SUMMARY JUDGMENT ON ALL CLAIMS AND BRIEF IN SUPPORT Timila S. Rother, OBA #14310 Paige Masters, OBA #31142 Amanda M. Finch, OBA #34650 CROWE DUNLEVY Braniff Building 324 N. …

Key terms in this filing

depreciation ×42 · bad faith ×27 · denial ×26 · deposition ×11 · summary judgment ×11 · roof replacement ×11 · Xactimate ×5 · indemnity ×2

Notable passages

PAGE 11 · bad faith, summary judgment

… the extent they were, they would have been made in December 2021 when the Policy issued, more than three years before suit was filed. UMFs 2-5. II, PLAINTIFFS’ BAD FAITH CLAIM FAILS ON THE MERITS AS A MATTER OF LAW. Even if Plaintiffs’ bad-faith claim were not time-barred, summary judgment is proper. An insurer’s refusal to pay all amounts demanded does not constitute bad faith. The Oklahoma Supreme Court specificall …

PAGE 14 · denial, bad faith, summary judgment

… ing may take several forms... . a plaintiff may demonstrate bad faith by providing evidence that the insurer did not actually rely on the legitimate dispute to deny coverage, denied the claim for an illegitimate reason, or otherwise failed to treat the insured fairly. A plaintiff may also show 13

PAGE 196 · depreciation

… General Contractor Overhead [2] @ General Contractor Profit wo ‘ 0: cost benefits. cs Cost Value (Including Gene! Coniracto Overhead and Prot) Replacement Lass Depreciation (Including Taxes) cy Esiimated cost to repair of replace = The decrease in the 4, Depreciation volua of property over a period of ima . ; 10,000% x 1,620.08 Q £3, Replacement Cost Value (RCV) ~ damaged property. , . Minium It to cover a.certaln mi …

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Amended Notice to TAKE Deposition (West v. State Farm, 2026-08-25)

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