Oh my God! State Farm files motion to compel New Light Baptist Church to supplement discovery
I come to the Garden alone
While the dew is still on the roses
and the voice I hear, falling on my ear…
is Scott Spragins – and he walks with me and he talks with me and he tells me:
State Farm propounded its First Set of Interrogatories and First Request for Production on 6 May 2009. Plaintiff propounded responses to State Farm’s interrogatories and request for production on 6 May 2009. (Plaintiff’s Responses to Interrogatories and Request for Production attached as Exhibit A).
On 27 May 2009 State Farm’s counsel directed the attached Good Faith Letter to Plaintiffs’ counsel in an attempt to secure supplemental responses. (Good Faith Letter attached as Exhibit B [Exhibits B-F ]). State Farm’s counsel specifically advised that “[m]any of these responses are evasive or incomplete,and require immediate supplementation.” (see Exhibit B).
State Farm's Motion to Compel Supplemental Discovery from New Life Baptist Church: Exhibit E
On 21 July 2009 Plaintiff’s counsel advised it was working with Pastor Nathaniel Smith and that it would supplement discovery no later than 4 August 2009. (see Exhibit C). On 19 August 2009 after Plaintiff failed to provide supplemental responses by 4 August 2009, counsel for State Farm again wrote requesting same. (see Exhibit D).
Finally on 21 August 2009 counsel for Plaintiff advised “after careful consideration by the Pastor, he has determined that he is unable to add anything further.” (see Exhibit E).
The apostle Paul instructed the Corinthian believers to not go to court against one another (1 Corinthians 6:1-8). For Christians not to forgive each other and reconcile their own differences is to demonstrate spiritual defeat. Why would someone want to become a Christian if Christians have just as many problems and are just as incapable of solving them? However, there are some instances when a lawsuit might be the proper course of action. If the biblical pattern for reconciliation has been followed (Matthew 18:15-17) and the offending party is still in the wrong, in some instances a lawsuit might be justified. This should only be done after much prayer for wisdom (James 1:5) and consultation with spiritual leadership.
Matthew 18: 15-17 provides context for Exhibit A , the Plaintiffs’ response.
Perhaps Deborah Trotter’s response to the motion will tell how Pastor Smith determined that he is unable to add anything further.
Did he, for example, look at the location of the church on the map and take note of the distance from the Gulf and ask her what water the policy covered.
Given the Scriptural guidance, did he ask her what information the all-risk policy required a policyholder to provide and determine the Church had fulfilled its obligation?
Perhaps, he did both and then looked at what Katrina left the congregation according to the google map of the location.
That said, the question is how much this one is going to cost State Farm.
Plaintiff, New Light Baptist Church, requests that this Court enter an award of actual, compensatory and consequential damages, prejudgment interest, costs of this action, and such other and further relief as this Court deems just and appropriate.
Since it’s a Church, just and appropriate further relief would be an additional 10% on top – although a true tithe would be 10% of State Farm. Do I hear an amen to that?
Did he, for example, look at the location of the church on the map and take note of the distance from the Gulf and ask her what water the policy covered.