(The Jensen Petition) 
FILED JAN. 18 2008

IN THE CIRCUIT COURT OF KNOX COUNTY,
CHERYL R. JENSEN, 700 Cleveland  Moberly, Missouri 65270 
Plaintiff,
vs.
FARM BUREAU TOWN & COUNTRY INSURANCE COMPANY OF MISSOURI
P.O. Box 658 701 South Country Club Drive Jefferson City, Missouri 65102
Serve Registered Agent: DanCassidy
701 S. Country Club Drive P.O. Box 658 Jefferson City, Missouri 65102 Defendant.
Cir. Clerk Knox County
Case No. 07KN-CC00004
PETITION FOR DAMAGES
Count I
Breach of Contract
COMES NOW the Plaintiff, Cheryl R. Jensen, by and through her attorneys, Briggs & Reuschel, L.L.C., and for the Plaintiff's cause of action, states:
1. That Plaintiff is and at all times relevant hereto was a resident of the city of Moberly, Randolph County, Missouri.
2. That Defendant is a corporation duly organized and existing under the laws of the State of Missouri, whose principal place of business is in Cole County, Missouri.
3. That at all times relevant hereto Plaintiff owned real property located at 403 West Lafayette, Edina, Knox County, Missouri.
3. That at all times relevant hereto Plaintiff owned real property located at 403 West Lafayette, Edina, Knox County, Missouri.
4. Prior to September 23, 2006, Defendant issued and delivered to Plaintiff an insurance policy on 403 West Lafayette, Edina, Knox County, Missouri covering loss due to, but not limited to, fire.
5. That on or about September 23, 2006, Plaintiff suffered a loss of property due to fire on the contents of property located at 403 West Lafayette, Edina, Knox County, Missouri.
6. That Plaintiff's insurance policy was in force on September 23, 2006.
7. That Plaintiff paid her insurance policy premiums and satisfied all conditions precedent, pursuant to her policy tex:.ms and conditions.
8. That Plaintiff claimed loss to the Defendant in the amount of $27,024.35 due to fire on the property located at 403 West Lafayette, Edina, Knox County, Missouri, pursuant to the those terms prescribed to her by Defendant and its agents.
9. That on or about May 10, 2007, Plaintiff received notice that Defendant denied Plaintiff's claim for coverage of her loss suffered on September 23, 2006.
10. That despite being furnished with documentation detailing Plaintiff's loss, Defendant has failed and refused to pay to pursuant to her insurance policy.
WHEREFORE, Plaintiff requests judgment against Defendant in an amount which is fair and reasonable, for interest at a rate of Nine Percent (9%) per annum, including prejudgment interest, for costs and all other appropriate relief.
Count II
Vexatious Refusal to Pay by Insurance Company
COMES NOW Plaintift and fer its cause of action against Defendant, respectfully states as follows:
11. Plaintiff restates and realleges paragraphs 1 through 10 of Count I of Plaintiffs' Petition.
12. That on or about September 23, 2006, Plaintiff suffered a loss of property due to fire on the contents of property located at 403 West Lafayette, Edina, Knox County, Missouri.
13. That Defendant denied coverage of Plaintiff's loss, and that more than thirty (30) days have passed since Defendant's denial of coverage.
14. That Defendant has refused to pay Plaintiff for fire damage to her property located at 403 West Lafayette, Edina, Knox County, Missouri, without reasonable cause or excuse.
15. That Plaintiff has suffered damages in the amount of $27,024.35.
WHEREFORE, Plaintiff prays for judgment against Defendant in an amount that is fair and reasonable, including those damages provided for pursuant to Sections 375.296 RSMo. and 375.420 RSMo., plus lawful interest from the date said sums were due and owing, for its costs and for such other and further relief as the Court deems just and proper.
BRIGGS & REUSCHEL, L.L.c. 201 S. Baltimore, Suite B
P.O. Box 710
Kirksville, Missouri 63501 (660) 665-4300 Telephone
(660) 665-4303 Facsimile ATTORNEYS FOR PLAINTIFF

IN THE CIRCUIT COURT OF THE COUNTY OF KNOX STATE OF MISSOURI
FILED MAR - 5 2008
CHERYL RAY JENSEN,  
Plaintiff,  
v. 

FARM BUREAU TOWN & COUNTRY  INSURANCE COMPANY OF MISSOURI
Defendant, 
Cause No. 08KN-CC00004 
ANSWER TO PLAINTIFF'S PETITION
COMES NOW Defendant, Farm Bureau Town & County Insurance Company of
Missouri, by and through the undersigned counsel, and for its Answer to Plaintiffs Petition,
states as follows:
COUNT I - BREACH OF CONTRACT
1. Defendant is without sufficient information to form a belief as to the truth or
falsity of this allegation and, therefore, denies the same.
2. Admit.
3. Admit.
4. Defendant admits that it issued a policy of insurance to Plaintiff having Policy
Number PRO 0043931 08 with a policy period of September 16, 2006 to September 16, 2007.
Defendant denies each and every remaining allegation contained in Paragraph 4 of Plaintiff s
Petition.
5. Defendant admits there was a fire on or about September 23, 2006 at 403 West
Lafayette, Edina, Missouri. Defendant denies each and every remaining allegation contained in
Paragraph 5 of Plaintiff s Petition.
6. Defendant admits that it issued a policy of insurance to Plaintiff having Policy
Number PRO 0043931 08 with a policy period of September 16, 2006 to September 16, 2007.
Defendant denies each and every remaining allegation contained in Paragraph 6 of Plaintiff s Petition.
7. Deny.
8. Deny.
9. Deny.
10. Deny.
AFFIRMATIVE DEFENSES
A. For further answer and Defendant's first affirmative defense, Defendant states
that Count I of Plaintiff s Petition has failed to state a claim for which relief can be granted.
B. For further answer, and Defendant's second affirmative defense, Defendant states
that there is no coverage and Plaintiff is barred from recovery under the insurance policy because
Plaintiff intentionally misrepresented the extent and amount of her personal property claim. As
such, coverage for the claimed loss is specifically precluded pursuant to the following provisions
contained in the policy:
GENERAL POLICY CONDITIONS APPLYING TO SECTION I AND SECTION II 
5. CONCEALMENT, FRAUD, OR MISREPRESENTATION
We do not provide coverage for any insured who has concealed any fact, . made fraudulent statements, misrepresentations, or engaged in fraud in connection with any application for insurance, accident, or loss for which coverage is sought under this policy.
COUNT II
11. Defendant restates and incorporates herein by reference Paragraphs 1-10 of
Plaintiff s Petition.
12. Defendant admits there was a fire on or about September 23, 2006 at 403 West
Lafayette, Edina, Missouri. Defendant denies each and every remaining allegation contained in
Paragraph 12 of Plaintiffs Petition.
13. Admit.
14. Deny.
15. Deny.
AFFIRMATIVE DEFENSES
A. For further answer and Defendant's first affirmative defense, Defendant states
that Count II of Plaintiff s Petition has failed to state a claim for which relief can be granted.
B. For further answer, and Defendant's second affirmative defense, Defendant states
that there is no coverage and Plaintiff is barred from recovery under the insurance policy because
Plaintiff intentionally misrepresented the extent and amount of her personal property claim. As
such, coverage for the claimed loss is specifically precluded pursuant to the following provisions
contained in the policy:
GENERAL POLICY CONDITIONS APPLYING TO SECTION I AND SECTION II
5. CONCEALMENT, FRAUD, OR MISREPRESENTATION
We do not provide coverage for any insured who has concealed any fact, made fraudulent statements, misrepresentations, or engaged in fraud in connection with any application for insurance, accident, or loss for which coverage is sought under this policy.

WHEREFORE. having fully answered Plaintiff's Petition, Defendant prays for dismissal
with prejudice, for its costs, and for any further relief this Court deems just and proper under the circumstances. 

Robert L. Brady, #47522 
Jonathan B. Morrow, #58661 BROWN & JAMES,P.C.
1010 Market Street, 20th Floor S1. Louis, MO 63101-2000
(314) 421-3400 - Phone
(314) 421-3128 -Fax
rbrady @bipc.com     jmorrow@bipc.com
Attorneys for Defendant
Farm Bureau Town & County Insurance Company of Missouri

CERTIFICATE OF SERVICE
A true and accurate copy of the foregoing was sent via the United States Postal Service, first class postage prepaid, this 3rd day of March, 2008 to: Timothy A. Reuschel, BRIGGS & REUSCHEL, LLC, 201 S. Baltimore, Suite B, P.O. Box 710, Kirksville, MO 63501, 660-6654300, 660-665-4303 Facsimile, Attorney for Plaintiff Jensen.