IN THE CIRCUIT COURT OF PEMISCOT COUNTY, MISSOURI
MISSOURI FARM BUREAU INSURANCE  BROKERAGE, INC., FARM BUREAU TOWN & COUNTRY INSURANCE COMPANY OF
MISSOURI, AND FARM BUREAU LIFE INSURANCE COMPANY OF MISSOURI, 
Plaintiffs,
v
PARKER FAULKNER,
Serve: 2813 Playground Road Caruthersville, MO 63830
Defendant.
PETITION
COME NOW plaintiffs Missouri Farm Bureau Insurance Brokerage, Inc., Farm Bureau Town & Country Insurance Company of Missouri and Farm Bureau Life Insurance co of Missouri
and, for their Petition against defendant Parker Faulkner. states: 
COUNT I
Claim for Preliminary and Permanent Injunction
1. Plaintiff Missouri Farm Bureau Insurance Brokerage, Inc. is a Missouri corporation
with its principal place of business in Jefferson City, Missouri.
2. Plaintiff Farm Bureau Town & Country Insurance Company of Missouri is a property
and casualty insurance company incorporated under the laws of the State or Missouri with its
principal place of business in Jefferson City, Missouri.
3. Plaintiff Fann. Bureau Life Insu.ran.ce Company of Missouri is a life insurance
company incorporated under the laws of the State of Missouri with its principal place of business
in Jefferson City, Missouri.
4. Defendant Parker Faulkner is an individual residing in Pemiscot County, Missouri.
5. From February 1, 1993 until January 5~ 2007, defendant Parker Faulkner was an
employee of Missouri Farm Bureau Insurance Brokerage, Inc. In his capacity as an employee of
Missouri Farm Bureau Insurance Brokerage, Inc .. defendant was responsible to market and service
insurance products for plaintiffs as an insurance agent of Farm Bureau Town & Country and Farm
Bureau Life and to also market and service insurance products offered through Missouri Farm
Buteau Insurance Brokerage, Inc.
6. In consideration for employment with Missouri Farm Bureau Insurance Brokerage,
Inc., defendant entered into a written employment agreement (a copy of said employment agreement
is attached hereto as Exhibit "A" and incorporated herein by reference).
7. The aforementioned employment agreement provides as follows concerning the
obligations of defendant in. the event his employment with Missouri Farm Bureau Insurance
Brokerage, Inc. is terminated for any reason:
9. Non-Interference. In the event that I shall cease to represent the Companies, J will not, either personally or through any other person, agency, or organization disturb the business which shall be on the books of the Companies at the time my employment is terminated by either of us. I will not solicit the renewals of said business recognize that it belongs to the Companies. I will permit the Companies to continue in full and peaceable possession of' said business. I further understand and agree that in the event this agreement is violated , the companies may obtain damages for its breach or may obtain injunctive or other equitable relief against me without the necessity or requirement of posting a bond, each or otherwise, from further violations of this agreement.

8. Defendant's employment with Missouri Farm Bureau lnsurance Brokerage, Inc. was
terminated on January 5, 2007.
9. Subsequent to termination of his employment with Missouri Farm Bureau Insurance
Brokerage, Inc., defendant became, and is currently, an insurance agent for Anthem Blue Cross Blue
Shield and other insurers.
10. Subsequent to the termination of defendant's employment with Missouri Farm Bureau
Insurance Brokerage, Inc., defendant, in violation of the aforementioned Agreement, specifically
paragraph 9 of said Agreement, has solicited Insureds of Farm Bureau Town & Country, Farm
Bureau Life and clients of Missouri Farm Bureau Insurance Brokerage, Inc. for purposes of induceing
them to cancel or non-renew their policies with Farm Bureau Town & Country and/or Farm Bureau
Life and or insurance carriers whose business was placed through Brokerage and place their
insurance with insurance companies that defendant currently represents, including Anthem Blue
Cross Blue Shield,
11. Upon information and belief, defendant has further breached his contractual
obligations, as set forth in the aforesaid Agreement in that, u.pon information and belief, subsequent
to termination of his employment with Missouri Farm Bureau Insurance Brokerage, defendant,
without plaintiffs' knowledge or consent, has utilized and continues to utilize trade secrets and
proprietary information of plaintiffs, including customer lists and personal customer information, for purposes of soliciting insureds of Farm Bureau Town & Country and Farm Bureau Life clients of Missouri Farm Bureau Insurance Brokerage on behalf of insurance companies defendant currently represents.
12. Unless defendant is enjoined from continuing to contact or solicit insureds of the plaintiffs
, and is enjoined from accessing, divulging or utilizing plaintiffs' trade secrets or other
proprietary infonnation, including, but not limited to, its customer !ists, as an insurance agent for
insurance companies who compete with plaintiffs, plaintiffs will suffer irreparable harm, injury and
damage, for which they have no adequate remedy at law. 

WHEREFORE, plaintiffs Missouri Farm Bureau Insurance Brokerage, Inc .• Farm Bureau
Town & Country Insurance Company of Missouri and Farm Bureau Life Insurance Company pray
for an order and judgment ofthis Court against defendant as follows:
a. Enjoining defendant from directly or indirectly contacting or soliciting the
p.laintiffs' insurance customers/clients who were insurance customers/clients of
plaintiffs as of the date oftermit,ation of defendant's employment agreement with
Missouri Farm Bureau Insurance Brokerage;
b. Enjoining defendant from directly or indirectly divulging any of plaintiffs'
trade secrets or proprietary information ofwhicb he has acquired knowledge during
thc course of his employment with plaintiff Missouri Farm Bureau Insurance
Brokerage, Inc., or subsequent to the termination of such employment, to any third
parties;
c. Ordering defendant to return to plaintiffs all trade secret and proprietary
informatjon including, but not limited to, customer lists and customer insurance
infomation which defendant improperly obtained from plaintiffs.
d. Enjoining defendant from contacting directly or attempting to induce any of plaintiffs' customers/clients 
or termmate thier business relationships with plaintiffs.
e. That pending final determination of this cause, the Court grant a permanant
injunction to the same effect;
1'. Grant plaintiffs such actual d.amages as plaintiffs have sustained as a result
of defendant's breach of the Agreement between plaintiffs and defendant;
g. Grant plaintiffs their attorney's fees and expenses in prosecuting this action; 

h. For such further relief as the Court deems just and proper.

COUNT II

COME NOW plaintiffs Missouri Farm Bureau lnsurance Brokerage, Inc., Farm Bureau Town

& Country Insurance Company of Missouri and Faun Bureau Life Insurance Company and, for

Count Il of their Petition against defendant Parker Faulkner. states:

13. Plaintiffs incorporate by reference, as if set forth in full herein, the allegations

contained in paragraphs 1-12 of Count I of plaintiffs' Petition.

14. As a result of defendant's breach of his contractual obligations, as aforesaid, plaintiffs

have sustained damages by reason of the loss of premiurn income and/or commissions as a result of

defendant's unlawful and unauthorized solicitation of plaintiffs' customers/clients and unlawfully

using plaintiffs' proprietary and trade secret information.

WHEREFORE, plaintiffs Missouri Farm Bureau Insurance Brokerage, Inc., Farm Bureau

Town & Country Insurance Company of Missouri and Farm Bureau Life Insurance Company pray

for judgment in their favor and against defendant for damages sustained;i

as the Court deems just and proper.

By:

Dana L. Frese 515 E. High Street
P.O. Box 28
Jefferson City, MO 65102 (573) 636-2177
(573) 636-7119 fax 

and

SPAIN, MERRELL AND MILLER

By:
Samuel P. Spain 1912 Big Bend P.O. Box 1248
Poplar Bluff. MO 63902 573-686-5868 573-686-6885 Fax
Attorneys for Plaintiffs


(court actions filed in this case)
34th Judicial Circuit (New Madrid & Pemiscot Counties)
07PE-CV00168 - MO FARM BUREAU INS ET AL V PARKER FAULKNER
This information is provided as a service and is not considered an official court record.
Displaying 1 thru 9 of 9 dockets returned for case 07PE-CV00168.

03/28/2007 Docket Entry: Pet Filed in Circuit Ct

Docket Entry: Summons Issued-Circuit
Text: Document ID: 07-SMCC-220, for FAULKNER, PARKER;

04/02/2007 Docket Entry: Summons Personally Served
Text: Document ID - 07-SMCC-220; Served To - FAULKNER, PARKER; Server - SO PEMISCOT CO-CARUTHERSVILLE; Served Date - 29-MAR-07; Served Time - 00:00:00; Service Type - Sheriff Department; Reason Description - Served

04/18/2007 Docket Entry: Entry of Appearance Filed
Filing Party: SPAIN, SAMUEL P.

Docket Entry: Application Filed
Text: Application for Change of Venue
Filing Party: SPAIN, SAMUEL P.

05/01/2007 Docket Entry: Entry of Appearance Filed
Text: on behalf of Defendant Parker Faulkner.
Filing Party: O'LOUGHLIN, TOM K II

Docket Entry: Motion to Dismiss
Text: Defendant Faulkner's Motion to Dismiss For Failure to State a Cause.
Filing Party: O'LOUGHLIN, TOM K II

05/09/2007 Docket Entry: Memorandum Filed
Text: Defendant Faulkner's Legal Memorandum in Support of his Motion To Dismiss.
Filing Party: O'LOUGHLIN, TOM K II

Docket Entry: Motion Filed
Text: Defendant Faulkner's Motion To Strike Prayer For Attorney's Fees.
Filing Party: O'LOUGHLIN, TOM K II

Displaying 1 thru 9 of 9 dockets returned for case 07PE-CV00168.