Every exhibit is free to download
Neil and Lacy West v. State Farm Fire and Casualty Company, No. CJ-2025-135, District Court of Comanche County, Oklahoma. The plaintiffs' response filed 21 August 2026 and its 44 exhibits were unsealed by the court's 20 August 2026 de-designation order. Mantis hosts the filing as the clerk scanned it and every exhibit as its own PDF, unaltered, so you can read the documents rather than a summary of them.
An Oklahoma family's disputed roof claim has become a window into how one of the country's largest insurers manages wind and hail losses. The central case is Neil and Lacy West v. State Farm Fire and Casualty Company and Nancy Holcomb Ins. Agency, Inc., Case No. CJ-2025-135, in the District Court of Comanche County, Oklahoma.1
The underlying dispute is concrete. In its own motion, State Farm describes the question as whether it owes the Wests approximately $50,000 to replace a roof following a June 15, 2023 weather event. The broader litigation asks whether claim-management initiatives improperly influenced decisions about covered damage.2
The public record now includes internal emails, instant messages, operating guidelines, training materials, management dashboards, agent complaints, financial discussions, and a court order addressing confidentiality. Some documents raise serious questions about the relationship between claim accuracy and lower claim payments. Others provide important context that should not be omitted. A financial trend is not automatically a wrongful-denial rate, and a discovery ruling is not a verdict.41314
Mantis Claims Group's position is straightforward: a roof claim should be evaluated from the policy, the physical evidence, the feasibility of a proper repair, and the applicable requirements — not reverse-engineered to satisfy a preferred financial result. That is the lens through which we examine this record.
Free public-record downloads: The released State Farm exhibits discussed in this case study are available to download free at MantisClaims.com. Use the exhibit guide below to locate the internal documents, the confidentiality order, and the related procedural exhibits. The documents are presented for readers to examine the underlying record, not merely someone else's characterization of it.
- 1. The case at a glance
- 2. What the Wests allege — and what remains disputed
- 3. One controversy, several different proceedings
- 4. The attorneys identified in the West record
- 5. Who actually handled the West claim? The defense witness list
- 6. State Farm executives, managers, and agents in the corporate record
- 7. The timeline: from operating guidelines to litigation
- 8. What the internal documents actually show
- 9. An overlooked part of the release: State Farm's own roofing guidelines
- 10. What the confidentiality order did — and did not — release
- 11. Why the fight over depositions and consolidation matters
- 12. State Farm's response belongs in the case study
- 13. What policyholders and public adjusters should learn
- 14. Free exhibit guide: the 31 internal-document exhibits
- 15. Frequently asked questions
- 16. Mantis Claims Group's conclusion
- Appendix A. Additional related cases identified in the filing
- Appendix B. Extended participant and organization index
- Appendix C. Boundaries of this case study
1. The case at a glance
| Question | Verified identification or record-based answer |
|---|---|
| Who are the homeowners? | Neil West and Lacy West. |
| Who are the named defendants in West? | State Farm Fire and Casualty Company; Nancy Holcomb Ins. Agency, Inc. |
| What is the state case number? | CJ-2025-135. |
| What court is hearing it? | District Court of Comanche County, Oklahoma. |
| Who is the assigned state judge? | Grant Sheperd, as spelled in the court's docket. |
| When was the lawsuit filed? | February 28, 2025. |
| What loss is at issue? | A June 15, 2023 weather event, according to State Farm's own description of the dispute. |
| What amount is described? | Approximately $50,000 for roof replacement; this is a disputed amount, not an award. |
| Was the case in federal court? | Yes: No. 5:25-cv-00388, Western District of Oklahoma, ultimately before Judge Scott L. Palk. |
| What happened in federal court? | On August 21, 2025, Judge Palk granted remand in eleven cases consolidated for that limited purpose, including West. |
| What is the reported trial setting? | November 2, 2026, stated in the August 21, 2026 West filing. Settings can change. |
| Has this review located a final merits verdict? | No final verdict or damages judgment was located in the records reviewed through September 19, 2026. |
Sources: the state docket, the federal docket, and the parties' filings.12523
A docket-reading trap: the state case page displays an April 7, 2025 "closed" date alongside a disposition of transfer to another jurisdiction. That entry reflects the removal history. It should not be used to claim that the present dispute ended in April 2025; the same docket contains extensive later proceedings.15
2. What the Wests allege — and what remains disputed
State Farm's August 2026 motion summarizes the pleaded claims as breach of contract and bad faith against the insurer; negligent procurement against the agency; and constructive fraud and negligent misrepresentation against the defendants. The insurer describes the plaintiffs' theory as an alleged plan to reduce indemnity by misattributing storm damage to uncovered wear and tear through the Fire Model Enhancement, or FME, initiative. This is the insurer's summary of the pleadings, not a judicial determination that the theory is correct.2
The distinction between the insurer and the agency matters. A claim about whether the insurer properly evaluated roof damage is not identical to a claim about what an agent represented, recommended, or procured. The agency allegations are one reason the plaintiffs argue that separate cases cannot be treated as interchangeable merely because they involve the same insurer.223
The defense witness list also makes clear that this is not simply a story in which the insurer acknowledges a covered full-roof loss and refuses to pay. The defense anticipates testimony that inspections identified some damage to other property but did not establish covered hail or wind damage to the shingles sufficient to justify replacement. The plaintiffs dispute the handling and outcome. Those competing positions must be tested against photographs, inspections, communications, policy terms, repair feasibility, and testimony.3
From a public adjuster's perspective, the important question is therefore not just, "Was there a hailstorm?" It is: What happened to this roof, what did each inspection establish, who made the coverage and scope decisions, and was a proposed repair actually adequate?
3. One controversy, several different proceedings
West: the Comanche County roof claim and public exhibits
West is the focal case for the August 21, 2026 filing analyzed here. That filing contains a 19-page plaintiffs' brief followed by 44 numbered exhibits. Exhibits 1-31 are the internal-document collection discussed in much of the coverage. Exhibits 32-44 are the confidentiality order and related motions, correspondence, orders, and transcript excerpts. The complete PDF has 285 physical pages.23
That is why "31 exhibits" and "44 exhibits" can both appear in accurate descriptions: they refer to different portions of the same filing.
Hursh: a separate case with overlapping corporate discovery
Billy and Lacy Hursh v. State Farm Fire and Casualty Company and Mark D. Welty Insurance Agency, Inc., CJ-2025-2626, is an Oklahoma County case before Judge Amy Palumbo. Related filings also identify Mark D. Welty individually. The removed federal case was 5:25-cv-00529. The August West filing identifies a December 7, 2026 trial setting for Hursh.623
Hursh is important because of orders addressing corporate representatives and executive depositions. It is not the West family's claim, and the two cases' trial dates should not be mixed up. The West filing identifies Nicole Manduca and Wayne Stewart as State Farm's chosen corporate designees in the Hursh discovery process.23
The attorney general's civil enforcement action
On June 24, 2026, Oklahoma Attorney General Gentner Drummond filed a separate action in Cleveland County District Court, CJ-2026-1066, against State Farm Fire and Casualty Company. The petition asserts claims under the Oklahoma Consumer Protection Act and Oklahoma's racketeering framework, along with civil conspiracy and unjust enrichment. Those are allegations in a civil action, not criminal convictions.7
The petition is signed through the Attorney General's Office by Gentner Drummond, Garry M. Gaskins II, Cameron R. Capps, and Christopher J. Campbell. The filing's assignment field identifies the judge as "Virgin." This article does not expand that abbreviated assignment into a currently verified judicial assignment.7
Two Oklahoma Supreme Court proceedings that should not be conflated
In State Farm Fire & Casualty Co. v. Palumbo, No. 123739, 2026 OK 51, the Oklahoma Supreme Court issued a June 23, 2026 writ barring enforcement of the order permitting the attorney general to intervene in Hursh. The majority held that the proposed statewide claims would impermissibly expand the private homeowners' action. It expressly identified a separate, independent lawsuit as a possible avenue. The ruling did not decide whether the alleged claims-handling scheme existed or resolve State Farm's remaining arguments.8
A separate June 23 order, No. 123812, appears as Exhibit 42 in the West filing. It denies an application to assume original jurisdiction in a proceeding naming Judge Palumbo and several real parties in interest, including the Hurshes, Moong Sian Wong-Faust, Stephen Faust, and the state through the attorney general. A refusal to accept extraordinary jurisdiction should not be described as a final merits judgment on every disputed discovery or insurance issue.33
The insurance department's examination
The Oklahoma Insurance Department's examination is another distinct process. In an August 25, 2026 statement, the department described independent examination work and coordination with the attorney general. An examination, a civil enforcement suit, a homeowner's damages action, and a hearing about market competitiveness are not the same proceeding.10
4. The attorneys identified in the West record
The following names come from the August 21 filing's signature and service blocks and the court dockets. They identify participation in the record, not necessarily every lawyer's present role or whether a lawyer remains counsel at a later date.1524
| Side / firm | Lawyers identified |
|---|---|
| West plaintiffs — Whitten Burrage | Reggie N. Whitten; Michael Burrage; Blake Sonne; Hannah Whitten; John S. Sanders; Jake Denne. The federal docket gives Sanders' fuller name as Johnathon Scott Sanders. |
| West plaintiffs — Burgess & Hightower | Brad W. Burgess; Colby A. Stephenson. |
| Additional counsel listed for the Wests on the state docket | R. Ryan Deligans, Durbin, Larimore & Bialick. |
| Defense — Crowe & Dunlevy | Timila S. Rother; Paige A. Masters; Amanda M. Finch. |
| Defense — GableGotwals | Lance E. Leffel. |
The related Hursh journal entry identifies defense counsel Lance E. Leffel, Ashlyn M. Smith, Carrie B. McNeer, and Grant A. Fitz of GableGotwals. Related federal docket materials also identify Lacy Williamson and plaintiffs' counsel Patrick F. Collogan. These should not all be presented as attorneys of record in West without a corresponding West appearance.625
Other lawyers appear in historical or related-case exhibits. For example, J. Blake Patton and Brian D. Blackstock appear with Leffel in the 2024 Nida opposition attached as Exhibit 34; the 2026 Adair motion in Exhibit 35 identifies Jerick L. Irby, Christopher J. Gnaedig, and Taylor R. Bagby of Hall Estill, alongside Timila S. Rother. Those documents supply context for the consolidation dispute, rather than establishing that every listed attorney represents a West party.26
5. Who actually handled the West claim? The defense witness list
Corporate emails are only one part of the story. The June 23, 2026 Defendants' Final Witness List identifies people whose anticipated testimony concerns the Wests' actual claim. A witness list is a proffer of expected testimony, not a transcript, an admission that every description is true, or proof that each listed witness eventually testified.3
Claim personnel and outside resources
| Person | Affiliation / role stated in the witness materials | Why the person matters to the claim history |
|---|---|---|
| Cedric Gooch | Identified in the account of Eberl supervision | Claim work discussed in Kristi Walls' anticipated testimony. Do not relabel him a corporate executive. |
| Kristi Walls | Associate Vendor Manager, Eberl | Supervision of Gooch and external claim-resource practices. |
| Brandi Hervey | External Claim Resource, Alacrity | Attempts to contact the Wests and an interview with Neil West. |
| Kristin Haun | Claim Specialist, State Farm | Contractor communications, supplemental photographs, and review of the claim decision. |
| Christy Mebane | Claim Specialist, State Farm | Supplemental materials, reinspection requests, and communications with Jason Taylor. |
| Max Balser | Team Manager, State Farm | Communications after a customer survey; inspection findings and the possibility of additional information or reinspection. |
| Jason Taylor | Team Manager, State Farm | Claim supervision, a second-inspection request, contractor materials, and payment-status communications. |
| Yasiin Bradley | Claim Specialist, State Farm | Photographs, supplemental materials, and reinspection review. |
| Joe Wicker | Claim Specialist, State Farm | Review of materials associated with Coastal Claims and Bobby Odom, and requests for further information. |
| Temicka Collett | Claim Specialist, State Farm | Anticipated explanation of the conclusion that the contractor photographs did not establish covered roof damage supporting replacement. |
| Alexis Napoles | Claim Specialist, State Farm | Photographs, weather information, claim-file review, and referral for further field review. |
This list makes an important distinction: Eberl and Alacrity resources are not automatically State Farm employees, and the executives in corporate strategy emails are not automatically the people who inspected the West roof.3
Contractors, public adjusters, appraisers, and experts
The same witness materials identify Bobby Odom of Trademark Exteriors Restoration and Derek Franklin of Legacy Roofing in connection with contractor inspections, communications, photographs, or estimates. They identify Jose Parga, Brandon Gold, and John Dekker, or other representatives of Coastal Claims Services, in connection with public-adjuster work on the West claim.3
Mantis Claims Group is analyzing the public record; this article does not claim that Mantis represented the Wests.
Other identified witnesses or expert references include Nancy Holcomb; appraiser Terry Peak; real-estate broker Darin Ray of RE/MAX; Frederick J. Bingham of Glynloen Insurance Consulting; and Kevin McCarty of Celtic Global Consulting. The defense descriptions reference plaintiffs' experts Walt Haskins, Mark Romano, and Jared Joseph. Inclusion in the list is not a judicial endorsement of an expert's qualifications or opinions.3
6. State Farm executives, managers, and agents in the corporate record
The table below separates prominent corporate participants from claim-specific handlers. Job descriptions are tied to the documents or identified source dates; they are not a claim that every person holds the same job today.111718192427
| Name | Documented connection |
|---|---|
| Jon Farney | Named in Fix Profit Task Force correspondence. State Farm's current leadership page identifies him as president and CEO of State Farm Mutual Automobile Insurance Company; he became CEO in June 2024, after the 2020-2021 initiatives. |
| Michael Tipsord | Senior leadership references and correspondence in the historical exhibits. State Farm identifies him as the CEO preceding Farney. |
| Wensley J. Herbert | Executive communications, April 2021 quarterly review, and disputed deposition notices. |
| Kathy Ress | Repeated leadership, dashboard, agency-complaint, training, and playbook correspondence; a named deposition subject. |
| Tom / Thomas Moss | Wind/hail strategy, training, benchmark and financial discussions; a named deposition subject. |
| Scott Welsh | Training and playbook development, management reporting, presentation edits, and deposition disputes. Some docket text misspells his surname. |
| Nicole Manduca | Central participant in wind/hail implementation, dashboards, training, claim escalations, and indemnity discussions. State Farm's 2026 motion describes her as a director in its Property & Casualty department. |
| Wayne Stewart | Identified as a designated corporate representative in the related Hursh discovery process. |
| Tyrone Smith | Quality strategy, agency communications, and the 2023 HRU redesign record. |
| Dana Jokerst; David Chikahisa; Eric Daly | Named with Manduca as Quality Pillar leads in Exhibit 2. |
| John Christensen | Leadership communications concerning manager approval results, earlier tactics, and the quality/profit process. |
| Jordan J. Coad | Claims manager identified in Quality Pillar planning and Fix Profit Task Force correspondence. |
| Michael Roper | Planning-and-analysis material in the task-force correspondence. |
| Kimberly Rose | Presentation-development correspondence, including instructions to change references to "targets" to "selections." |
| Wendy Mazza | Management-review and training correspondence. |
| Gwen Hodgson | Hail Reconciliation Unit service review and escalation communications concerning a separate claim. |
| Zach Olson; Terrie Lemon; Greg Robinson | Analytics, financial/trend reporting, and tracking discussions. |
| Tracy Blair Haus; Chad Harris; Robert Garner | State Farm agents whose complaints about other customers' claim experiences appear in the exhibits. |
| Jennifer Chandler; Debbie Myers | Agency leadership communications concerning complaints, service, and roof-claim practices. |
A name on an email, an invitation, or a witness list is not proof of misconduct. The evidentiary questions are what the person wrote, knew, directed, decided, or did — and how that connects to a particular claim. The broader participant index at the end preserves additional names without labeling every recipient a decision-maker.
7. The timeline: from operating guidelines to litigation
| Date | Development and significance |
|---|---|
| April 18, 2018 | Date of the Wind/Hail Roofing Guidelines, OG 75-160, reproduced as Exhibit 26. |
| March 2020 | Internal development and distribution discussions for Haag hail/wind training. |
| June 26, 2020 | The FME presentation identifies a wind/hail kickoff in Dallas County, Texas. |
| December 7, 2020 | The same presentation identifies expansion to Texas. |
| December 17, 2020 | The presentation identifies expansion to all states. This does not by itself establish identical application to every claim. |
| 2021 | Playbooks, management reviews, training, dashboards, and complaints appear across the released correspondence. |
| January 16, 2023 | Manduca's retrospective email describes approximately $1.4 billion less indemnity from 2020 to 2021 and changing full-to-partial roof ratios. |
| June 15, 2023 | Weather event underlying the West dispute, according to State Farm's motion. |
| 2023-2024 | Quality planning and Fix Profit Task Force communications appear in the exhibits. |
| February 28, 2025 | West filed in Comanche County. |
| April 4, 2025 | West removed to federal court. |
| August 21, 2025 | Federal remand order returns West and ten other cases to state courts. |
| December 31, 2025 | Hursh journal entry denies several motions to quash depositions. |
| January 23, 2026 | State Farm seeks limited corporate-discovery consolidation involving 22 identified Oklahoma County cases. |
| May 21, 2026 | Judge Dishman's communicated ruling denies consolidation as to written discovery while leaving discussion of deposition limits open. |
| June 23, 2026 | The West defense witness list is filed; separate Oklahoma Supreme Court proceedings produce the orders discussed above. |
| June 24, 2026 | The attorney general files the Cleveland County civil enforcement action. |
| July-August 2026 | West and Hursh orders, motions, and hearings address document production and executive/corporate depositions. |
| August 20, 2026 | Judge Sheperd signs the confidentiality de-designation order. |
| August 21, 2026 | The West plaintiffs file the response/counter-motion with the 44-exhibit packet. |
| September 3, 2026 | State Farm requests additional time to comply with the document-review/de-designation order. A request is not proof it was granted. |
| September 24, 2026 | The West docket lists hearings concerning a motion to compel, the Rule 4 counter-motion, and executive-deposition consolidation. |
| October 22, 2026 | The docket lists motion hearings and a pretrial conference. |
| November 2 / December 7, 2026 | Trial dates identified in the August filing for West and Hursh, respectively; subject to subsequent court action. |
The historical rows are drawn from the actual exhibits; the court-procedure rows come from the dockets, orders, and motions. Scheduled dates are not representations that an event has occurred.125711131920232528
8. What the internal documents actually show
A. A coordinated wind/hail initiative, not merely an isolated adjuster's opinion
Exhibits 3-5, 9-13, and 30 connect planning, analytical comparisons, manager involvement, training, and monitoring. The FME presentation supplies a rollout history. The playbook materials describe how directions would be communicated and followed through. Those records support scrutiny of whether a claim decision reflected independent evaluation or a broader organizational initiative.11121523
The existence of a coordinated initiative is not itself unlawful. Insurers can train staff, improve investigations, supervise difficult decisions, and seek to avoid payments not owed. The disputed issue is whether these processes improved contractually correct outcomes or steered handlers away from paying covered losses. The answer requires more than a program name.
B. The $1.4 billion email is significant — but its meaning has limits
Exhibit 6, physical PDF page 43, contains Manduca's January 16, 2023 email describing an approximately $1.4 billion decrease in indemnity from 2020 to 2021. The same message says volume went down while severity increased. It also reports full-roof-to-partial-roof payment ratios of 5.6 to 1 at the initiative's beginning, 2.0 to 1 in 2021, and 2.2 to 1 in 2022.13
That is important evidence of how leadership discussed results. It is not, standing alone, proof that $1.4 billion was wrongfully withheld, that the amount was all Oklahoma money, or that it was profit. Claim volume, storm activity, claim mix, severity, and payment timing can affect aggregate paid amounts. The email does not quantify how much of the change was caused by correct handling versus improper denial.
Likewise, a full-to-partial payment ratio is not a denominator of all reported roof claims. A decline in the ratio cannot honestly be relabeled as the percentage of homeowners denied benefits.
C. The $78.8 million example includes a qualification that must not be deleted
In Exhibit 7, Moss discusses a hypothetical one-percentage-point difference representing about 5,000 claims at an average severity of $15,769. That produces approximately $78.8 million. Critically, the message describes the example as claims without damage and not covered that might previously have been paid because of insufficient skill or willingness to make the appropriate decision.14
Plaintiffs are entitled to challenge whether the category was fairly defined or applied. But an article should not remove that qualification and present the message as an express instruction to deny 5,000 valid claims. Nor does it establish that $15,769 was the value of every homeowner's roof, the West claim, or a universal amount saved per denial.
D. Benchmarks deserve examination, not automatic acceptance
The exhibits compare State Farm outcomes with a purported industry benchmark for selected light-wind and small-hail situations and reference Accenture Consulting Services. The relevant questions include the populations compared, storm severity, building stock, roof age and condition, policy differences, claim maturity, sampling method, and whether other insurers' outcomes were themselves correct.15
A benchmark can identify a question. It cannot answer whether a particular shingle was damaged or whether a compatible repair is possible.
The 57% figure in Exhibit 5 is another example of why precision matters: it combines wind/hail and non-weather water losses as a share of net paid indemnity. The plan separately attributes 40% to wind/hail. It is inaccurate to describe the 57% as roof replacements alone.12
E. Manager review can protect accuracy or create directional pressure
The playbook and FME slides show management review of replacement recommendations. That is a legitimate subject for discovery because the questions include which recommendations required approval, who could overturn them, what information reviewers received, and how performance was measured.1116
However, the exhibits do not justify a simplistic statement that a displayed approval percentage equals the insurer's approval rate for all hail claims. The charts involve selected review populations; some labels also change between periods. Comparisons must preserve those definitions rather than treating every column as the same cohort.
A useful claim-specific question is: Did the reviewing manager identify a factual error in the proposed replacement, or merely prefer a different outcome?
F. "Fix Profit Task Force" is a real document label; the surrounding data still matter
Exhibits 14-16 contain correspondence using Fix Profit Task Force terminology and discussing how claims material would be presented. They also include instructions to replace references to "targets" with "selections." These are fair subjects for questions about intent, measurement, governance, and why wording was changed.17
But the often-repeated 39% closed-without-payment figure must be handled carefully. It appears in a financial discussion that includes auto physical-damage, comprehensive/collision, bodily-injury, and property-damage concepts. It is not identified as a 39% homeowners roof-denial rate. Treating it as one would detach the number from its context.17
A change in presentation language can be relevant evidence. Without more, it does not establish that the underlying conduct was unlawful or that a particular executive committed fraud.
G. State Farm's own agents reported customer problems
The agent correspondence is important because the concerns did not originate exclusively with plaintiffs' lawyers or outside contractors. Tracy Blair Haus raised concerns about repair estimates, customers' experiences, and State Farm's reputation. Jennifer Chandler and Debbie Myers discussed a larger volume of complaints and difficulties explaining the roof-claim approach. Chad Harris sought attention to a protracted separate claim. Robert Garner described the effect of another customer's roof dispute on the agency relationship.1822
These are first-hand internal complaints, not a representative statistical sample. Several chains also contain the insurer's response: requests for file review, additional contact, explanations, coaching, or corrective action. Both the complaint and the response belong in the analysis.
H. Some of the record shows decisions being corrected upward
Exhibit 21 is particularly useful. It concerns a separate Ohio customer, not the Wests. The internal escalation says the original inspection findings supported replacement, addresses communication problems, and states that the contractor's estimate was reviewed and would be accepted as reasonable in scope and price.22
Similarly, Exhibit 10 includes a metric tracking claims previously closed without payment that later became paid total-roof claims. In that context, an "overturn" moved toward payment rather than away from it.15
The lesson is not that every internal process worked properly. It is that the direction of a reversal matters. A sound case study should not transform a correction of underpayment into evidence that replacement was denied.
I. Haag training is not an insurance contract
Exhibit 25 contains internal discussion recognizing that Haag's material provides an engineering perspective rather than an interpretation of coverage under a particular policy. Later exhibits address refresher requirements, new-handler training, completion tracking, and 2022 repair-versus-replace training.1921
That distinction is central to public adjusting. A technical damage description, a claim guideline, and an insurance contract are different documents with different functions. None should silently be substituted for another.
It would also be inaccurate to reduce the training record to "employees were told never to replace roofs." Exhibit 29 includes a repair-versus-replace scenario in which slope replacement is supported even though a repair-cost comparison has not reached 50%.21
9. An overlooked part of the release: State Farm's own roofing guidelines
The most practical exhibit for many roof-claim professionals may be Exhibit 26: OG 75-160, Wind/Hail Roofing Guidelines, dated April 18, 2018. It should be identified by its date. It is evidence of the reproduced historical guidance, not a representation that every provision remains current or overrides a policy, law, or endorsement.20
Damage is not limited to a roof that already leaks
The composition-roof discussion describes damage in terms of reduced water-shedding ability or reduced life expectancy. An analysis that mentions only active leakage omits part of the document's own stated criterion. The task remains to establish actual damage and causation, not to presume that every mark constitutes a covered loss.20
Repairability requires more than counting a few marked shingles
The guide discusses representative test areas, roof condition, practical repair problems, and the distinction between damaged areas and undamaged roof sections. It recognizes that deteriorated roofing can make surrounding shingles vulnerable during repair. The 2022 training material separately illustrates that a percentage comparison is not the only relevant consideration.2021
Our practical takeaway is to document the proposed repair sequence, compatible materials, surrounding damage risk, and any reason a repair cannot restore the covered property properly. A generic "repairable" label does not explain how the work will be performed.
Waste, starter, and hip/ridge cannot be evaluated in isolation
The reproduced guide lists waste factors of 5% for a flat roof, 10% for a gable roof, and 15% for a hip roof when applying its described estimating approach. It also warns that waste may already be included in an estimating item and discusses the relationship between waste, starter, ridge, and separate specialty products.20
This is valuable historical carrier-side material. It is not a universal entitlement to add 15% plus separate starter and ridge without checking for overlap. The defensible question is what the selected line item already includes, what material is actually being installed, how the roof is configured, and how quantities were calculated.
Steep and two-story charges are expressly addressed
The guide addresses steep charges for slopes of 7/12 or greater and additional labor for a two-story roof. It distinguishes removal from replacement activity and discusses applying the charges to the applicable areas and quantities. This is more specific than an unsupported assertion that such charges are never appropriate.20
The roof geometry and work conditions still must support the estimate. The historic guide should not be used to invent a current rate or to apply an access surcharge to an area that does not require it.
Tear-off, multiple layers, and prior claims need separate treatment
The guide states that reasonable repairs can include tear-off without depreciation in the approach it describes, and it addresses removing all roofing layers when multiple layers are present. It also contains detailed treatment of earlier roof claims, previous payments, actual repairs, and subsequent damage.20
These sections reinforce a basic estimating discipline: separate the damaged material, necessary removal, earlier claim history, deductible, and recoverable depreciation rather than blending them into one unexplained number. Whether a particular payment rule applies depends on the actual contract and governing law; the historical guide is not itself an adjudication of that issue.
Availability, matching, code, warranties, and solar equipment are not one question
The exhibit discusses product availability and like-kind-and-quality considerations, references separate matching guidance, distinguishes physical loss from a voided warranty, and addresses ordinance-or-law coverage as a policy-specific issue. It also discusses solar equipment and other roof appurtenances.20
A manufacturer requirement, a building-code obligation, an unavailable product, a matching dispute, and a loss-settlement provision may interact, but they are not interchangeable. A public adjuster's estimate should identify the actual reason for each requested item and the evidence supporting it.
10. What the confidentiality order did — and did not — release
Judge Sheperd's August 20, 2026 order granted relief in part concerning blanket confidentiality designations and identified materials. It did not lift the entire protective order or make every discovery document public. The order preserves a process for justified confidentiality claims and does not simply nullify orders entered by other courts.4
A further numbering issue matters: the order refers to exhibits associated with an earlier August 6 filing. Those numbers are not automatically the same as the exhibit numbers in the August 21 packet. A document should be matched by its identity and production markings, not only by an exhibit numeral.
Large production totals discussed by the parties — hundreds of thousands of documents or pages, depending on the speaker and context — should not be advertised as the number of records released in this packet. Nor should the continuing presence of an old "Confidential" stamp on a reproduced page be treated, by itself, as proof that the particular public exhibit remains sealed.4
The correct description is narrower and stronger: specific materials became publicly accessible in litigation, subject to the actual court orders.
11. Why the fight over depositions and consolidation matters
The plaintiffs argue that different insureds, agents, policies, events, discovery histories, and trial settings make broad consolidation inappropriate. Their August 21 response asks that West discovery not be merged into other pending cases. They point to State Farm's earlier opposition to consolidation and to orders already entered in West and Hursh.2326
State Farm presents a different rationale: repeated executive testimony about the same alleged corporate program can be duplicative, inefficient, and burdensome. Its motion invokes federal cases in which depositions concerning common corporate subjects were coordinated. That is a procedural argument, not an admission of the alleged scheme.2
The dispute matters because access to knowledgeable witnesses can help determine who developed a program, how it was measured, what instructions reached claim personnel, and whether leadership knew of adverse customer outcomes. At the same time, a court may reasonably impose limits on repetitive discovery without endorsing the insurer's claim decisions.
The record includes orders concerning Ress, Herbert, Moss, Welsh, and corporate witnesses, and later reporting describes disputes involving Farney. A notice or order setting a deposition is not proof that the deposition occurred, that a witness refused to answer, or that particular testimony was given. Those assertions require the subsequent record.1232529
12. State Farm's response belongs in the case study
State Farm disputes the allegations. On its Oklahoma issues page, the company describes its commitment to evaluating claims under the policy and the facts, points to substantial payments for Oklahoma wind and hail losses, and distinguishes litigation allegations from established wrongdoing.9
The company's documents also contain language about paying what is owed, identifying uncovered conditions correctly, improving communication, and correcting service gaps. Those passages do not disprove the plaintiffs' theory. They do mean that a fair analysis cannot treat every mention of accuracy, lower expenses, training, or manager review as an explicit instruction to deny valid coverage.18192223
Conversely, aggregate payment totals do not resolve whether an individual claim was underpaid. Both propositions can be true: an insurer can pay a great many legitimate claims and still mishandle a particular insured's loss. The West claim must be evaluated on its own record.
13. What policyholders and public adjusters should learn
Build a claim-specific evidence file before relying on a headline
A productive review starts with the complete policy and endorsements, declarations, all versions of the insurer's estimate, inspection photographs, reports, correspondence, payment history, deductible, and a dated chronology. For roofing, identify the material, age, condition, slopes, geometry, prior repairs, storm indicators, and claimed damage locations. Preserve the originals rather than only screenshots of selected images.
The corporate exhibits can suggest questions. They do not replace proof of the homeowner's loss. The West witness list illustrates how contractor photographs, supplemental submissions, reinspection requests, and public-adjuster records can become important evidence in litigation.3
Ask who made the decision and what evidence changed it
Useful questions include: Who performed the site inspection? Who reviewed the photographs? Was a replacement recommendation changed? Who made that change? What specific factual or policy reason was recorded? Was a reinspection requested, performed, or refused? What evidence would the insurer consider material to reconsideration?
Those questions are grounded in the distinction the exhibits reveal between field observations, desk review, management review, vendor resources, and corporate strategy. They are more useful than assuming that the person on the roof made every final decision.311
Require a workable repair explanation
When a carrier proposes repair rather than replacement, ask for a repair scope that identifies the product, quantity, affected areas, compatibility, access, and practical sequence of work. Document why any proposed approach would damage surrounding materials or fail to restore the covered property. Explain the evidence rather than merely stating that repair is impossible.2021
Audit quantities and components, not just the estimate total
Review waste calculations, starter, ridge, underlayment, flashing, ventilation, access charges, tear-off, disposal, multiple layers, and detach-and-reset work where applicable. Check what each estimating item includes to avoid both omission and double counting. Separate a disagreement over covered scope from a disagreement over price or a policy limitation.20
Keep contract deadlines and legal remedies separate from public discussion
A news story or newly public exhibit should not be assumed to restart a notice requirement, suit limitation, proof-of-loss deadline, or other contractual or legal period. A public adjuster can evaluate and present a property claim within the authorized role; litigation, compelled discovery, and bad-faith remedies belong with appropriately qualified counsel. The governing policy and jurisdiction must be examined rather than imported from an Oklahoma lawsuit into another state.30
For North Carolina policyholders, the value of this case study is primarily better documentation and better questions. An Oklahoma procedural order is not a North Carolina coverage rule.
14. Free exhibit guide: the 31 internal-document exhibits
The following index uses the physical pages of the complete 285-page August 21 filing. Some exhibits have their own printed page numbers, and some reproduce documents originally produced in other cases. Preserve the exhibit label and Bates/production markings when citing them.23
| Exhibit | Full-filing PDF pages | Subject and reading guide |
|---|---|---|
| 1 | 20-29 | Agent complaint and internal service review. A separate Ohio window claim, not the West roof claim. Includes complaints and a corrective-action review. |
| 2 | 30-33 | 2022 Fire and AWC Claims: Quality Pillar Strategy. Identifies quality-pillar leadership, measures, and tactical planning. |
| 3 | 34 | Full roof replacements and opportunity discussion. June 2020 discussion of full-roof replacement, small hail, light wind, and tracking payment codes. |
| 4 | 35 | Indemnity opportunity and industry comparison. December 2020 discussion linking analytical opportunities to indemnity spending. |
| 5 | 36-42 | 2020 Fire Weather Leadership Business Plan. The 57% figure combines wind/hail and non-weather water; wind/hail alone is shown at 40% of net paid indemnity. |
| 6 | 43 | 2020-2021 indemnity decrease and roof-payment ratios. January 2023 retrospective: about $1.4 billion lower indemnity, with volume down and severity up; full-to-partial ratios. |
| 7 | 44-45 | One-percentage-point financial example. Conditional example involving claims described as undamaged and uncovered; not a finding of wrongful nonpayment. |
| 8 | 46 | Wind/hail dashboard discussion. March 2021 dashboard and leadership discussion. |
| 9 | 47 | Management review and customer conversations. September 2020 discussion of expanding review and communicating claim decisions. |
| 10 | 48-52 | Roof-payment trends, benchmarks, and reversals. Contains full/partial roof charts and a closed-without-payment-to-paid-full-roof metric. Reversal direction matters. |
| 11 | 53 | Wind/hail playbook distribution. June 2021 communication, monitoring, and execution instructions. |
| 12 | 54-56 | Playbook communication and huddle planning. Drafting, customer communications, and leadership follow-through. |
| 13 | 57-58 | Manager approvals and revisiting earlier plays. September 2023 discussion of management approval results; not an overall claim-approval rate. |
| 14 | 59-65 | Fix Profit Task Force correspondence. Claims and profitability discussions. The 39% closed-without-payment passage appears in an auto-related financial discussion, not a roof-claim dataset. |
| 15 | 66-67 | Changing targets to selections in presentation materials. October 2023 editing instructions. Wording changes invite questions but do not independently establish unlawful conduct. |
| 16 | 68-71 | Quality Pillar opportunity-sizing framework. August 2023 planning and connections to the profit-task-force process. |
| 17 | 72-76 | Agent Tracy Blair Haus complaint and follow-up. Kentucky agent concerns about repair estimates, customer outcomes, and reputation; includes an internal response plan. |
| 18 | 77-79 | Agency leadership complaints about fire and roof claims. April 2021 concerns over communications, claim handling, and the roof-claim philosophy. |
| 19 | 80-86 | 2021 agency leadership training outline. Virtual inspections, REIAP, Hancock and Seek Now, policy endorsements, and customer communications. |
| 20 | 87-96 | Agent complaint chain, repeated with different emphasis. Substantially repeats Exhibit 1. Do not count it as a second independent customer event. |
| 21 | 97-100 | Agent Robert Garner complaint and claim correction. Separate Ohio roof claim; internal review concluded the original findings supported replacement. Not the West claim. |
| 22 | 101-123 | Growing Together: 2021 market-area partnership. Agent distrust, claim communications, training, and joint agency/claims strategy. |
| 23 | 124-125 | April 2021 quarterly business review. Quality, customer experience, management involvement, and operating expense. |
| 24 | 126-130 | April 2020 Oklahoma agency conference call. Storm-response call announcement. A name in a bulk distribution list does not establish personal responsibility for a disputed claim. |
| 25 | 131-134 | Haag hail/wind training development. March 2020 drafts distinguish engineering instruction from coverage under an insurance policy. |
| 26 | 135-153 | OG 75-160: Wind/Hail Roofing Guidelines, April 18, 2018. Inspection, repairability, functional damage, waste, steep/height charges, starter, ridge, prior losses, experts, and related topics. Historical guidance, not proof of current terms. |
| 27 | 154-160 | 2021 quality plan and Haag training requirements. Yearly refresher requirement and new-handler training logistics. |
| 28 | 161-163 | MyBlock training completion tracking. Internal reports and completion tracking. |
| 29 | 164-166 | 2022 wind/hail training and repair-versus-replace guidance. Includes a scenario supporting slope replacement even below a 50% repair-cost comparison. |
| 30 | 167-177 | Fire Model Enhancement presentation. Rollout dates, selected small-hail/light-wind populations, manager reviews, benchmarks, and financial charts. |
| 31 | 178 | HRU Stewardship Redesign project record. 2023 workflow, ownership, and expense/quality project record; not a statement that every roof replacement must be overturned. |
The remaining attachments are also included in the downloadable research set: Exhibit 32 is the confidentiality order; 33-38 concern related hearings, consolidation motions, and correspondence; 39-40 are deposition-related orders; 41 is State Farm's West consolidation motion; 42 is the Supreme Court's No. 123812 order; and 43-44 concern the August 4 Hursh hearing and court minute. A separate download index provides individual PDFs and source-page ranges.
15. Frequently asked questions
Is the State Farm Oklahoma hail case a class action?
The West record reviewed here is an individual action by named homeowners. No class-certification order was located. Shared attorneys, similar allegations, coordinated depositions, or consolidation for a limited procedural purpose do not by themselves create a class action.1523
Did a court find that State Farm stole $1.4 billion?
No such finding was located. The figure comes from an internal email describing a decrease in indemnity payments from 2020 to 2021. Whether any portion reflects wrongful nonpayment is a different evidentiary and legal question.13
Were all of State Farm's internal records made public?
No. The August 20 order did not eliminate the entire protective order. This collection is a particular public filing and its exhibits, not the insurer's entire discovery production.4
Can the internal guidelines prove that my roof must be replaced?
Not by themselves. They may supply useful historical context or identify questions, but the policy, actual damage, causation, repair feasibility, and governing requirements remain necessary. A roof geometry or training example does not establish every fact of a separate loss.2021
Does a roof have to leak before hail damage can matter?
The reproduced 2018 guideline is not limited to active leakage: it also discusses reduced life expectancy. That is a statement about this document. A claim still requires support for actual covered damage under the applicable policy.20
Does the $50,000 figure represent a settlement or verdict?
No. It is the approximate roof-replacement amount in State Farm's description of the West dispute. The records reviewed do not establish a $50,000 award.2
Are the named employees personally accused defendants in West?
The named defendants in the West caption are the insurer and the agency corporation. A person's appearance in an email or witness list does not make that person a defendant or establish personal liability.13
Where can I download the released exhibits free?
Visit MantisClaims.com and use the free State Farm Oklahoma case-study document collection. The exhibit index identifies what each file contains so readers can evaluate the underlying evidence themselves.
Related North Carolina resources: Roof damage insurance claims, storm-damage claim assistance, and denied-claim assistance. These resources concern Mantis' service market; they do not make Oklahoma law applicable to a North Carolina loss.
16. Mantis Claims Group's conclusion
The importance of the West litigation is not that it supplies a shortcut to proving every denied roof claim. It is that the public record allows readers to examine the relationship between corporate claim strategy and individual claim outcomes.
The documents support serious questions about benchmarks, manager review, financial priorities, agent complaints, training, and the treatment of replacement recommendations. They also demand disciplined reading: ratios are not denial rates, conditional examples are not admissions of theft, customer complaints are not verdicts, and confidentiality rulings are not final findings of insurance bad faith.
For the policyholder, the most useful principle is also the simplest:
An internal playbook is not your insurance policy. A payment goal is not an inspection. A repair recommendation should be supported by a repair that can actually be performed.
Mantis Claims Group provides public-adjusting services for North Carolina property owners. To discuss a denied or underpaid property claim, contact Mantis Claims Group. Bring the policy, the insurer's estimate and correspondence, photographs, and any contractor documentation so the discussion can begin with the actual claim rather than assumptions.31
Appendix A. Additional related cases identified in the filing
This is a historical litigation map, not a representation that the cases were actually consolidated or that their current outcomes are known. Exhibit 35 identifies 22 Oklahoma County cases as candidates for limited corporate discovery as of January 23, 2026. In the table below, State Farm is a defendant in each listed matter; the final column preserves the additional agent/agency names used in that motion. A shortened caption is not a substitute for the live docket.32
| Named plaintiff / shortened case | Oklahoma County case number | Additional agent/agency names in Exhibit 35 |
|---|---|---|
| Adair | CJ-2023-6121 | Tim Custer Ins. Agency, Inc. |
| Adamo | CJ-2025-1844 | Brittanie Portillo McCoy; Brittanie Portillo Ins. Agency, Inc. |
| Black | CJ-2024-7827 | Randall Young Insurance Agency, Inc. |
| Davis | CJ-2025-2883 | Grant Gingerich; Grant Gingerich Ins. Agency, Inc. |
| Gabel | CJ-2025-1861 | Bill Kolb |
| Giertz | CJ-2025-1132 | Jennifer Lowder Ins. Agency, Inc. |
| Hardy | CJ-2025-3535 | Corbin Cooper; Lilly June, Inc. d/b/a Corbin Cooper Insurance Agency, Inc. |
| Harris | CJ-2024-8002 | Curtis L. Davidson; Eric Davidson Agency, LLC |
| Hursh | CJ-2025-2626 | Mark D. Welty; Mark D. Welty Ins. Agency, Inc. |
| Jacob Cox | CJ-2024-7630 | Elizabeth Gallery |
| Maher | CJ-2024-8245 | Terry M. Amacher |
| Martin | CJ-2025-2627 | Bobby Lewis Ins. Agency, Inc. |
| Methvin | CJ-2025-1031 | Kristopher "Nickey" Lee |
| Moong Sian Wong-Faust | CJ-2025-1675 | Grant Gingerich Ins. Agency |
| Osborn | CJ-2025-1638 | Steve Wright |
| Pruitt | CJ-2024-7828 | Jim Campos Agency, Inc. |
| Riley | CJ-2025-1328 | Oanh Stanger Insurance Agency, Inc. |
| Stearns | CJ-2025-1704 | Dennis Chaumont |
| Walter K. Weber | CJ-2025-2575 | Cherie R. Logan |
| Willard | CJ-2024-7830 | Rod C. Chew Ins. Agency, Inc. |
| Coover | CJ-2025-1302 | Bobby Lewis Insurance Agency, Inc. |
| Yost | CJ-2025-2576 | Mike Teague |
The 2024 opposition attached as Exhibit 34 is captioned Dale Nida and Sherri Nida v. State Farm Fire and Casualty Company and Sheryl Mandeville, CJ-2020-4453, before Judge Aletia H. Timmons. It is historical context for the parties' arguments over consistency and consolidation, not the West case itself.26
The August 2026 defense motion also references federal matters called Barlow, Cisneros, Cook, Dressel, Johnson, Newell, Porter, Stafford, and White for its argument about coordinated corporate depositions. Those references should be followed to the actual orders before using any one as authority for a proposition beyond the argument made in the West motion.2
Appendix B. Extended participant and organization index
This index identifies additional people and organizations in the reviewed materials beyond the principal tables. It is intentionally organized by documentary function. It does not identify every person in mass email distribution lists and does not imply that a recipient approved a policy, handled the West claim, or committed misconduct. Private contact information, account identifiers, meeting credentials, and home addresses are not reproduced in this article.
Claim escalation and agency feedback
Exhibits 1 and 20: Chris Schell, Robert Yi, Beth Lamb, Brandon Becker, and contractor Feazel appear in the separate agent-escalation chain. These exhibits concern the Loeser matter, not the West claim. They should not be counted as two independent complaints merely because the chain is attached twice.
Exhibit 17: Renee Bass-Taylor, Paul Odland, Dan Krause, Rand Harbert, Angela Null, and Jeremy Bryan appear in the Tracy Blair Haus complaint/follow-up materials, alongside leaders identified above.
Exhibit 21: Tyler Deneault, Alicia W. Gardner, Thad Holman, Rob Stewart, Alec Hagan, Erin Pander, Shayanna N. Terry, Jason Guilliams, and Matthew Poteet appear in the Robert Garner escalation chain. The separate insured discussed is identified in that chain as Fryan. Do not attribute that claim's payments, inspections, or corrective action to the Wests.1822
Playbook, communication, and training participants
Exhibits 11-12: Lisa Clawson, Daphne Outerbridge Louie, Steve Meulemans, Katie Benes, Angela M. Mitchell, and Jared Starnes appear in playbook and communication development.
Exhibit 19: Nick Meehan, Eric Lambert, Windy Clark, Bill Lingenfelter, and Tim Northquist appear in the agency-training distribution or outline. Hancock Claims Consultants and Seek Now are named inspection-program vendors. A vendor's involvement does not itself establish that the vendor made the insurer's final coverage decision.
Exhibit 22: Ami Kuhlman, Beatrice Lee, Juan Parilo, and editor Betty Taylor appear in the market-area partnership presentation.
Exhibit 24: Ami Kuhlman and Vince Watson are identified with the Oklahoma storm-response call. The distribution includes many more names; this article does not turn a bulk invitation into an allegation against each recipient.
Exhibit 25: Melissa Grimmett, Brad Rushton, Tanya E. Potts, Tina Kohn, Tricia Carter, and Kelly Bever appear in the Haag training development and distribution material.
Exhibit 27: Eileen Colbert, Pete McArdle, Katina Butler, Bill Escott, Laura E. Mize, Scott Steele, Stacey Janssen, Julie Jarnagin, and Heather Hanselka appear in the training requirement and scheduling chain.
Exhibit 28: Marie Dyer appears in training-completion reporting.
Exhibit 29: Walter Phillips, John Thoma, Adrian Mack, Kevin Brotherton, Jared Runnels, Clint Mahan, Tammy M. Davidson, John Broadway, Anthony Richardson, Jason Payne, Jessica Rich, and Derek Miller appear in the wind/hail training correspondence or distribution. These are document appearances, not independently verified current job assignments.192123
Analytics, financial planning, and task-force correspondence
Exhibit 10: Sean McCary and Gregory E. Jones appear with Zach Olson and senior claims leaders in reporting correspondence.
Exhibit 14: Bryan McLaughlin, Brad Babic, Katie Maguire, Gregory Enchinton, Matt Schulkins, Michael T. Keating, Matthew Parola, Michael Arnold, Brian Trautmann, Jennifer Megagel, Mark Schwamberger, Justin Tipsord, Sara Frankowiak, Craig Isaacs, Kristyn Cook, Joshua Torrey, Melanie Cassidy, Paul Smith, and Becky Herald appear in the extended task-force or financial correspondence. Different names have different functions in a chain: author, addressee, attendee, or mentioned person. They should not be treated as equivalent evidence of involvement.
Exhibit 15: Bruce Aldrich, Phani Atyam, Wendy Hopping, and Heather Burns appear in the presentation-development chain.1517
Outside organizations and tools mentioned
The record mentions Accenture Consulting Services; Haag; Eberl; Alacrity; Hancock Claims Consultants; Seek Now; Feazel; Coastal Claims Services; Trademark Exteriors Restoration; Legacy Roofing; Glynloen Insurance Consulting; Celtic Global Consulting; RE/MAX; AccuWeather; EagleView; ITEL; Xactimate; and MyBlock. These references cover consulting, engineering education, staffing, inspections, contractors, public adjusting, experts, weather data, measurement, identification, estimating, and training systems. Being mentioned does not establish wrongdoing or a contract to deny claims.315192021
Additional judicial and procedural names
Beyond Judges Sheperd, Palumbo, Dishman, Timmons, and Palk, the federal West docket records Judge Bernard M. Jones' April 7, 2025 recusal. The June 23 order in Supreme Court No. 123812 records concurrence by Rowe, C.J.; Kuehn, V.C.J.; Winchester; Edmondson; Combs; Gurich; and Darby, with Kane and Jett recused. Those names identify participation in that order, not a merits finding about the West roof.533
Appendix C. Boundaries of this case study
This article reviews the provided 285-page August 21 filing, its reproduced exhibits and orders, identified public court entries, a separately obtained defense witness list and later motion, official statements, and selected reporting available through September 19, 2026. It is not the entire docket, the complete discovery production, every deposition transcript, or an authenticated current trial exhibit list.
Specific gaps remain: the review did not independently obtain the complete operative West petition and every policy attachment from the live clerk's file; two pages of the separately hosted witness-list PDF were intermittently inaccessible; and no completed transcript was obtained for every executive deposition discussed in notices or reporting. The article consequently distinguishes the insurer's summary of pleaded claims, witness proffers, reported scheduling, and established orders.
Footnotes and primary-source references
Oklahoma State Courts Network, Neil and Lacy West v. State Farm Fire and Casualty Company and Nancy Holcomb Ins. Agency, Inc., CJ-2025-135, Comanche County, docket reviewed September 19, 2026. Court docket. OSCN itself directs readers to verify information with the official record keeper.
State Farm, motion to consolidate executive depositions reproduced as Exhibit 41, August 2026, especially printed p. 2 / complete-filing PDF p. 267 (loss date, disputed amount, pleaded claims, Manduca's described position), and pp. 266-279 (coordination rationale). Exhibit 41.
West, Defendants' Final Witness List, filed June 23, 2026, particularly pp. 2-6 and the service/signature material. Court-hosted PDF. Witness descriptions are anticipated testimony; not all eight pages were retrievable consistently. Names and roles used above are limited to readable material.
West, Order on confidentiality/de-designation, August 20, 2026, Exhibit 32, complete-filing PDF pp. 179-188. Extracted order; public mirror of the order.
West et al. v. State Farm Fire and Casualty Company et al., No. 5:25-cv-00388, U.S. District Court, Western District of Oklahoma. Federal docket entries April 4, April 7, and August 21, 2025. Docket mirror.
Hursh et al. v. State Farm Fire and Casualty Company et al., No. 5:25-cv-00529, federal docket mirror; related state case CJ-2025-2626 identified in the West brief and Exhibits 39 and 44. Federal docket mirror; Exhibit 39; Exhibit 44.
Oklahoma Attorney General, June 24, 2026 announcement and filed petition in State ex rel. Drummond v. State Farm Fire and Casualty Company, CJ-2026-1066, Cleveland County; petition's caption, counts, and signature pages. Official announcement; official petition PDF.
State Farm Fire & Casualty Co. v. Palumbo, No. 123739, 2026 OK 51, June 23, 2026, opinion concerning the attorney general's intervention. Opinion PDF mirror. This is not Supreme Court No. 123812.
State Farm, Understanding the Issues in Oklahoma, official company response, accessed September 19, 2026. Company statement. This is the defendant's position, not an independent adjudication.
Oklahoma Insurance Department, August 25, 2026 statement regarding examination work and coordination; see also its August 18 statement concerning report status. August 25 release; August 18 release.
Exhibit 30, Fire Model Enhancement presentation, complete-filing pp. 167-177, especially pp. 171-174 (rollout, selected populations, playbook, and charts). Exhibit 30. Labels and populations must be preserved when comparing the displayed figures.
Exhibit 5, 2020 Fire Weather Leadership Business Plan, complete-filing pp. 36-42; combined-peril 57% and wind/hail 40% figures at p. 36. Exhibit 5.
Exhibit 6, Nicole Manduca email to Tommy Higa-Seaver, January 16, 2023, forwarding Terrie Lemon material; complete-filing p. 43; production marking WEST00020276. Exhibit 6.
Exhibit 7, Tom Moss/Nicole Manduca instant-message discussion dated November 16, 2021, complete-filing pp. 44-45, particularly p. 45; production markings WEST00008026-27. Exhibit 7.
Exhibit 10, October 2021 reporting and correspondence, complete-filing pp. 48-52; benchmark discussion at p. 48, closed-without-payment-to-paid-full-roof explanation at p. 51. Exhibit 10.
Exhibit 13, September 20, 2023 correspondence involving John Christensen, Tom Moss, and Scott Welsh, complete-filing pp. 57-58. Exhibit 13.
Exhibits 14-16, complete-filing pp. 59-71: Fix Profit Task Force correspondence; presentation revisions; and Quality Pillar opportunity-sizing. The 39% passage appears at p. 64; the target/selection editing instructions at pp. 66-67. Exhibit 14; Exhibit 15; Exhibit 16.
Agent complaints and responses: Exhibits 1 and 20, pp. 20-29 and 87-96; Exhibit 17, pp. 72-76; Exhibit 18, pp. 77-79. Exhibit 1; Exhibit 17; Exhibit 18; Exhibit 20.
Exhibit 25, March 2020 Haag-training correspondence, complete-filing pp. 131-134, especially the engineering-versus-coverage qualification at pp. 132 and 134; Exhibit 19, pp. 80-86, agency-training outline. Exhibit 25; Exhibit 19.
Exhibit 26, State Farm OG 75-160, Wind/Hail Roofing Guidelines, April 18, 2018, complete-filing pp. 135-153. Key locations: policy/law qualification p. 136; inspections/repairability pp. 138-140; life-expectancy criterion p. 141; waste/steep/two-story p. 145; roof components pp. 146-147; tear-off pp. 147-148; prior losses pp. 148-151; availability/code/warranties p. 152; communications p. 153. Exhibit 26.
Exhibits 27-29, complete-filing pp. 154-166: training requirements, MyBlock tracking, and 2022 training correspondence. Repair-versus-replace example at p. 165. Exhibit 27; Exhibit 28; Exhibit 29.
Exhibit 21, Robert Garner escalation and internal review, complete-filing pp. 97-100, especially pp. 97-98. The chain concerns a different insured's Ohio claim. Exhibit 21.
Plaintiffs' August 21, 2026 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, West, CJ-2025-135. Complete source: 2026-08-21-West-Response-Counter-Motion_7751.pdf, 285 physical pages. Nineteen-page brief; individual exhibits linked in the index. The original PDF is supplied separately with this publication package. The filing is advocacy, and some reproduced attachments are excerpts rather than complete underlying documents.
August 21 West brief, pp. 17-19, signature blocks and certificate of service; compare the state and federal dockets. Brief, p. 17.
Exhibit 39, Hursh journal entry, filed December 31, 2025, pp. 261-264 of the complete filing; Exhibits 43-44, August 4, 2026 transcript excerpts and court minute, pp. 281-285. Exhibit 39; Exhibit 43; Exhibit 44.
Exhibit 34, 2024 Nida opposition, complete-filing pp. 192-214; Exhibits 35-38, 2026 consolidation motion, opposition, and correspondence, pp. 215-260. Exhibit 34; Exhibit 35; Exhibit 36; Exhibit 37; Exhibit 38.
State Farm, current leadership page and March 14, 2024 CEO-transition announcement. Leadership page; transition announcement. Historical exhibit titles are not automatically current titles.
West, State Farm's September 3, 2026 request for additional time to comply with the August 20 order. Court-hosted motion. The filing contains arguments and estimates; a requested extension is not an order granting one.
Reporting for context: KOKH, Kimberly Querry-Thompson, August 24, 2026, Filings cite State Farm touting $1.4B savings as Oklahoma policyholders sue over payouts; NonDoc, September 15, 2026, As trials near, document dispute in State Farm roof claim cases crawl along. KOKH; NonDoc. Media accounts are secondary; document interpretation above relies on the underlying exhibits rather than repeating every characterization in coverage.
Professional-practice analysis by Mantis Claims Group. This article does not calculate any reader's deadline or prescribe an Oklahoma remedy for a North Carolina claim. The actual policy, claim chronology, applicable law, and the professional's authorized role require separate review.
Mantis Claims Group, company website, accessed September 19, 2026; North Carolina service positioning. MantisClaims.com. This article does not assert Oklahoma licensure or representation of any party in these cases.
Exhibit 35, January 23, 2026 motion, printed pp. 3-4 / complete-filing pp. 217-218. It lists 22 proposed consolidation candidates and describes a request, not an order granting consolidation. Exhibit 35, p. 3.
Exhibit 42, Oklahoma Supreme Court, June 23, 2026, No. 123812, complete-filing p. 280. Exhibit 42. The order denies assumption of original jurisdiction and records the participating and recused justices.
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