The Oklahoma Supreme Court delivered a significant ruling in 2025 that establishes clear boundaries for discovering financial information from expert witnesses in civil litigation. In Jolley v. McClain, Oklahoma Supreme Court 2025, the court addressed whether opposing parties can use subpoenas duces tecum to obtain broad financial records from expert witnesses, ultimately holding that such discovery methods exceed the scope permitted under Oklahoma’s Discovery Code.
Background and Parties
The case arose from a condemnation action initiated by the Oklahoma Department of Transportation (ODOT) against Christopher Charles Jolley. ODOT sought to acquire a strip of land owned by Jolley for public use, but when negotiations failed, the agency filed a condemnation proceeding in Garvin County District Court. Following standard Oklahoma condemnation procedures under 69 O.S. § 1203, three disinterested freeholders were appointed as commissioners to appraise the property value.
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