Surreply may be filed if opposing party introduces new material in its reply.
Mend the Hold Doctrine has been adopted in Oklahoma.
Should this court rule plaintiff has no standing, plaintiff should be granted leave to amend as executor of deceased’s estate.
Oklahoma law applies to this cause of action.
Oklahoma law should apply to the contract claim.
But, should court apply Georgia Law to contract claim, court should not dismiss contract claim.
Oklahoma law should apply to the tort claim.
Petition is sufficient as it satisfies Iqbal but to extent court rules complaint does not satisfy Iqbal, plaintiff should be granted leave to amend.
Plaintiff’s claims not time-barred because statute of limitations tolled by Servicemembers Civil Relief Act.
Ambiguous policy language should be construed against defendants.
Original policy and reinstated policy different enough to trigger new policy based on reinstatement language.