If you read Locked and loaded with State Farm in crosshairs, Rigsbys plan to remove Renfroe before pulling the trigger, you’ve been waiting for me to update the Rigsby qui tam file under Legal in the left side bar. It’s done and the Branch qui tam has been moved to a separate file to make room for my adding more documents to both.
As mentioned in the post, the Rigsbys’ exhibits came from documents in the public domain. In the Affidavit supporting their Response the Relators’ added the potential need for additional information through Discovery, noting as yet there has been none.
As set forth in the Relators’ Consolidated Pre-hearing Response to All Dispositive Motions, Relators respectfully submit that the dispositive motions should be denied on the merits. In the alternative, however, the Relators seek discovery to present an opposition to the dispositive motions.
The requested discovery would include all documents in State Farm’s possession relating to its adjustment of the McIntoshes’ claims following Hurricane Katrina. This includes but is not limited to: complete damage estimates, transaction logs, digital photographs of the McIntosh home, and correspondence relating to Forensics Analysis and Engineering Company’s assessments of the McIntosh home.
The Relators also request that they be allowed to depose the following individuals with direct knowledge of the damage to the McIntosh home and its claims adjustment: Alexis King, Brian Ford, John Kelly, Mike Church, Craig Robertson, and Ron and Linda Muchk.
If I didn’t know better, I’d think qui tam meant “wait and see”.