(Karen Sanders Petition)
IN THE CIRCUIT COURT OF CARTER COUNTY, MISSOURI.
KAREN SANDERS,
Plaintiff,
Case No. 04CV612899
vs
FARM BUREAU TOWN AND COUNTRY INSURANCE OF MISSOURI,
Defendant.
PETITION
Comes now Plaintiff and for her cause of action, states and alleges to the
Court as follows:
1. Plaintiff is a resident of the County of Carter, State of Missouri.
2. Defendant is an insurance company organized and existing under
the laws of the State of Missouri, designating the Superintendent of Insurance
as the entity to accept service on their behalf.
3. This cause of action arose in Carter County, Missouri.
4. That at all times pertinent hereto, Plaintiff was the owner of a 1994
Acura Integra automobile, which was insured by the Defendant under a policy
of insurance bearing policy number 2NH091J 1.
5. That on or about October 18,2004, the before mentioned
automobile was involved in an accident which totaled said automobile. The
coverage under the policy aforesaid provided for collision. However, the
Defendant has failed and refused to pay the damages for the vehicle to Plaintiff.
WHEREFORE, Plaintiff prays Judgment against Defendant in a sum
equal to the value of the automobile pursuant to the policy, and for whatever
other order and relief the Court deems just and proper.
MOORE, WALSH & ALBRIGHT, L.L.P. Attorneys at Law
Daniel T. Moore
P.O. Box 610 Poplar Bluff, MO 63902-0610 573/785-6200
ATTORNEY FOR PLAINTIFF
(Farm Bureaus Answer)
IN THE CIRCUIT COURT OF CARTER COUNTY, MISSOURI
KAREN SANDERS,
Plaintiff,
v.
FARM BUREAU TOWN AND COUNTRY INSURANCE OF MISSOURI,
Defendant.
Case No. 05AK-CV00076
ANSWER
Comes now the Defendant, Farm Bureau Town and Country Insurance of Missouri,
by and through its attorneys, Spain, Merrell and Miller, LLC, and in answer to the
Plaintiff's Petition, states to the Court as follows:
1. Admits the allegations contained in paragraphs one, two, and three.
2. Denies the allegations contained in paragraphs four and five.
WHEREFORE, having fully answered, Defendant prays Judgment in its favor, for
its costs expended herein, and for such other and further relief as the Court may deem
just and proper.
By
Samuel1 Spain #34050 Attorneys at Law
1912 Big Bend Post Office Box 1248 Poplar Bluff, MO 63902 (phone) 573/686-5868 (fax) 573/686-6885
ATTORNEYS FOR DEFENDANT