IN THE CIRCUIT COURT OF PLATTE COUNTY, MISSOURI        JUN 26 2007 
FARM BUREAU MUTUAL INSURANCE CO. INC. 
Plaintiff,
vs.

ROBERT E. BALTZELL,
Defendant.

Case No. 07AE-CV02112
PETITION
Plaintiff, Farm Bureau Mutual Insurance Co., Inc. ("Farm Bureau"), for its cause of
action against defendant Robert E. Baltzell, states as follows:
1. Plaintiff Farm Bureau is an Iowa corporation in good standing authorized to do
and doing business in the state of Missouri.
2. Defendant, Robert E. Baltzell, is an individual and may be served with process at
1013 NE Maple Drive, Gladstone, Clay County, Missouri 64118-4846.
3. On June 28, 2002, Phillip and Barbara Dierks were the owners of a 2000 Pontiac
Grand Prix insured by Farm Bureau.
4. On or about June 28, 2002, Phillip Dierks was operating the aforesaid vehicle
owned by Dierks in which Barbara Dierks was a passenger, and was lawfully stopped at a stop
light at the intersection of Green Hills Road and 152 Highway West in Platte County, Missouri,
when Defendant Baltzell failed to stop and hit Dierks' vehicle in the rear, pushing Dierks'
vehicle into another car.
5. Due to the negligence of Baltzell as described above, Phillip Dierks received
personal injuries that required medical treatment and the Dierks sustained property damage to
their vehicle.
6. The sole and proximate cause of the injuries to Phillip Dierks and the property
damages and related expenses sustained by Phillip and Barbara Dierks was the negligence of
Baltzell.
At the time of the collision, Phillip and Barbara Dierks were insureds under an
Insurance policy issued by plaintiff. Pursuant to the terms of the policy, plaintiff paid
$39,571.43 in reimbursement of the Dierks' injuries, damages and expenses as follows:
Property Damage to the Dierks' vehicle  $2991.21
Rental vehicle fees $150.00

Bodily injury  $21,500.00
Medical expenses $9500.00
Lost wages $4930.00
Attorneys' fees  $500.00
8. Farm Bureau, pursuant to its policy of insurance issued to the Dierks, is
subrogated to the rights of the Dierks to pursue this action against Baltzell to recover from
Baltzell the amounts it paid as a result of the collision.
WHEREFORE, Plaintiff pray for judgment against Defendant, Richard E. Baltzell, for
the total amount of $39,571.43, for interest as allowed by statute, for costs, and for such other
and further relief as the Court deems just and proper.
Timothy P. McCarthy MO#58431
8717 W. 110th Street Suite 630 Overland Park, KS 66210 (913) 317-5100
Fax (913) 317-9100
ATTORNEYS FOR PLAINTIFF FARM BUREAU MUTUAL INSURANCE COMPANY