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What the documents show, what they do not, the people and courts involved, and a public adjuster's reading of State Farm's own roofing guidelines.

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The plaintiffs' brief

Response to State Farm's notice of motion to consolidate depositions and counter-motion for a Rule 4 order. Filing pages 1–19, with the certificate of service.

PDF, 5.6 MB

The complete filing

All 285 pages as scanned by the court clerk on 21 August 2026: the brief followed by Exhibits 1 through 44. The reference copy every extract below was cut from.

PDF, 94.8 MB

Exhibits 1–31: State Farm's internal documents

Emails, instant-message transcripts, planning decks, training material, dashboards, agent complaints and the April 2018 Wind/Hail Roofing Guidelines (OG 75-160), produced in discovery and carrying WEST and HOSIERGAR Bates numbers. Page numbers are the physical pages of the complete filing. Read the note on each row before quoting a figure.

Exhibit	Filing pages	What it is	Download
Exhibit 1	pp. 20–29 10 pages	Agent complaint and internal service review Chad Harris; Gwen Hodgson; Nicole Manduca; Kathy Ress A separate Ohio window claim, not the West roof claim. Includes complaints and a corrective-action review.	PDF, 3.6 MB
Exhibit 2	pp. 30–33 4 pages	2022 Fire and AWC Claims: Quality Pillar Strategy Dana Jokerst; David Chikahisa; Eric Daly; Nicole Manduca Identifies quality-pillar leadership, measures, and tactical planning.	PDF, 1.3 MB
Exhibit 3	p. 34 1 page	Full roof replacements and opportunity discussion Nicole Manduca; Greg Robinson June 2020 discussion of full-roof replacement, small hail, light wind, and tracking payment codes.	PDF, 0.3 MB
Exhibit 4	p. 35 1 page	Indemnity opportunity and industry comparison Nicole Manduca; Dana Jokerst December 2020 discussion linking analytical opportunities to indemnity spending.	PDF, 0.4 MB
Exhibit 5	pp. 36–42 7 pages	2020 Fire Weather Leadership Business Plan Fire Weather leadership The 57% figure combines wind/hail and non-weather water; wind/hail alone is shown at 40% of net paid indemnity.	PDF, 2.1 MB
Exhibit 6	p. 43 1 page	2020-2021 indemnity decrease and roof-payment ratios Nicole Manduca; Tommy Higa-Seaver; Terrie Lemon January 2023 retrospective: about $1.4 billion lower indemnity, with volume down and severity up; full-to-partial ratios.	PDF, 0.4 MB
Exhibit 7	pp. 44–45 2 pages	One-percentage-point financial example Tom Moss; Nicole Manduca Conditional example involving claims described as undamaged and uncovered; not a finding of wrongful nonpayment.	PDF, 0.8 MB
Exhibit 8	p. 46 1 page	Wind/hail dashboard discussion Kathy Ress; Nicole Manduca March 2021 dashboard and leadership discussion.	PDF, 0.3 MB
Exhibit 9	p. 47 1 page	Management review and customer conversations Wendy Mazza; Nicole Manduca September 2020 discussion of expanding review and communicating claim decisions.	PDF, 0.5 MB
Exhibit 10	pp. 48–52 5 pages	Roof-payment trends, benchmarks, and reversals Nicole Manduca; Kathy Ress; Scott Welsh; Tom Moss; Zach Olson Contains full/partial roof charts and a closed-without-payment-to-paid-full-roof metric. Reversal direction matters.	PDF, 1.9 MB
Exhibit 11	p. 53 1 page	Wind/hail playbook distribution Nicole Manduca and distribution group June 2021 communication, monitoring, and execution instructions.	PDF, 0.4 MB
Exhibit 12	pp. 54–56 3 pages	Playbook communication and huddle planning Nicole Manduca; Kathy Ress; Scott Welsh; Steve Meulemans; Angela Mitchell Drafting, customer communications, and leadership follow-through.	PDF, 1.0 MB
Exhibit 13	pp. 57–58 2 pages	Manager approvals and revisiting earlier plays John Christensen; Tom Moss; Scott Welsh September 2023 discussion of management approval results; not an overall claim-approval rate.	PDF, 0.5 MB
Exhibit 14	pp. 59–65 7 pages	Fix Profit Task Force correspondence Jordan Coad; John Christensen; Jon Farney; Michael Roper and others Claims and profitability discussions. The 39% closed-without-payment passage appears in an auto-related financial discussion, not a roof-claim dataset.	PDF, 2.2 MB
Exhibit 15	pp. 66–67 2 pages	Changing targets to selections in presentation materials Kimberly Rose; Scott Welsh and colleagues October 2023 editing instructions. Wording changes invite questions but do not independently establish unlawful conduct.	PDF, 0.7 MB
Exhibit 16	pp. 68–71 4 pages	Quality Pillar opportunity-sizing framework Jordan Coad; Nicole Manduca; John Christensen; Tyrone Smith August 2023 planning and connections to the profit-task-force process.	PDF, 1.6 MB
Exhibit 17	pp. 72–76 5 pages	Agent Tracy Blair Haus complaint and follow-up Tracy Blair Haus; Kathy Ress; Renee Bass-Taylor and others Kentucky agent concerns about repair estimates, customer outcomes, and reputation; includes an internal response plan.	PDF, 2.0 MB
Exhibit 18	pp. 77–79 3 pages	Agency leadership complaints about fire and roof claims Jennifer Chandler; Debbie Myers; Nicole Manduca April 2021 concerns over communications, claim handling, and the roof-claim philosophy.	PDF, 1.0 MB
Exhibit 19	pp. 80–86 7 pages	2021 agency leadership training outline Tom Moss and agency/claims leaders Virtual inspections, REIAP, Hancock and Seek Now, policy endorsements, and customer communications.	PDF, 1.7 MB
Exhibit 20	pp. 87–96 10 pages	Agent complaint chain, repeated with different emphasis Chad Harris; Gwen Hodgson; Nicole Manduca; Kathy Ress Substantially repeats Exhibit 1. Do not count it as a second independent customer event.	PDF, 3.7 MB
Exhibit 21	pp. 97–100 4 pages	Agent Robert Garner complaint and claim correction Robert Garner; Tyler Deneault; Kathy Ress; Nicole Manduca Separate Ohio roof claim; internal review concluded the original findings supported replacement. Not the West claim.	PDF, 1.5 MB
Exhibit 22	pp. 101–123 23 pages	Growing Together: 2021 market-area partnership Wensley Herbert; Kathy Ress; Ami Kuhlman; Beatrice Lee; Juan Parilo Agent distrust, claim communications, training, and joint agency/claims strategy.	PDF, 5.8 MB
Exhibit 23	pp. 124–125 2 pages	April 2021 quarterly business review OVP Herbert; Fire Weather and AWC Quality, customer experience, management involvement, and operating expense.	PDF, 1.2 MB
Exhibit 24	pp. 126–130 5 pages	April 2020 Oklahoma agency conference call Ami Kuhlman; Vince Watson; broad distribution Storm-response call announcement. A name in a bulk distribution list does not establish personal responsibility for a disputed claim.	PDF, 2.7 MB
Exhibit 25	pp. 131–134 4 pages	Haag hail/wind training development Tom Moss; Melissa Grimmett; Brad Rushton; Tanya Potts March 2020 drafts distinguish engineering instruction from coverage under an insurance policy.	PDF, 1.7 MB
Exhibit 26	pp. 135–153 19 pages	OG 75-160: Wind/Hail Roofing Guidelines, April 18, 2018 State Farm operating guide Inspection, repairability, functional damage, waste, steep/height charges, starter, ridge, prior losses, experts, and related topics. Historical guidance, not proof of current terms.	PDF, 9.6 MB
Exhibit 27	pp. 154–160 7 pages	2021 quality plan and Haag training requirements Eileen Colbert; Pete McArdle; Katina Butler; Gwen Hodgson and others Yearly refresher requirement and new-handler training logistics.	PDF, 2.1 MB
Exhibit 28	pp. 161–163 3 pages	MyBlock training completion tracking Tanya Potts; Marie Dyer; Heather Hanselka; Tom Moss and others Internal reports and completion tracking.	PDF, 1.0 MB
Exhibit 29	pp. 164–166 3 pages	2022 wind/hail training and repair-versus-replace guidance Walter Phillips; Tom Moss; Scott Welsh and training staff Includes a scenario supporting slope replacement even below a 50% repair-cost comparison.	PDF, 1.1 MB
Exhibit 30	pp. 167–177 11 pages	Fire Model Enhancement presentation Fire/claims leadership Rollout dates, selected small-hail/light-wind populations, manager reviews, benchmarks, and financial charts.	PDF, 2.2 MB
Exhibit 31	p. 178 1 page	HRU Stewardship Redesign project record Tyrone Smith listed as VPO sponsor 2023 workflow, ownership, and expense/quality project record; not a statement that every roof replacement must be overturned.	PDF, 0.2 MB

Exhibits 32–44: orders, motions, transcripts and correspondence

The de-designation order that made the packet public, the consolidation fight in Oklahoma County, the Hursh deposition orders, State Farm's own motion describing the West claim, and the Oklahoma Supreme Court's No. 123812 order. These supply the procedural context; they are not findings on the merits.

Exhibit	Filing pages	What it is	Download
Exhibit 32	pp. 179–188 10 pages	August 20, 2026 confidentiality de-designation order Judge Grant Sheperd Grants relief in part but leaves the broader protective order in place.	PDF, 2.7 MB
Exhibit 33	pp. 189–191 3 pages	January 9, 2026 hearing transcript excerpts Judge Don R. Dishman; related Adair/Cox/Pruitt proceedings Selected transcript pages, not a complete hearing transcript.	PDF, 0.7 MB
Exhibit 34	pp. 192–214 23 pages	January 16, 2024 State Farm opposition to consolidation Nida litigation; State Farm and Sheryl Mandeville Historical opposition to broader reassignment/consolidation, attached by the West plaintiffs.	PDF, 7.1 MB
Exhibit 35	pp. 215–229 15 pages	January 23, 2026 motion for limited corporate-discovery consolidation Adair; 22 identified Oklahoma County cases State Farm explains its efficiency rationale and identifies the proposed consolidation candidates.	PDF, 4.5 MB
Exhibit 36	pp. 230–238 9 pages	February 10, 2026 objection to partial consolidation Adair plaintiff and counsel Opposition addressing case-specific agents, facts, discovery posture, and governing rules.	PDF, 2.7 MB
Exhibit 37	pp. 239–247 9 pages	May 21, 2026 court communication on consolidation Judge Dishman through courtroom staff; counsel Written discovery consolidation denied; potential deposition limits left for discussion.	PDF, 3.5 MB
Exhibit 38	pp. 248–260 13 pages	July-August 2026 scheduling and consolidation emails Counsel and Judge Dishman courtroom staff Communications about a status conference and coordination.	PDF, 5.2 MB
Exhibit 39	pp. 261–264 4 pages	December 31, 2025 Hursh journal entry Judge Amy Palumbo Denies several motions to quash corporate and individual depositions.	PDF, 1.0 MB
Exhibit 40	p. 265 1 page	July 2026 West deposition order Judge Grant Sheperd Handwritten hearing order, filed July 24, concerning Ress, Herbert, Moss, and Welsh.	PDF, 0.3 MB
Exhibit 41	pp. 266–279 14 pages	August 2026 State Farm motion to consolidate executive depositions West; State Farm; four executives Includes the insurer's own summary of the June 15, 2023 loss, approximately $50,000 roof dispute, and pleaded causes of action.	PDF, 4.1 MB
Exhibit 42	p. 280 1 page	June 23, 2026 Oklahoma Supreme Court order, No. 123812 State Farm v. Palumbo; Hursh and other real parties Application to assume original jurisdiction denied. Different proceeding from No. 123739 / 2026 OK 51.	PDF, 0.2 MB
Exhibit 43	pp. 281–284 4 pages	August 4, 2026 Hursh hearing transcript excerpts Judge Amy Palumbo Selected pages addressing depositions, document production, and trial preparation.	PDF, 1.0 MB
Exhibit 44	p. 285 1 page	August 4, 2026 Hursh court minute Judge Amy Palumbo Deposition and production directions; contains permission to use production in West.	PDF, 0.5 MB

Source integrity and how to cite

Each exhibit was cut from the source PDF at its exhibit sticker and checked page by page against the original. The files reproduce the pages as filed: original confidentiality stamps, production numbers and the filing party's highlighting are all preserved, and nothing has been redacted, annotated or re-ordered. The extraction manifest records every page range and SHA-256 hash, including the source file's (22aedef62ecf1c8d…).

Cite by exhibit number, Bates or production number and the physical page of the filing, for example "Exhibit 6, WEST00020276, filing p. 43." An old "Confidential" stamp on a page is not evidence that the page remains sealed: the 20 August 2026 order de-designated these materials, while leaving the wider protective order in place for documents it did not address.

This is one public filing and its attachments, not State Farm's full discovery production, and no document here is a court's finding of bad faith. The originals contain historical business contact details as filed; they are reproduced from the public court record, and a party with a correction or a request may contact Mantis Claims Group.