IN THE CIRCUIT COURT OF CAMDEN COUNTY STATE OF MISSOURI
DENNIS AND TANYA NEWBERRY 
Plaintiff,  
vs. 

 FARM BUREAU TOWN AND  COUNTRY INSURANCE COMPANY  OF MISSOURI  
Missouri Farm Bureau Insurance 701 South Country Club Drive  Jefferson City, Cole County, MO 65102 ) 
Defendant.

PETITION
Case No. 07CM-CC00390
FACTS COMMON TO ALL COUNTS
COMES NOW Plaintiffs by and through their attorney, Lewis Z. Bridges and
state:
1. That they are residents of Camden County, Missouri.
2. That the Defendant is a mutual insurance company doing business within
the State of Missouri and the County of Camden.
3. That on or about August 5,2006 the Defendant issued its policy of
insurance No. BT 0206323 03 to the Plaintiff.
4. That said policy of insurance insured a certain 1990 Sea Ray boat VIN
SERP 1335D090 owned by the Plaintiff against certain perils described within said policy.
5. That on or abou~December 2,2006 said boat was damaged in an ice and snow storm within the County of Camden, State of Missouri.
6. That thereafter the Plaintiffs made claim against the policy of insurance described about.
7. That pursuant to the provisions of said policy of insurance. The Plaintiffs have elected to retain the property and receive from the Defendant payment for the difference between the actual cash value of the boat prior to the damage and its salvage value.
COUNT I BREACH OF CONTRACT
COMES NOW Plaintiffs by and through their attorney, Lewis Z. Bridges and for their cause of action in Count I of this Petition state and allege as follows:
1. That they hereby incorporate all allegations contained in paragraphs one through seven of their Allegations Common to All Counts.
2. That the actual cash value of the property prior to damage is the sum of $80,000.00.
3. That the salvage value of the above described boat following the damage is the sum of $13,200.00.
4. That the Defendants have failed and refused to pay the damages to Plaintiff pursuant to the contract of insurance entered into between them although demand for same has been made.
5. That the failure to so pay constitutes a breach under the terms of the contract described hereinabove. 
6. That the Plaintifl's have fully performed all their obligations under said contract.
7. That the Defendants are indebted to the Plaintiffs in the sum of $66,800.00.
WHEREFORE, Plaintiffs pray Judgment against the Defendant in the sum of $66,800.00, for their costs herein expended, and for such other and further orders as the Court may deem just in the premises.
COUNT II
BREACH OF COVENANT OF GOOD FAITH AND FAIR DEALING COMES NOW Plaintiffs by and through tneir attorney, Lewis Z. Bridges and for their cause of action in Count II of this Petition state and allege as follows:
1. Plaintiffs hereby incorporate by this reference all allegations contained in paragraphs one seven of their Allegations Common to All Counts and paragraphs two through seven of Count I of this Petition.
2. That the Defendant herein represented to the Plaintiffs that they had obtained estimates salvage values for the property described hereinabove ranging between $25,000.00 and $35,000.00 and established the salvage value at $32,500.00.
3. That said representations were false and were made for the purpose of gaining advantage of the Defendants in the negotiations concerning amount of payment of the sums due under the contract described herein above. 
4. That said actions colistitute a breach of the covenant of good faith and fair dealing present in every contract within the State of Missouri and entitle the Plaintiff to damages as described above.
WHEREFORE, Plaintiffs pray Judgment against the Defendant in the sum of $66,800.00, for their costs herein expended, and for such other and further orders as the Court may deem just in the premises.
Respectfully submitted,

Lewis Z. Bridges, Missouri Bar No. 28101 Curran & Sickal
3750 Highway 54, Suite 100 Osage Beach, Missouri 65065 Telephone: 573-348-3157 Facsimile: 573-348-3093
ATTORNEY FOR PLAINTIFFS


(Farm Bureaus Answer)  Not yet filed