WEST V. STATE FARM FIRE & CASUALTY CO.
Comanche County District Court, CJ-2025-135 · Filed 2026-08-21 · 285 pages · Download the PDF
STATEa anaOF OKLAHOMA ies ounty Fil ihe C IN THE DISTRICT COURT OF COMANCHE STATE OF OKLAHOMA COUNTY NEIL and LACY WEST, Office of AUG 21 he ourt Clerk 2008 6 By. Deputy Plaintiffs, V. CASE NO. CJ-2025-135 STATE FARM FIRE AND CASUALTY COMPANY and NANCY HOLCOMB INS. AGENCY, INC., Defendants. PLAINTIFFS’ RESPONSE TO STATE FARM’S IMPROPER NOTICE OF MOTION TO CONSOLIDATE THE DEPOSITIONS IN THIS CASE WITH A CASE PENDING IN ANOTHER COUNTY & COUNTER MOTION FOR RULE 4 ORDER THAT THIS CASE IS NOT TO BE CONSOLIDATED WITH ANY OTHER CASE COME NOW the Plaintiffs, by and through their counsel of record, Whitten Burrage, and respectfully request that the Court issue an order that this case and the discover …
protective order ×160 · deposition ×154 · denial ×37 · roof replacement ×30 · OG 75-160 ×19 · bad faith ×19 · Xactimate ×17 · FME ×16
PAGE 273 · 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 “[aJn 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 268 · 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 269 · 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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